(the RIPA Board) charged with its implementation. Of course, law enforcement agencies are not free to disregard the laws and regulatory agencies they dislike or disagree with. Nevertheless, since the insupportable PORAC theory appears to have gained some adherents in San Rafael law enforcement, we are providing a memorandum on RIPA Reliability (attached and linked here) that briefly describes how the statute and the Board operate, and the failings of the PORAC theory.
Sincerely,
MVFREE Police Team
Helen Bruner
Tammy Edmonson
Tara Evans
Ginna Fleming
Frank Leidman
Barbara Rothkrug
Ed Rusly
[1]
At the May 21 hearing the PAAC expressed the intention to adopt the four full recommendations as proposed by MVFREE. When individual members moved to adopt each of the four recommendations, they used short-hand titles rather than reading the full text of each recommendation. The Annual Report references these these short-hand titles.
For the benefit of the City Council and the public, the Addendum includes the full text of each recommendation and all of their requisite elements.
2/27/26, 3:39 PM Mail - Lindsay Lara - Outlook
https://outlook.office365.com/mail/inbox/id/AAkALgAAAAAAHYQDEapmEc2byACqAC%2FEWg0AOJ8v9gzPFE6wSNu2pNW1awAJqVlt%2FAAA 2/2 mvfree.org; [email protected]
MVFREE Addendum to PAAC Annual Report (March 2, 2026) 1 MVFREE Addendum to PAAC Annual Report:
Equitable Policing Recommendations (May 21, 2025)
Racial and Identity Profiling Act (RIPA)
On May 21, 2025, at the PAAC’s request, MVFREE data analyst, Tammy Edmonson, presented on the 2025 Report of the State RIPA Board,
1 and what San Rafael Police Department (SRPD) RIPA data reveals regarding policing disparities in this community. Her data-based presentation and supporting documents (May 21, 2021, PAAC Agenda Packet, pp. 16-55) revealed: (A) pervasive state and countywide policing disparities for Black and Latinx people, including in San Rafael; (B) specific practices and conditions that cause and contribute to San Rafael’s racial policing disparities and RIPA-recommended strategies to alleviate them; and (C) how ongoing RIPA monitoring and metrics can ensure continuous improvement toward safe and equitable policing in San Rafael. The data in each of these areas is summarized below.
A. State and Local Racial Stop Disparities
The 2025 RIPA Report reveals
substantial stop disparities in
San Rafael for Black and
Latinx people (Black people
stopped at 6.4 times the rate
of Whites and Latinx people
stopped at 1.8 times the rate
of Whites).
The RIPA Board found this
same pattern of Black and
Latinx stop disparities in
more than 90% of all
California law enforcement
agencies. However, Marin
County law enforcement
agencies, including the
SRPD, had Black and Latinx
stop disparities that were
significantly higher than State
averages.
The statewide data for more
than 500 police agencies
showed that these racial stop
disparities were not justified
by racially disparate findings
of criminal conduct.
1 Both the 2025 Report and the MVFREE analysis were based on mandatory law enforcement reporting of perceived demographic data on every stop in 2023.
mvfree.org; [email protected]
MVFREE Addendum to PAAC Annual Report (March 2, 2026) 4
2. Race-Based Calls for Service
Race-Based Calls for Service (or “Bias by Proxy”) Defined— Too often, community members call the police because seeing someone of another race in their neighborhood makes them uneasy, even though the person is not behaving in a suspicious manner. If police respond, this subjects individuals to unwarranted police interference and contributes to racial policing disparities.
RIPA Board Recommendation—
In 2020, the RIPA Board identified
the critical need for practical
policies to prevent race-based
calls for service. The Board
developed detailed policy and
training recommendations
intended to help officers identify
race-based calls, protect the
subjects of the calls, educate the
callers to prevent future such
calls, and ensure that the
agencies record and monitor the
calls as part of their performance
metrics. 2020 RIPA Report, pp.
54-57.
The Mill Valley Experience—
When 2020 RIPA data showed
that Mill Valley community
members were calling the police
about Black people at nearly 20
times the rate of Whites, the
MVPD and the City of Mill Valley
worked with MVFREE to develop a
RIPA-informed policy, training
and a public education
campaign. The Police Chief made
a public service video, and the
City sent fliers (shown at left) to
every Mill Valley household with
specific guidance on the
appropriate uses of 911.
The Mill Valley effort resulted in a 25% reduction in call for service disparities in the first year. /
/
mvfree.org; [email protected]
MVFREE Addendum to PAAC Annual Report (March 2, 2026) 6 PAAC RECOMMENDATION—PERFORMANCE METRICS AND MONITORING
Member Alm moved to adopt MVFREE recommendation #3 consisting of the following to measure and monitor the effectiveness of any and all SRPD equitable policing strategies:
• Use the initial RIPA disparity finding as the baseline for progress monitoring; • Identify the numerical goal of the remedial strategy (elimination or % reduction in the disparity); and
• Establish and track annual data-informed benchmarks (expected outcomes from the chosen remedial strategy).
o E.g., eliminating SRPD pretext stops is expected to reduce Black stops by 17.8% and reduce Latinx stops by 14.2% in year 1.
o E.g., the three-part bias by proxy strategy is expected to reduce call for service disparities by 25% in year 1.
Member Kamena seconded the motion.
AYES: MEMBERS: Alm, Alvarez, Kamena, Nguyen, Ruiz, Tokolahi, Valdez NOES: MEMBERS: None
ABSENT: MEMBERS: Davidi
PAAC RECOMMENDATION—ANNUAL RIPA EQUITY ASSESSMENT
Member Alm moved to adopt MVFREE recommendation #4 to conduct an annual RIPA equity assessment consisting of the following to ensure continuous progress toward safe and equitable policing:
• Monitor progress and refine existing remedial strategies as needed; • Gradually expand areas of analysis until all potential areas of concern have been assessed; • Adopt targeted remedial strategies to address any newly discovered disparities; and • Establish performance metrics for new and ongoing strategies for the coming year.
Member Kamena seconded the motion.
AYES: MEMBERS: Alm, Alvarez, Kamena, Nguyen, Ruiz, Tokolahi, Valdez NOES: MEMBERS: None
ABSENT: MEMBERS: Davidi
Status: The PAAC’s annual report indicates that the PAAC’s two recommendations pertaining to ongoing RIPA monitoring are “under consideration.” It appears that the SRPD which led the development of the annual report is again promoting the unofficial views of the “RIPA working group.” Apparently that group discussed creating a “RIPA dashboard” as an alternative to the data-based analysis reflected in the PAAC’s two recommendations, above. Again, the idea of a RIPA dashboard was never considered or adopted by the full PAAC. Whatever benefits a RIPA dashboard might provide, it would accomplish none of the objectives of the PAAC’s two RIPA-data-monitoring recommendations above.
Many law enforcement agencies include “RIPA dashboards” on their websites that provide excerpts and summaries of the agency’s RIPA data selected and interpreted by the agency and its vendors. The dashboards do not include the full RIPA data sets which are essential to meaningfully and independently analyze the data.
Instead, the dashboards present high level generalities (e.g., number and percentage of total stops by category, area, race, etc.). Critically, they do not calculate, report or address the significance of the data as a measure of policing disparities. Based on the data available on a RIPA dashboard, it would be impossible to measure or monitor the effectiveness of specific equitable policing strategies, or to carry out the annual RIPA equity assessment as proposed in the PAAC’s two recommendations above. mvfree.org; [email protected]
MVFREE Addendum to PAAC Annual Report (March 2, 2026) 7 Conclusion
With RIPA, California has established the most complete and reliable system for measuring and addressing policing disparities that has ever existed. See, RIPA Reliability. We hope this memorandum provides the foundation that the Council needs to begin to understand the need for, and benefits of, the PAAC’s equitable policing recommendations in San Rafael. MVFREE will be happy to answer questions and provide other supports to further the Council’s informed consideration and implementation of these targeted recommendations. RIPA requires California law enforcement agencies to eliminate policing disparities and provides effective means to do so. Please do not turn away from this important responsibility. mvfree.org; [email protected]
MVFREE—Reliability of RIPA Analysis (March 2, 2026) 1
RIPA Reliability:
Operation of the Law and Failings of the PORAC Theory
Introduction
The law enforcement lobbying group PORAC has aggressively opposed any legislation—in California and across the nation—designed to identify, measure, or address racial and other policing disparities. Despite PORAC opposition, in 2015 the California Legislature passed the groundbreaking Racial and Identity Profiling Act (RIPA), “to eliminate racial and identity profiling and improve diversity and racial and identity sensitivity in law enforcement." The law requires law enforcement agencies to collect and report comprehensive demographic data on all police stops and related activities and creates and empowers the State RIPA Board to analyze the data and issue annual reports and recommendations for the purpose of identifying and overcoming policing disparities and their causes.
The encyclopedic Annual Reports of the State RIPA Board represent the cutting edge of multi-disciplinary research into the patterns, causes, and conditions of policing disparities in California, and the law enforcement best practices that can prevent them.
PORAC wants us to ignore the law and its mandate. Since RIPA became law, PORAC has promoteed an easily disproven hypothetical objection to the RIPA Board’s statistical methodology in an effort to discredit and evade the law’s purpose and effect. Of course, law enforcement agencies are not free to disregard the laws and regulatory agencies they dislike or disagree with. Unfortunately, the PORAC theory appears to have gained some adherents in San Rafael law enforcement circles. To assist the City Council’s understanding, this memorandum briefly describes: (A) the analytical best practices used by the RIPA Board to identify and measure policing disparities; and (B) the PORAC theory and the fallacies at its core.
A. RIPA Experts’ Methodology
RIPA takes a dispassionate and scientific approach to the emotionally and politically charged issue of policing disparities. Experts on the RIPA Board and staff use analytical best practices to identify, measure, and study policing disparities in every California law enforcement jurisdiction.
Thanks to the statutory reporting requirements, the RIPA Board has access to a massive, comprehensive data set that includes demographic data—reported by police—on every single stop in the State (over 4.7 million stops by more than 500 police agencies every year). With this information, the RIPA Board is able to precisely determine stop demographics for every California law enforcement agency without resort to sampling or estimates.
But how does the Board determine whether the stop demographics indicate policing disparities? Statistically speaking, all things being equal, an agency’s stop demographics should closely mirror the population demographics of its jurisdiction (in a community that is 60% White, we would expect roughly 60% of the people stopped by police to be White.) Identifying stop disparities therefore necessarily requires a comparison of an agency’s annual stop demographics to a benchmark of local population demographics.
The RIPA Board uses the gold standard for U.S. population demographics as its benchmark: the Census Bureau’s annual American Community Survey estimates. These are the same demographic data that inform state and federal government decision-making and allocation of resources (more than $100 billion annually) in such critical areas as public health, education, housing, infrastructure, and democratic representation.
The Census ACS estimates provide a standardized benchmark that is readily available for virtually all jurisdictions which allows the RIPA Board to meaningfully compare disparity patterns and relationships in and among jurisdictions.
RIPA Board data, formulas, and methodologies are entirely transparent. They are available—along with the Board’s disparity findings for every city, county, and statewide law enforcement agency in California—in the annual RIPA Reports linked above.
mvfree.org; [email protected]
MVFREE—Reliability of RIPA Analysis (March 2, 2026) 2
B. The PORAC Theory and Why it Fails
The PORAC theory urges us to disregard RIPA and the RIPA Board’s disparity findings in their entirety solely because the Census data benchmark is based on surveys of the local resident populations, and not everyone stopped by police is a local resident. By PORAC’s reasoning, any statistical analysis with an element of sampling, estimation, or extrapolation would have to be discarded. (1) The PORAC Theory is Unreasoned and Unsupported
In the nine years that the RIPA Board has been publishing its disparity findings, PORAC has failed to identify a single instance in which the Board erroneously identified a policing disparity due to the use of the Census benchmark, or for any other reason.
PORAC does not dispute the fact that the Census data is the best available benchmark for local population demographics. Indeed, there is no benchmark for population demographics that includes visitor demographics, and for obvious reasons: visitors to a given jurisdiction represent a highly variable population whose identities and demographics change on a daily and even hourly basis. By contrast, the resident population is heavily determinative of average year-round demographics because it reflects a reliable constant in the jurisdiction: residents are consistently present in the jurisdiction all year long (they might visit other jurisdictions, but every trip begins and ends in the jurisdiction of their residence); and the demographic identities of residents do not change.
Nor has PORAC pointed to any evidence of a substantial demographic difference over the course of a year between the residents and visitors in any California jurisdiction, much less a difference consistent and pervasive enough to meaningfully affect the RIPA Board’s disparity calculations. To the contrary, when we look at the actual data, PORAC’s conjecture about visitor-resident demographic differentials is entirely unsupported.
(2) Statewide RIPA Data Disproves the PORAC Theory
The size and consistency of racial policing disparities across all California law enforcement agencies at every level powerfully refute the PORAC theory that RIPA disparity findings are a product of shifting demographics caused by interjurisdictional travel.
The reality of policing disparities in California came into sharp focus with the 2025 RIPA Report when comprehensive statewide RIPA data became available. That data revealed that all Marin County law enforcement agencies, and over 90% of all California police agencies, stop Black and Latinx people at higher rates than they do Whites. In San Rafael the RIPA Board calculations show the SRPD stops Black people at
6.4 times the rate of Whites and stops Latinx people at 1.8 times the rate of Whites. Countywide the average Black and Latinx stop disparities are even higher.
In order to negate these findings of Black and Latinx policing disparities in San Rafael (or any other California jurisdiction) based on the PORAC theory, there would have to be an ongoing disproportionate influx of Black and Latinx visitors into the city large enough to substantially reshape the local resident demographics (vastly expanding to local Black and Latinx population). If that were occurring, there would have to be a correspondingly large and disproportionate exodus of Black and Latinx people from the visitors’ jurisdictions of origin. This would, presumably, be reflected in correspondingly low stop rates for Black and Latinx people in those jurisdictions. But, as the 2025 RIPA Report shows, there is no jurisdiction in the San Rafael vicinity, and virtually none in the entire state, with low or even equitable Black and Latinx stop rates.
The steep and pervasive Black and Latinx stop disparities in California shown in the 2025 RIPA Report tell us two things: first, California has an undeniable systemic problem with Black and Latinx policing disparities; and second, those disparity findings cannot be blamed on the omission of visitor demographics from the Census benchmark.
mvfree.org; [email protected]
MVFREE—Reliability of RIPA Analysis (March 2, 2026) 3
(3) We Tested the PORAC Theory and it Failed
There are a number of reliable ways to test whether and how visitors to a jurisdiction are affecting RIPA disparity calculations. Yet PORAC has conspicuously failed to put its theory to the test. MVFREE has undertaken some of these tests in our analyses of the Marin County Sheriff’s Office (MCSO) and the Mill Valley Police Department RIPA data. In each instance, the test results rebutted the PORAC theory.
Resident-Only Data Analysis
As part of its RIPA data collection, the MCSO has been recording whether or not detainees are County residents. This made it possible for MVFREE to conduct a resident-only disparity analysis to test whether the demographics of visitors to the County materially affected the disparity findings made using the RIPA Board formula. We found that they did not.
MVFREE’s one-year analysis of resident-only MCSO stop data showed that Black residents were stopped at
8.3 times the rate of White residents. When visitor stops were included, the stop rate for Blacks showed a fractional increase to 9.2 times the rate of Whites. For Latinx people, the resident-only data showed Latinx people being stopped at 2.4 time the rate of Whites, compared with 2.8 times the rate of Whites when visitor stops were included. These marginal differences did not materially affect the disparity findings using the RIPA Board’s disparity analysis.
Day vs. Night Data Analysis
Conducting a separate analysis of stop disparities for high and low visitation periods (day vs. night) provides another means of assessing the impact of visitor traffic in a jurisdiction on RIPA disparity findings. MVFREE did a one-year analysis of day vs. night stop rates for Mill Valley and again found that the presence or absence of visitors did not materially affect the disparity findings. The day vs. night stop rates for Black people were 6.5 and 6.3 times the rate of Whites, respectively. The day vs. night stop rates for Latinx people were 2.7 and 3.4 times the rate of Whites, respectively.
Conclusion
With RIPA, California has established the most complete and reliable system for measuring policing disparities that has ever existed. The RIPA Board’s disparity calculations have been tested and honed over many years and represent analytical best practices. The RIPA mandate—to identify and eliminate policing disparities wherever they are found—is clear. The annual RIPA reports provide the tools and best practices communities, and law enforcement agencies need to achieve that mandate.