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File #: 26-0617   
Type: Formal Action Status: Passed
Meeting Body: City Council Formal Meeting
On agenda: 3/25/2026 Final action: 3/25/2026
Title: Community Transparency Initiative - Citywide
District: Citywide
Attachments: 1. Attachment A - A.R. DRAFT 3.19.26 - Use of City Property for Civil Law Enforcement (Final Draft).pdf
Title
Community Transparency Initiative - Citywide

Description
During the February 10, 2026, Work Study Session, the Mayor and City Council approved direction to staff to explore, develop and present a framework for a Community Transparency Initiative and return to the Council within 45 days.

Report
Summary
Residents throughout Phoenix have shared their growing concern about how federal law enforcement activities adversely impact the community. In response, on February 5, 2026, Mayor Gallego called a Work Study Session to discuss and direct staff to explore, develop and present a framework for a Community Transparency Initiative and return to the Council within 45 days. The Mayor’s memo identified five items for the Council to consider in support of the Community Transparency Initiative. Work Study sessions provide an opportunity for the Mayor and City Council to discuss topics important to the community in an open session.

During the February 10 Work Study Session, the Mayor and City Council approved a motion to direct staff to “develop potential ordinances, regulations and guidelines consistent with the deliverables outlined in the Mayor's February 5, 2026, memo, as well as options for the Council to consider relating to outside organizations, staging in our parks and preserve and other city property.”

The approved directives for staff were to:
Document and preserve information on federal immigration enforcement activities within Phoenix city limits that may violate criminal statutes and/or individual civil rights with the intent to investigate crimes committed by federal agents who act outside the scope of their duties.
Collect data on impacts to City services as a result of federal immigration enforcement.
Identify potential partnerships and volunteer opportunities to facilitate the initiative.
Ensure multilingual communication channels across City services and resources.
Implement training for City employees who may encounter federal enforcement actions, including protocols related to administrative and judicial warrants.
Develop options for the Council to consider relating to outside organizations, staging in our parks and preserve and other city property.

Since February 10, the City Manager’s Office has led an effort with numerous City departments to create the framework for each item as directed by the Mayor and City Council.

Community Transparency Initiative Framework
The Community Transparency Initiative (CTI) framework outlined herein reflects the specific directives provided by the Mayor and City Council as well as the feedback on those directives provided by community stakeholders through various meetings, listening sessions, conversations and sharing of information. The discussion with stakeholders largely reflected an understanding of the goals of the directives as well as a shared intent that the best path forward would include an iterative process. This process would include continued dialogue between Councilmembers, City staff and community members which would inform and shape the current directives as well as potential future elements of the CTI as it evolves to meet the needs of the community.

1. Document and preserve information on federal immigration enforcement activities within Phoenix city limits that may violate criminal statutes and/or individual civil rights with the intent to investigate crimes committed by federal agents who act outside the scope of their duties.
To support the first directive of the CTI, there are two scenarios where documentation and investigation may occur; reports of inactive incidents that have occurred and are no longer in progress and reports of active, emergency incidents.

Regarding inactive incidents, staff will implement a new process in coordination with the Office of Accountability and Transparency (OAT) and the Phoenix Police Department (PPD). The new process includes receiving, documenting and preserving a community member’s complaint about an alleged crime or violation of individual civil rights by a federal agent through the Sivil complaint portal, which is administered by OAT. Sivil is a multilingual platform that will be available for the community to use to submit complaints to the City. It will also be accessible by calling or visiting OAT where a staff member will take a complaint and enter it into the portal.

The complaints will be documented and tracked using the portal platform then directed to the PPD Special Investigations Detail (SID) where detectives will review the incident. Two additional detectives will be assigned to SID to manage the anticipated workload and may be adjusted as needed. The assigned detectives and the necessary administrative, supervisory and executive level staff will be the only PPD staff to have access to the Sivil complaint portal.

The SID review will include a review of the complaint to determine if allegations of state or local law violations are present. If there are allegations of criminal violations of local or state law, SID investigators will contact the complainant for further information, if contact information is provided, and will investigate to the extent necessary and possible. If enough evidence exists for charges to be filed, PPD will refer criminal charges to the appropriate charging agency. If there is not enough evidence to refer criminal charges, a report will be documented. Reports of civil right violations will be forwarded to the Attorney General’s Office for further review and possible investigation.

All reports and related evidence for all complaints made to the City of Phoenix will be forwarded to the Arizona Attorney General’s Office with documentation also maintained by the City. The City will collaborate with the Attorney General’s Office to develop a Memorandum of Understanding (MOU) to outline this relationship.

Where applicable, complaints may also be forwarded to the appropriate federal agency with a request for further investigation.

Regarding active, emergency incidents, if a member of the community believes a crime is actively being committed by a federal agent acting outside the scope of their duties, or they would like to verify the identity of a law enforcement officer, they should call 911 for immediate assistance. If there is a situation that warrants intervention or criminal investigation, PPD will respond and investigate. PPD also has capabilities to document situations using technologies such as body worn cameras and drones.

Complainants may also be offered referrals to resource information through the City’s website (see #3 below), as well as victim support services where applicable.

For transparency, it is important to note that investigation and prosecution of these incidents will be challenging, and few are likely to result in criminal prosecution. However, the information gathered through this process will be valuable for potential future civil action, if necessary. It is also important to note that these records are likely to be subject to public records requests with appropriate redactions.

2. Collect data on impacts to City services as a result of federal immigration enforcement.
To support the second directive of the CTI, staff have established tracking mechanisms for City resources used during incidents involving federal law enforcement officials. Pathways for tracking the utilization of City resources include documenting staff time and the call response information for first responders as a result of an incident involving federal law enforcement. Staff will also focus on tracking specific incident types where feasible, such as use of aerosol irritants as a use of force against members of the community. The tracking of City resources will be conducted by the Police and Fire departments (including the Community Assistance Program) as well as the Office of Accountability and Transparency through their established tracking processes. Additionally, a staff member will be assigned to track impacts to small businesses and the local economy.

3. Identify potential partnerships and volunteer opportunities to facilitate the initiative.
To support the third directive of the CTI, staff have worked with several key stakeholders since February 10 to develop partnerships and receive feedback on the initiative. Stakeholders frequently identified establishing a “Know Your Rights” campaign as one of the most critical components of this initiative. In response, City staff have developed a new Know Your Rights webpage. The new page on the City’s website features key resources from partners that will equip the community with information to empower them with the knowledge to maintain their individual civil rights. The webpage also includes information for businesses, schools, employers and impacted communities, such as refugees, and links to volunteer opportunities.

Additionally, the City’s website will contain general information about the Community Transparency Initiative, status of CTI implementation, relevant data and information about related City services, such as virtual Municipal Court service options for traffic citations. As we expect the CTI to be an ongoing, iterative process in collaboration with the community, this webpage would also be a place to share updated information about the initiative publicly, such as new resources available.

Staff have identified additional partners, including the Arizona Attorney General’s Office and the Cities of Tucson and Flagstaff, to support this work. Collaboration with these entities will enable resource sharing and coordinated information exchange, promoting transparency. These partnerships will help ensure that any resulting actions are legally defensible and minimize risks, while addressing community concerns. Data and information regarding the CTI will also be made available to our Congressional representatives in order to ensure they are fully informed about the impacts to Phoenix.

Additionally, there are many opportunities to continue to collaborate with community-based organizations engaged in services to residents of the city of Phoenix. For example, we are evaluating potential partnerships with organizations that may be able to provide focused resources to the business community. This collaborative work will be an ongoing component of the CTI as it is implemented.

4. Ensure multilingual communication channels across City services and resources.
To support the fourth directive of the CTI, staff are utilizing several resources to ensure services and resources are shared with the community through multilingual channels. A primary multilingual channel to shared City services and resources is through the updated City of Phoenix website, and specifically, the City’s new Know Your Rights webpage. The website is capable of translating information on City services and resources in more than 120 languages. Where possible, the City will also link to resources in multiple languages on the CTI resource pages. Additionally, any information about the Community Transparency Initiative will be communicated in multiple languages.

Additionally, Phoenix City Council meetings offer captioning and translation services through Wordly, a third-party translation and interpretation platform. Wordly automatically transcribes meetings into 67 languages and provides speaker interpretation services for 60 languages.

5. Implement training for City employees who may encounter federal enforcement actions, including protocols related to administrative and judicial warrants.
To support the fifth directive of the CTI, staff are developing training and additional resources for all City staff regarding what to do if a staff member encounters federal enforcement officials. The following documents have been prepared to support City staff regarding any potential encounters with federal officials:
Guidelines for City Staff - Provides procedures for responding to federal officials entering City facilities, including supervisor notification, documentation of agent details, legal review of warrants, and professional conduct. Includes a staff script and an Incident Report Template capturing date, time, agency information, actions taken, and number of staff/public present.
Federal Guidelines Training Video - Supports staff readiness by illustrating procedures from the written guidelines, including response protocols, scripts, and documentation steps.
Resource Card - Provides a quick-reference of operational guidance, including a staff script. Blank customizable template for staff to insert supervisor and department leadership contact information.

6. Develop options for the Council to consider relating to outside organizations, staging in our parks and preserve and other city property.
To support the sixth directive of the CTI, staff have developed a proposed Administrative Regulation (A.R.) regarding the use of City-Owned and City-Controlled property for civil law enforcement (Attachment A).

The proposed A.R. establishes standards for the use, access, and designation of City-Owned and City-Controlled property, with some exceptions, to protect public use and enjoyment of City facilities, maintain operational integrity, and ensure City resources best serve residents. City property exists for public use and enjoyment in support of authorized City purposes. The City has a duty to ensure that all real and personal property under its ownership and control is used appropriately. Accordingly, City-Owned and City-Controlled property may be used only for authorized City purposes and shall not be used for any unauthorized or non-City purposes. Prohibited uses include, but are not limited to, using City property as a staging area, processing location, or operations base for civil law enforcement actions, unless approved by the City Manager, or their designee.

The Administrative Regulation also establishes requirements for staff to maintain an annual inventory of City properties and to develop and update an Access Control Plan for those locations. This plan must include appropriate signage limiting or prohibiting the staging, deployment, or operational use of City property by law enforcement agencies except as expressly authorized by the City Manager, or their designee.

The City Manager’s Office recommends the Mayor and City Council approve a directive to the City Manager to authorize and implement the Administrative Regulation: Use of City-Owned and City-Controlled Property for Civil Law Enforcement. This A.R is written to sunset in 2029 unless the directive to implement is extended by the City Council.

Legal Considerations
Arizona Revised Statutes 11-1051 (A) states, “No official or agency of this state or a county, city, town or other political subdivision of this state may limit or restrict the enforcement of federal immigration laws to less than the full extent permitted by federal law.” This restriction limits the ability of the City of Phoenix to act and is a unique legal environment in comparison to cities and other jurisdictions outside Arizona.

Financial Impact and Previous Council Action
On March 4, the Phoenix City Council authorized $1 million to enter into an agreement with law firm Coppersmith Brockelman to provide legal counsel to the City on matters related to federal actions impacting the City of Phoenix.

As part of the initiative, staff are monitoring additional potential financial impacts and will keep the Council informed of additional resources that may be required.


Public Outreach and Process
Since the February 10 Work Study Session, the Mayor, City Council members, and staff have held several meetings and listening sessions on this topic. Additionally, staff presented to and received feedback from the City’s Human Relations Commission.

The overwhelming sentiment of the feedback received is that these measures are important steps, however, there are additional potential actions identified by stakeholders that would augment the CTI. Stakeholders also expressed a desire to continue to work together collaboratively to address this important community concern.

Department
Responsible Department
This item is submitted by Assistant City Manager Lori Bays and the City Manager’s Office.