Orange Orange PD (2023-2024 inspection cycle)

October 16, 2023 Dan Adams, Chief of Police Orange Police Department 300 E. Chapman Ave. Orange, CA 92866 2023-2024 COMPREHENSIVE INSPECTION, PENAL CODE SECTION 6031, WELFARE & INSTITUTIONS CODE SECTION 209, ORANGE POLICE DEPARTMENT’S DETENTION FACILITY Dear Chief Adams: The 2023-2024 Comprehensive Inspection of the Orange City Police Department has been completed. The following facility was inspected Tuesday, May 30, 2023: FACILITY NAME BSCC # FACILITY TYPE Orange Police Department 3725 THJ This inspection was conducted pursuant to Penal Code Section 6031 to determine compliance with the Minimum Standards for Local Detention Facilities as outlined in Titles 15 and 24, California Code of Regulations. In addition, Board of State and Community Corrections (BSCC) staff conducted compliance monitoring pursuant to Welfare and Institutions Code Section 209(f) and the federal Juvenile Justice and Delinquency Prevention Act (JJDPA). In addition to the inspection(s) by the BSCC, inspections are also required annually by the County Health Officer and biennially by the State Fire Marshal or an authorized representative (Health and Safety Code Sections 101045 and 13146.1). The results of those inspections are considered a part of this report. INSPECTION RESULTS We identified no items of noncompliance with Title 15 Minimum Standards. Refer to the attached Title 15 Procedures Checklist for detailed information. No items of noncompliance were identified with Title 24 Minimum Standards. Refer to the Physical Plant Evaluation (PHY) and Living Area Space Evaluation (LASE) attachments for information related to Rated Capacity. Dan Adams Chief of Police Page 2 Juvenile Justice and Delinquency Prevention Act Compliance Monitoring There are two juvenile holding rooms in the facility, out of sight and sound of adult detainees. However, youth are not brought into the facility. Per department policy and records, no youth have been detained inside the facility or in the department’s administrative area in the past 4 years. An Exit Briefing with your staff was held on Tuesday, May 30, 2023; BSCC staff presented an inspection overview and discussed technical assistance and best practice recommendations. * * * Please email me at michael.bush@bscc.ca.gov or call (916) 956-5968 if you have any questions. Sincerely, MICHAEL J. BUSH Field Representative Facilities Standards and Operations Division Enclosures Cc: Presiding Judge, Orange County Superior Court* Chair, Grand Jury, Orange County* Chair, Board of Supervisors, Orange County* County Administrator, Orange County* Tyler Ray, Sergeant, Orange Police Department *Copies of the inspection are available upon request or online at www.bscc.ca.gov. 3725 Orange Orange PD THJ LTR 23-24 TEMPORARY HOLDING FACILITIES Board of State and Community Corrections PROCEDURES1 BSCC Code:3725 FACILITY NAME: Orange Police Department City Jail FACILITY TYPE: THJ PERSON(S) INTERVIEWED: Sergeant Tyler Ray FIELD REPRESENTATIVE: Michael Bush DATE: May 30, 2023 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS 1024 COURT HOLDING AND TEMPORARY 33.1024 HOLDING FACILITY TRAINING Two Jailers are available when there is an incarcerated person in custody. At a minimum, all supervisors of and personnel who supervise incarcerated persons in, a Court Holding or Temporary Holding facility shall complete eight hours of specialized corrections training. Such training shall include, but not be limited to: (a) applicable minimum jail standards; (b) jail operations liability; (c)separation of incarcerated persons; (d) emergency procedures and planning, fire and life ☒ ☐ ☐ safety; and; (e) suicide prevention; (f) de-escalation; (g) juvenile procedures; (h) racial bias; and, (i) mental illness. Each agency shall determine if additional training is needed based upon, but not limited to, the complexity of the facility, the number of people incarcerated, the employees' level of experience and training, and other relevant factors Such training shall be completed as soon as Training records indicate requirements practical, but in any event not more than six months have been met. after the date of assigned responsibility. Successful completion of Core training or supplemental Core ☒ ☐ ☐ training, pursuant to Section 1020, Corrections Officer Core Course, may be substituted for the initial eight hours of training. A total of eight hours of refresher training shall be completed every two years. Successful completion of the requirements in Section 1025, Continuing ☒ ☐ ☐ Professional Training may be substituted for the eight-hour refresher. 1027 NUMBER OF PERSONNEL In addition to the implementation and operation of all programs and activities A sufficient number of personnel shall be employed in ☒ ☐ ☐ required by the regulations, another each local detention facility to ensure the predicator for compliance with this section 1 This document is intended for use as a tool during the inspection process; this worksheet may not contain each Title 15 regulation that is required. Additionally, many regulations on this worksheet are SUMMARIES of the regulation; the text on this worksheet may not contain the entire text of the actual regulation. Please refer to the complete California Code of Regulations, Title 15, Minimum Standards for Local Facilities, Division 1, Chapter 1, Subchapter 4 for the complete list and text of regulations. 3725 Orange Orange PD PRO 23-24 Page 1 of 17 A351 TH PRO eff. 4/2023 (23-24).dot TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS implementation and operation of the programs and is the availability of staff to complete and activities required by these regulations. document at least hourly safety checks. Whenever there is a person in custody, there shall be 33.1027 at least one employee on duty at all times in a local detention facility or in the building which houses a BSCC reviewed staffing assignments, the local detention facility who shall be immediately duty roster, and the Correctional ☒ ☐ ☐ available and accessible to incarcerated people in the Sergeant’s Log to verify staffing patterns. event of an emergency. All information appeared appropriate. Such an employee shall not have any other duties 33.1027 which would conflict with the supervision and care of ☒ ☐ ☐ incarcerated people in the event of an emergency. Whenever one or more females are in custody, 33.1027 there shall be at least one female employee who shall be immediately available and accessible to Whenever a female incarcerated person is such females. Note: Reference PC§ 4021. in custody, there shall be at least one ☒ ☐ ☐ female employee who shall in like manner be immediately available and accessible to such females. To determine if there is a sufficient number of personnel for a specific facility, the facility administrator shall prepare and retain a staffing plan indicating the personnel assigned in the facility and their duties. Such a staffing plan shall be reviewed by ☒ ☐ ☐ the Board staff at the time of their biennial inspection. The results of such a review and recommendations shall be reported to the local jurisdiction having fiscal responsibility for the facility. 1027.5 SAFETY CHECKS 33.1027 The facility administrator shall develop and Visual checks shall be made at least every implement policy and procedures for conducting ☒ ☐ ☐ 15 minutes on juvenile prisoners that are safety checks that include, but are not limited to, the in a sobering cell. following: (a) Safety checks will determine the safety and well- 33.1027 being of individuals and shall be conducted at least hourly through direct visual observation of all people ☒ ☐ ☐ held and housed in the facility. (b) There shall be no more than a 60-minute lapse 33.1027 between safety checks. Incarcerated persons are rarely detained ☒ ☐ ☐ in cells; however, the few records we did examine were compliant with regulation. (c) Safety checks for people in sobering cells, safety 33.1056 cells, and restraints shall occur more frequently as outlined in section 1055, section 1056, and section ☒ ☐ ☐ 1058 of these regulations. (d) Safety checks shall occur at random or varied 33.1056 intervals. ☒ ☐ ☐ (e) There shall be a written plan that includes the documentation of all safety checks. ☒ ☐ ☐ Documentation shall include: ☒ ☐ ☐ (1) the actual time at which each individual safety check occurred; ☒ ☐ ☐ (2) the location where each individual safety check occurred, such as a cell, module, or ☒ ☐ ☐ dormitory number; and, 3725 Orange Orange PD PRO 23-24 Page 2 of 17 A351 TH PRO eff. 4/2023 (23-24).dot TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (3) Initials or employee identification number of staff who completed the safety check(s). ☒ ☐ ☐ (f) A documented process by which safety checks are reviewed at regular defined intervals by a supervisor or facility manager, including methods of mitigating ☒ ☐ ☐ patterns of inconsistent documentation, or untimely completion of, safety checks. 1028 FIRE AND LIFE SAFETY STAFF 33.1028 Whenever there is a person in custody, there shall be Whenever there is an incarcerated person at least one person on duty at all times who meets in custody, there shall be at least one the training standards established by the Board for person on duty at all times who meets the ☒ ☐ ☐ general fire and life safety. [Penal Code section training standards established by the State 6030(c)]. Fire Marshal for general fire and life safety, which relate specifically to the facility. The facility manager shall ensure that there is at least Will receive training during the 8 hours one person on duty who trained in fire and life safety specialized training per 1025 CCR and ☒ ☐ ☐ procedures that relate specifically to the facility. during the 8 hours refresher course. 1029 POLICY AND PROCEDURES MANUAL2 Lexipol and a standalone manual are used for the jail. Facility administrator(s) shall develop and publish a manual of policy and procedures for the facility. The policy and procedures manual shall address all applicable Title 15 and Title 24 regulations and shall be comprehensively reviewed and updated at least every two years. Such a manual shall be made ☒ ☐ ☐ available to all employees. The policies and procedures required in subsections (a)(6) and (a)(7) may be placed in a separate manual to ensure confidentiality. Subsections (c) and (d) do not apply and have been deleted. (a) The manual for Temporary Holding, Type I, II, 33.1001 and III facilities shall provide for, but not be limited to, the following: ☒ ☐ ☐ (1) Table of organization, including channels of communications. (2) Inspections and operations reviews by the 33.1280 facility administrator/manager. ☒ ☐ ☐ (3) Policy on the use of force that meets current Policy 300 state and federal legal requirements and includes prohibition of the use of carotid restraint and choke ☒ ☐ ☐ holds. (4) Policy on the use of restraint equipment, 33.1005(b)(1) including the restraint of pregnant persons as Pregnant arrestees are booked directly referenced in Penal Code Section 3407. ☒ ☐ ☐ into the Orange County Jail. (5) Procedure and criteria for screening newly received persons for release. 33.1005(t) ☒ ☐ ☐ (6) Security and control including: In practice, a limited number of incarcerated persons are held in cells and ☒ ☐ ☐ all are under constant supervision. physical counts, 901 and 33.1007 to 1010 ☒ ☐ ☐ searches of the facility and incarcerated persons, 33.1005 (o) ☒ ☐ ☐ contraband control, and 33.1005 (o) ☒ ☐ ☐ 2 Procedures related to security and emergency response may be in a separate manual to ensure confidentiality by limiting general access. 3725 Orange Orange PD PRO 23-24 Page 3 of 17 A351 TH PRO eff. 4/2023 (23-24).dot TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS key control. 33.1005 (o) ☒ ☐ ☐ Each facility administrator shall, at least annually, review, evaluate, and make a record of security measures. The review and evaluation shall include internal and external security measures ☒ ☐ ☐ of the facility including security measures specific to prevention of sexual abuse and sexual harassment. (7) Emergency procedures include: Policy 900 (A) fire suppression preplan as required by ☒ ☐ ☐ section 1032 of these regulations; (B) escape, disturbances, and the taking of 33.1029 hostages; ☒ ☐ ☐ (C) mass arrests; ☒ ☐ ☐ (D) natural disasters; ☒ ☐ ☐ (E) periodic testing of emergency equipment; and ☒ ☐ ☐ (F) storage, issue, and use of weapons, 33.1005(d) ammunition, chemical agents, and related ☒ ☐ ☐ security devices. (8) Suicide Prevention. 33.1219 ☒ ☐ ☐ (9) Separation of incarcerated persons. 33.1050 & 33.1053 ☒ ☐ ☐ (10) Zero tolerance in the prevention of sexual Policy 902 abuse and sexual harassment. ☒ ☐ ☐ (11) Policy and procedure to detect, prevent, and Policy 902 respond to retaliation against any staff or person ☒ ☐ ☐ after reporting any abuse. (12) Release policy, including release planning for Policy 902 incarcerated persons. ☒ ☐ ☐ (e) The manual for Temporary Holding, Court Holding, Type I, II, III, and IV facilities shall provide Policy 902 for, but not be limited to, the following: (1) multiple internal ways for incarcerated people to privately report sexual abuse and sexual harassment, retaliation by other incarcerated ☒ ☐ ☐ persons or staff for reporting sexual abuse and sexual harassment, and staff neglect or violation of responsibilities that may have contributed to such incidents, (2) a method for uninvolved incarcerated persons, family, community members, and other Policy 902 interested third parties to report sexual abuse or ☒ ☐ ☐ sexual harassment. The method for reporting shall be publicly posted at the facility. 1030 SUICIDE PREVENTION PROGRAM Suicidal subjects are prohibited from entering the THF and are booked directly The facility shall have a comprehensive written into county jail. suicide prevention program developed by the facility administrator or designee, in conjunction with the health authority and mental health director, to ☒ ☐ ☐ identify, monitor, and provide treatment to those incarcerated persons who present a suicide risk. The program shall include the following: (a) Annual suicide prevention training for all All staff who will have direct contact with custodial personnel. incarcerated people will attend suicide ☒ ☐ ☐ prevention training. 3725 Orange Orange PD PRO 23-24 Page 4 of 17 A351 TH PRO eff. 4/2023 (23-24).dot TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (b) Intake screening for suicide risk immediately Upon a detainee entering the facility, upon intake and prior to housing assignment. he/she will be assessed by staff for the ☒ ☐ ☐ ability to answer medical and mental health screening questions. (c) Suicide prevention screening during special situations, including placement in restrictive housing, following a hearing, and after a transfer or ☐ ☐ ☒ change in classification. (d) Provisions facilitating communication among arresting/transporting officers, facility staff, court staff, medical and mental health personnel in ☐ ☐ ☒ relation to suicide risk. (e) Housing recommendations for people at risk of 33.1219 suicide that balance safety and environment. The ☐ ☐ ☒ least restrictive environment should be considered. (f) Supervision depending on level of suicide risk. ☐ ☐ ☒ (g) Suicide attempt and suicide intervention policies Policy 900 and procedures. ☐ ☐ ☒ (h) Provisions for reporting suicides and suicides Policy 900 attempts. ☐ ☐ ☒ (i) Multi-disciplinary administrative review of suicides Policy 900 and attempted suicides as defined by the facility administrator, including the development of a ☐ ☐ ☒ corrective action plan to address deficiencies identified in the administrative review. (j) Provisions for follow up care as needed. ☐ ☐ ☒ (k) Plan for mental health consultation following return from court as determined by the mental health ☐ ☐ ☒ director. 1032 FIRE SUPPRESSION PREPLANNING 33.1032 Pursuant to Penal Code Section 6031.1(b), the facility administrator shall consult with the local fire department having jurisdiction over the facility, with ☒ ☐ ☐ the State Fire Marshal, or both, in developing a plan for fire suppression which shall include, but not be limited to: (a) a fire suppression pre-plan developed with the Fire Clearance 09/08/22, fire clearance local fire department to be included as part of the policy with no deficiencies. and procedures manual (Title 15, California Code of ☒ ☐ ☐ Regulations Section 1029); (b) monthly fire prevention inspections by facility staff 33.1029 with two-year retention of the inspection record; ☒ ☐ ☐ (c) fire prevention inspections as required by Health 33.1029 and Safety Code Section 13146.1(a) and (b) which ☒ ☐ ☐ requires inspections at least once every two years; (d) an evacuation plan; and 33.1029 ☒ ☐ ☐ (e) a plan for the emergency housing of incarcerated The Orange County Jail would be used in people in the case of fire. this event. ☒ ☐ ☐ 3725 Orange Orange PD PRO 23-24 Page 5 of 17 A351 TH PRO eff. 4/2023 (23-24).dot TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS 1044 INCIDENT REPORTS 33.1044 Each facility administrator shall develop written policies and procedures for the maintenance of written records and reporting of all incidents which ☒ ☐ ☐ result in physical harm, or serious threat of physical harm, to an employee or incarcerated person of a detention facility or other person. Such records shall include the names of the persons No incident report to review. involved, a description of the incident, the actions ☒ ☐ ☐ taken, and the date and time of the occurrence. Such a written record shall be prepared by the staff assigned to investigate the incident and submitted to ☒ ☐ ☐ the facility manager or designee. 1046 DEATH IN CUSTODY 33.1218 In the event of an in-custody death, officers (a) Death in Custody Reviews for Adults and Minors. shall treat the detention facility as a crime The facility administrator, in cooperation with the scene. Officers shall take all reasonable health administrator, shall develop written policy and precautions to ensure physical evidence is procedures to ensure that there is an initial review of preserved. Unless otherwise directed by a ☒ ☐ ☐ every in-custody death within 30 days. The review supervisor, the officer who discovered the team at a minimum shall include the facility deceased prisoner / minor shall maintain a administrator or designee, the health administrator, log or other record of all person(s) who the responsible physician and other health care and enter the detention facility following the supervision staff who are relevant to the incident. discovery. Deaths shall be reviewed to determine the California Government Code 12525 appropriateness of clinical care; whether changes to requires that in any case in which a person policies, procedures, or practices are warranted; and dies while in the custody of a law to identify issues that require further study. enforcement agency, or a local correctional facility, the agency shall report in writing to the California Attorney General within 10 days after the death. The Death in Custody Form (BCIA 713) ☒ ☐ ☐ will satisfy this requirement and eliminates the requirement that agencies provide copies of death-in-custody incident reports to the Department of Justice (as of November 2005). The Bureau of Criminal Statistics (BCS) is responsible for maintaining the Death in Custody Reports submitted to the Attorney General. (b) Death of a Minor 33.1218 In any case in which a minor dies while detained in Although there are two juvenile holding a jail, lockup, or court holding facility: rooms in the facility, juveniles are ☐ ☐ ☒ prohibited from entering the facility except for finger printing and live scans. (1) The administrator of the facility shall provide 33.1218 to the Board a copy of the report submitted to the Attorney General under Government Code Section 12525. A copy of the report shall be ☐ ☐ ☒ submitted within 10 calendar days after the death. (2) Upon receipt of a report of death of a minor 33.1218 from the administrator, the Board may within 30 calendar days inspect and evaluate the jail, lockup, or court holding facility pursuant to the ☐ ☐ ☒ provisions of this subchapter. Any inquiry made by the Board shall be limited to the standards and requirements set forth in these 3725 Orange Orange PD PRO 23-24 Page 6 of 17 A351 TH PRO eff. 4/2023 (23-24).dot TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS regulations. 1050 CLASSIFICATION PLAN 33.1050 All prisoners housed with others shall be (a) Each administrator of a temporary holding, Type I, classified for holding purposes. II, or III facility shall develop and implement a written classification plan designed to properly assign BSCC staff reviewed 8 months of inmate’s incarcerated persons to housing units and activities classification and medical screening according to the categories of gender identity, age, forms. All forms were complete and ensure criminal sophistication, seriousness of crime the inmate's health and safety. charged, physical or mental health needs, assaultive/non-assaultive behavior, risk of being sexually abused, or sexually harassed and other criteria which will provide for the safety of the ☒ ☐ ☐ incarcerated people and staff. Such housing unit assignment shall be accomplished to the extent possible within the limits of the available number of distinct housing units or cells in a facility. The written classification plan shall be based on objective criteria and include receiving screening performed at the time of intake by trained personnel, and a record of each person's classification level, housing restrictions, and housing assignments. (Subsection b does not apply and has been deleted.) (c) In deciding housing and programming assignments, the agency shall consider on a case- by-case basis whether a placement would ensure the health and safety of the incarcerated person, and whether the placement would present management ☒ ☐ ☐ or security problems. A person’s own views with respect to their own safety shall be given serious consideration. 1051 COMMUNICABLE DISEASES 33.1051, 33.1026.5 & 33.1207 An incarcerated person suspected of The facility administrator, in cooperation with the having a communicable disease would be responsible physician, shall develop written policies immediately transported to the county jail and procedures specifying those symptoms that ☒ ☐ ☐ or other appropriate facility. require medical isolation of an incarcerated person until a medical evaluation is completed. At the time of intake into the facility, an inquiry shall 33.1005(j) be made of the person being booked as to whether the person has or has had any communicable diseases, such as tuberculosis or has observable symptoms of tuberculosis or any other communicable ☐ ☐ ☒ diseases, or other special medical problem identified by the health authority. The response shall be noted on the medical screening from. 1052 BEHAVIORAL CRISIS IDENTIFICATION 33.1005 (b) (3) and 33.1052 Incarcerated persons determined to be The facility administrator, in cooperation with the mentally disordered are transported responsible physician, shall develop written policies directly to the Orange County Jail. ☒ ☐ ☐ and procedures to identify and evaluate all incarcerated people who may be in behavioral crisis. 3725 Orange Orange PD PRO 23-24 Page 7 of 17 A351 TH PRO eff. 4/2023 (23-24).dot TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS Evaluation of behavioral crisis may include telehealth. If an evaluation from medical or mental health staff is not readily available, an incarcerated person shall be considered in behavioral crisis for the purpose of this section if they appear to be a danger to themselves ☐ ☐ ☒ or others or appear gravely disabled. An evaluation from medical or mental health staff shall be secured within 24 hours of identification or at ☐ ☐ ☒ the next daily sick call, whichever is earliest. Separation may be used if necessary, to protect the safety of the person in crisis or others. ☐ ☐ ☒ 1053 ADMINISTRATIVE SEPARATION 33.1053 This type of incarcerated person would be Except for Type IV facilities, facility administrators immediately transported to the county jail. shall develop and implement policies and procedures for the administrative separation of incarcerated ☒ ☐ ☐ people. Policies and procedures must include: (a) Administrative separation may consist of separate housing but shall not involve any other deprivation of privileges than is necessary to obtain the objective of ☐ ☐ ☒ protecting the welfare of incarcerated people and facility staff. (b) Administrative separation must not adversely affect an incarcerated person’s health. ☐ ☐ ☒ (c) Administrative separation may be used for incarcerated people who have: (1) A documented history of activity or behavior, or promoting such activity or behavior, that is criminal in nature, disruptive to facility operations, or affects the safety of the facility, other incarcerated people, and facility staff. (2) Influenced or participated in activity that is criminal in nature, disruptive to facility operations or affects the safety of the facility, ☐ ☐ ☒ other incarcerated people, and facility staff. (3) Committed assault, attempted assault, or participated in a conspiracy to assault or harm other incarcerated persons or facility staff. (4) A history of escape or have recently attempted escape. (5) A demonstrated need for protection from other incarcerated people. (d) Documentation indicating the necessity of administrative separation to obtain the objective of protecting the welfare of incarcerated people and ☐ ☐ ☒ facility staff. (e) A documented individualized ongoing review and evaluation of the need to continue placement in ☐ ☐ ☒ administrative separation. 3725 Orange Orange PD PRO 23-24 Page 8 of 17 A351 TH PRO eff. 4/2023 (23-24).dot TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS 1055 USE OF SAFETY CELL No Safety Cell The safety cell described in Title 24, Part 2, Section 1231.2.5, shall be used to hold only those people who display behavior which results in the destruction of ☐ ☐ ☒ property or reveals an intent to cause physical harm to self or others. The facility administrator, in cooperation with the responsible physician, shall develop written policies and procedures governing safety cell use and may delegate authority to place an incarcerated person in ☐ ☐ ☒ a safety cell to a physician. Policies and procedures shall include, but not be limited to: (a) In no case shall the safety cell be used for punishment or as a substitute for treatment. ☐ ☐ ☒ (b) A person shall be placed in a safety cell only with the approval of the facility manager or designee, or responsible health care staff; ☐ ☐ ☒ continued retention shall be reviewed a minimum of every four hours. (c) A medical assessment shall be completed as soon as possible, but not more than 12 hours from the time of placement in the safety cell. The person shall be medically cleared for continued retention, referral ☐ ☐ ☒ to advanced treatment, or removal from the safety cell a minimum of every 24 hours thereafter. (d) The facility manager, designee or responsible health care staff shall obtain a mental health opinion/consultation with responsible health care staff on placement and retention, which shall be ☐ ☐ ☒ secured as soon as possible, but not more than 12 hours from placement. (e) Direct visual observation shall be conducted at least twice every 30 minutes, with no more than a 15- minute lapse between safety checks. Such ☐ ☐ ☒ observation shall be documented. (f) Procedures shall be established to assure administration of necessary nutrition and fluids. ☐ ☐ ☒ (g) People placed in the safety cell shall be allowed to retain sufficient clothing or be provided with a suitably designed “safety garment,” to provide for their personal privacy unless specific identifiable ☐ ☐ ☒ risks to the person's safety or to the security of the facility are documented. 1056 USE OF SOBERING CELL 33.1056 The sobering cells (cells 44 and 49) shall The sobering cell described in Title 24, Part 2, be exclusively used to hold incarcerated Section 1231.2.4, shall be used for temporary holding persons who are a threat to their own ☒ ☐ ☐ of incarcerated people who are a threat to their own safety or the safety of others due to their safety or the safety of others due to their intoxication. state of intoxication. A person shall be removed from the sobering cell as 33.1056 soon as they are able to continue the admission process or are no longer a risk to themselves or ☒ ☐ ☐ others. 3725 Orange Orange PD PRO 23-24 Page 9 of 17 A351 TH PRO eff. 4/2023 (23-24).dot TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS In no case shall a person remain in a sobering cell 33.1056(c) over six hours without an evaluation by medical or Requires paramedics to respond if the custody staff to determine whether the person has an incarcerated person is still detained at 6 urgent medical problem, pursuant to section 1213 of hours. ☒ ☐ ☐ these regulations. At 12 hours from the time of placement, all persons must receive an evaluation by responsible health care staff. ☒ ☐ ☐ Intermittent direct visual observation of people held in 33.1056(c) the sobering cell shall be conducted no less than BSCC staff reviewed 6 months of every half hour. Such observation shall be incarcerated person’s placements in the documented. ☒ ☐ ☐ sobering cell. All observation logs were inside the required regulation standard time limit. 1057 DEVELOPMENTAL DISABILITIES 33.1005 (b) (8) & 33.1057 Incarcerated persons determined to be The facility administrator, in cooperation with the developmentally disabled are transported responsible physician, shall develop written policies directly to the county jail. and procedures for the identification and evaluation, ☒ ☐ ☐ appropriate classification and housing, protection, and nondiscrimination of all incarcerated persons with developmental disabilities. The health authority or designee shall contact the regional center for any incarcerated person suspected or confirmed to have a developmental disability for the purposes of diagnosis or treatment ☐ ☐ ☒ within 24 hours of such determination, excluding holidays and weekends. 1058 USE OF RESTRAINT DEVICES 33.1058 Restraints for this purpose are not used at The facility administrator, in cooperation with the this facility. responsible physician, shall develop and implement written policies and procedures for the use of restraint devices. Restraint devices include any devices which immobilize extremities or prevent the incarcerated person from being ambulatory. The provisions of this ☒ ☐ ☐ section do not apply to the use of handcuffs, shackles, or other restraint devices when used to restrain incarcerated people for security reasons. The facility manager may delegate authority to place an incarcerated person in restraints to responsible health care staff. (a) The policy shall address the following areas: ☐ ☐ ☒ (1) acceptable restraint devices; ☐ ☐ ☒ (2) signs or symptoms which should result in immediate medical/mental health referral; availability of cardiopulmonary resuscitation ☐ ☐ ☒ equipment; (3) protective housing of restrained persons; ☐ ☐ ☒ (4) provision for hydration and sanitation needs; and, ☐ ☐ ☒ (5) exercising of extremities. ☐ ☐ ☒ (b) Policy shall also include, but not be limited to, the following requirements: ☐ ☐ ☒ (1) In no case shall restraints be used for ☐ ☐ ☒ 3725 Orange Orange PD PRO 23-24 Page 10 of 17 A351 TH PRO eff. 4/2023 (23-24).dot TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS punishment or as a substitute for treatment. (2) Restraint devices shall only be used on incarcerated people who display behavior which results in the destruction of property or reveal an ☐ ☐ ☒ intent to cause physical harm to self or others. (3) Restraint devices should be used only when less restrictive alternatives, including verbal de- escalation techniques, have been attempted and ☐ ☐ ☒ are deemed ineffective. (4) An incarcerated person shall be placed in restraints only with the approval of the facility manager, the facility watch commander, or ☐ ☐ ☒ responsible health care staff; continued retention shall be reviewed a minimum of every hour. (5) Continuous direct visual observation shall be maintained until a medical opinion can be obtained. ☐ ☐ ☒ (6) A medical opinion on placement and retention shall be secured within one hour from the time of ☐ ☐ ☒ placement. (7) A medical assessment shall be completed within four hours of placement. ☐ ☐ ☒ (8) Continuous direct visual observation shall be conducted at least twice every 30 minutes to ensure that the restraints are properly employed, and to ensure the safety and well-being of the incarcerated person. Such observation shall be ☐ ☐ ☒ documented. While in restraint devices all incarcerated persons shall be housed alone or in a specified housing area which makes provisions to protect the person from abuse. (9) If the facility manager, or designee, in consultation with responsible health care staff determines that an incarcerated person cannot be safely removed from restraints after eight ☐ ☐ ☒ hours, the person shall be taken to a medical facility for further evaluation. (10) Where applicable, the facility manager shall use the restraint device manufacturer’s recommended maximum time limits for ☐ ☐ ☒ placement. (11) All events and information related to the placement in restraints shall be documented and shall be video recorded unless exigent circumstances prevent staff from doing so. The documentation shall include: the reason for ☐ ☐ ☒ placement; person authorizing placement; names of staff involved in the placement; injuries sustained; and the duration of placement. 1058.5 RESTRAINTS AND PREGNANT PERSONS Policy 301 Restraints for this purpose are not used at The facility administrator, in cooperation with the this facility. responsible physician, shall develop written policies and procedures for the use of restraint devices on ☒ ☐ ☐ pregnant people. In accordance with Penal Code Section 3407, the policy shall include reference to the following: 3725 Orange Orange PD PRO 23-24 Page 11 of 17 A351 TH PRO eff. 4/2023 (23-24).dot TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (1) An incarcerated person known to be pregnant Policy 301 or in recovery after delivery or termination of the pregnancy shall not be restrained by the use of ☐ ☐ ☒ leg or waist restraints, or handcuffs behind the body. (2) An incarcerated pregnant person in labor, Policy 301 during delivery, or in recovery after delivery or termination of the pregnancy, shall not be restrained by the wrists, ankles, or both, unless ☐ ☐ ☒ deemed necessary for the safety and security of the incarcerated person, the staff, or the public. (3) Restraints shall be removed when a professional who is currently responsible for the medical care of an incarcerated pregnant person during a medical emergency, labor, delivery, or ☐ ☐ ☒ recovery after delivery or termination of the pregnancy determines that the removal of restraints is medically necessary. (4) Upon confirmation of an incarcerated person’s pregnancy, they shall be advised, orally or in writing, of the standards and policies ☐ ☐ ☒ governing incarcerated pregnant people. 1067 ACCESS TO TELEPHONE 33.1067 P.C. 851.5 states the following: The facility administrator shall develop written policies ‘Immediately upon being booked, and, and procedures which allow access to a telephone or except where physically impossible, no communication device beyond those telephone calls later than three hours after arrest, an which are required by Section 851.5 of the Penal arrested person has the right to make at Code. Individuals who are known to have, or are least three completed telephone calls to an perceived by others as having hearing or speech attorney of his choice, or, if he has no impairments shall be provided access to the ☒ ☐ ☐ funds, a public defender... a bail appropriate telecommunication device which will bondsman, a relative or other person.’ facilitate communication. Such devices may include but are not limited to videophones, teletypewriters, or Subjects who are perceived by others as third-party communications assistance. An individual’s having hearing or speech impairments access to telephone communications shall not be would be transported to the county jail withdrawn unless doing so is required to uphold the where they would have access to needed safety and security of the facility. communication devices. 1068 ACCESS TO COURTS AND COUNSEL 33.1062 If a prisoner requests to see their attorney The facility administrator shall develop written policies and makes arrangements for the attorney and procedures to ensure incarcerated persons have ☒ ☐ ☐ to come to the facility, the attorney must be access to the court and to legal counsel. Such access allowed a visit. shall consist of: (b) confidential consultation with attorneys. Prisoners have a constitutional right to confidential access to attorneys and legal ☒ ☐ ☐ representation. 1080 RULES AND DISCIPLINARY ACTIONS 33.1081 Discipline is not administered at this Wherever discipline is administered, each facility facility. administrator shall establish written rules and ☐ ☐ ☒ disciplinary actions to guide the conduct of incarcerated persons. Such rules and disciplinary actions shall be stated simply and affirmatively and posted conspicuously in housing units and the booking area or issued to each ☐ ☐ ☒ person upon booking. 3725 Orange Orange PD PRO 23-24 Page 12 of 17 A351 TH PRO eff. 4/2023 (23-24).dot TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS For those individuals with limited literacy, who are unable to read English, and for persons with disabilities, provision shall be made for the jail staff to ☐ ☒ instruct them verbally or provide them with material in ☐ an understandable form regarding jail rules and disciplinary procedures and actions. 1081 PLAN FOR DISCIPLINE OF 33.1081 INCARCERATED PERSONS Discipline is not administered at this facility. If discipline is NOT administered, written policy should indicate as such. If discipline is administered, Sections 1080, 1081, 1082, 1083 and 1084 apply. ☐ ☐ ☒ Each facility administrator shall develop written policies and procedures for discipline of incarcerated persons. The plan shall include, but not be limited to, the following elements: (a) Temporary Loss of Privileges: For minor acts of non- conformance or minor violations of facility rules, staff may impose a temporary loss of privileges, such as access to television, telephones, commissary, or ☐ ☐ ☒ lockdown for less than 24 hours, provided there is written documentation and supervisory approval. (b) Disciplinary Actions: Major violations of facility rules or repetitive minor acts of non-conformance or repetitive minor violations of facility rules shall be reported in writing by the staff member observing the ☐ ☐ ☒ act and submitted to the disciplinary officer. The consequences of such violations may include, but are not limited to: 1. Loss of good time/work time. ☐ ☐ ☒ 2. Placement in disciplinary separation. ☐ ☐ ☒ 3. Loss of privileges mandated by regulations. ☐ ☐ ☒ A staff member with investigative and disciplinary authority shall be designated as a disciplinary officer ☐ ☐ ☒ to impose such consequences. Staff shall not participate in disciplinary review if they are involved in the charges. ☐ ☐ ☒ Such charges pending against an incarcerated person shall be acted on with the following provisions ☐ ☐ ☒ and within specified timeframes: 1. A copy of the report, or a separate written notice of the violation(s), shall be provided to ☐ ☐ ☒ the incarcerated person. 2. Unless declined by the incarcerated person, a hearing shall be provided no sooner than 24 hours after the report has been submitted to the disciplinary officer and the incarcerated person has been informed of the charges in writing. The ☐ ☐ ☒ hearing may be postponed or continued for a reasonable time through a written waiver by the incarcerated person, or for good cause. 3. The incarcerated person shall be permitted to appear on their own behalf at the time of hearing and present witnesses and documentary evidence. The incarcerated person shall have ☐ ☐ ☒ access to staff or assistance when they have limited literacy, or the issues are complex. 3725 Orange Orange PD PRO 23-24 Page 13 of 17 A351 TH PRO eff. 4/2023 (23-24).dot TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS 4. A charge(s) shall be acted on no later than 72 hours after an incarcerated person has been ☐ ☐ ☒ informed of the charge(s) in writing. 5. Subsequent to final disposition of disciplinary charges by the disciplinary officer, the charges and the action taken shall be reviewed by the ☐ ☐ ☒ facility manager or designee. 6. The incarcerated person shall be advised in a written statement by the fact-finders about the evidence relied on and the reasons for the ☐ ☐ ☒ disciplinary action. A copy of the record shall be kept pursuant to Penal Code Section 4019.5. 7. There shall be a policy of review and appeal to a supervisor on all disciplinary action. ☐ ☐ ☒ (c) Nothing in this section precludes a facility administrator from administratively separating any incarcerated person from the general population or program for reasons of personal, mental, or physical health, or under any circumstance in which the safety ☐ ☐ ☒ of the person, staff, program, or community is endangered, pending disciplinary action or a review as required by Section 1053 of these regulations. (d) Nothing in this section precludes the imposition of conditions or restrictions that reasonably relate to a ☐ ☐ ☒ legitimate, non-punitive administrative purpose. 1082 FORMS OF DISCIPLINE 33.1081 Discipline is not administered at this The degree of actions taken by the disciplinary officer facility. shall be directly related to the severity of the rule infraction and promotion of desired behavior through a progressive disciplinary process. Acceptable forms of discipline shall consist of, but not be limited to, the following: (a) Loss of privileges. (b) Extra work detail. ☐ ☐ ☒ (c) Short term lockdown for less than 24 hours. (d) Removal from work details. (e) Forfeiture of “good time” credits earned under Penal Code Section 4019. (f) Forfeiture of “work time” credits earned under Penal Code Section 4019. (g) Disciplinary separation. 1083 LIMITATIONS ON DISCIPLINARY 33.1081 ACTIONS Discipline is not administered at this facility. The Penal Code and the State Constitution expressly prohibit all cruel and unusual punishment. Disciplinary actions shall not include corporal punishment, group punishment when feasible, or physical or psychological degradation. ☐ ☐ ☒ Additionally, there shall be the following limitations: (a) Disciplinary separation shall be considered an option of last resort and as a response to the most serious and threatening behavior, for the shortest time possible, and with the least restrictive conditions possible. 3725 Orange Orange PD PRO 23-24 Page 14 of 17 A351 TH PRO eff. 4/2023 (23-24).dot TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (1) If a person is on disciplinary separation status for 30 consecutive days there shall be a review by the facility manager before the disciplinary separation status is continued. This review shall include a consultation with health ☐ ☐ ☒ care staff. Such reviews shall continue at least every fifteen days thereafter until the disciplinary status has ended. This review shall be documented. (2) The disciplinary separation cells or cell shall have the minimum furnishings and space specified in Title 24, Part 2, 1231.2.6 and 2.7. Occupants shall be issued clothing and bedding as specified in Articles 13 and 14 of these regulations and shall not be deprived of them through any portion of the day except that those incarcerated persons who engage in the ☐ ☐ ☒ destruction of bedding or clothing may be deprived of such articles. The decision to deprive a person of such articles of clothing and bedding shall be reviewed by the facility manager or designee during each 24-hour period. (3) If after placement in separation, mental health or medical staff determine that an individual has serious mental illness or an intellectual disability, they shall be removed ☐ ☐ ☒ from disciplinary separation immediately upon this determination. (b) The delegation of authority to any incarcerated person or group of incarcerated people to exercise the right of punishment over any other incarcerated ☐ ☐ ☒ person or group of incarcerated people. (Penal Code section 4019.5) (c) In no case shall a safety cell, as specified in Title 24, Part 2, 1231.2.5, or any restraint device be used ☐ ☐ ☒ for disciplinary purposes. (d) No incarcerated person may be deprived of the implements necessary to maintain an acceptable level of personal hygiene as specified in Section 1265 ☐ ☐ ☒ of these regulations. (e) Food shall not be withheld as a disciplinary measure. ☐ ☐ ☒ (f) Correspondence privileges shall not be withheld except in cases where the incarcerated person has violated correspondence regulations, in which case correspondence may be suspended for no longer ☐ ☐ ☒ than 72 hours, without the review and approval of the facility manager. (g) In no case shall access to courts and legal counsel be suspended as a disciplinary measure. ☐ ☐ ☒ 1084 DISCIPLINARY RECORDS 33.1081 Discipline is not administered at this Penal Code Section 4019.5 requires that a record is facility. kept of all disciplinary actions administered, therefore. This requirement may be satisfied by ☐ ☐ ☒ retaining copies of rule violation reports and report of the disposition of each. 3725 Orange Orange PD PRO 23-24 Page 15 of 17 A351 TH PRO eff. 4/2023 (23-24).dot TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS 1270 STANDARD BEDDNG AND LINEN ISSUE Incarcerated prisoners will not be detained longer than 24 hours. The standard issue of clean suitable bedding and linens, for each incarcerated person entering a living ☐ ☐ ☒ area who is expected to remain overnight, shall include, but not be limited to: (a) one serviceable mattress which meets the requirements of Section 1272 of these regulations; ☐ ☐ ☒ (b) one mattress cover or one sheet; ☐ ☐ ☒ (d) one blanket or more depending up on climatic conditions. ☐ ☐ ☒ Policy and procedure shall require that items (a), (b), and (d) above be provided prior to the first night in the ☐ ☐ ☒ facility. Two blankets or sleep bag may be issued in place of one mattress cover or one sheet at the request of the ☐ ☐ ☒ incarcerated person. Temporary Holding facilities which hold persons longer than 12 hours shall provide an incarcerated person with bedding and linen that meet the ☐ ☐ ☒ requirements of (a), (b) and (d) above prior to their first night in the facility and every night thereafter. 1280 FACILITY SANITATION, SAFETY, 33.1280 FACILITY SANITATION, AND MAINTENANCE SAFETY AND MAINTENANCE The facility administrator shall develop written The holding facility will always be kept in a policies and procedures for the maintenance of an clean and safe condition. Any damaged or acceptable level of cleanliness, repair, and safety defaced property shall be reported to the ☒ ☐ ☐ throughout the facility. Such a plan shall provide for a Watch Commander for proper disposition. regular schedule of housekeeping tasks and inspections to identify and correct unsanitary or Personnel who observe an unsafe work unsafe conditions or work practices which may be practice shall promptly report such found. observation to the Watch Commander. 3725 Orange Orange PD PRO 23-24 Page 16 of 17 A351 TH PRO eff. 4/2023 (23-24).dot DETENTION OF MINORS YES NO COMMENTS Are minors held in this facility? There are two juvenile holding rooms in the facility, out of sight and sound of adult detainees. The Juvenile Justice and Delinquency Prevention Act (JJDPA) establishes the following federal However, youth are not brought into the facility. standards on the detention of minors: Per department’s policy and records, no youth (1) Deinstitutionalization of Status Offenders ☐ ☒ have been detained inside the facility or in the (2) Separation department’s administrative area in the past 4 (3) Jail Removal (6-hour limit) years. The JJDPA requires an annual inspection on the federal standards for facilities that hold minors in secure detention. Are minors held in the jail cells? Penal Code Section 6030 and 6031.4 require the biennial inspection of local detention facilities that hold minors in secure detention in the jail. Title 15, Article 9 establishes the minimum standards of how ☐ ☒ facilities hold minors in temporary custody in the jail. Facilities that do not hold minors in the jail are not subject to Title 15, Article 9 biennial inspections. 3725 Orange Orange PD PRO 23-24 Page 17 of 17 A351 TH PRO eff. 4/2023 (23-24).dot PHYSICAL PLANT EVALUATION BOARD OF STATE AND COMMUNITY CORRECTIONS - BIENNIAL INSPECTION ADULT COURT AND TEMPORARY HOLDING FACILITIES APPLICABLE REGULATIONS: 1/78 Title 24, California Code of Regulations (CCR) BSCC Code: 3725 FACILITY NAME: Orange Police Department City Jail FACILITY TYPE: THJ APPLICABLE REGULATIONS (Check All That Apply): 1/78: OTHER: 1986 FIELD REPRESENTATIVE: Michael J. Bush DATE : 05/30/2023 ARTICLE/SECTION YES NO N/A COMMENTS Temporary Holding Cells (2.2) ☒ ☐ ☐ Contain 10 square feet of floor per inmate Limited to no more than 16 inmates ☒ ☐ ☐ No smaller than 40 square feet ☒ ☐ ☐ Contain sufficient seating to accommodate all inmates ☒ ☐ ☐ Toilet accessible ☒ ☐ ☐ Wash basin accessible ☒ ☐ ☐ Drinking fountain accessible ☒ ☐ ☐ Provide for adequate visual supervision of inmates ☒ ☐ ☐ Bunk provided to inmates held between hours of 2400 and 0600 (Later, less restrictive 1994 standards only require a bunk if inmates are held longer than 12 ☒ ☐ ☐ hours) Weapons Locker (3.12) External to the security area and equipped with ☒ ☐ ☐ individual compartments, locks and keys Sobering Cells (WA) (2.4) 11-17-94 granted a permanent alternate ☒ ☐ ☐ means of compliance for padded benches in Limited to no more than 8 inmates each of the two sobering cells. Contain 20 square feet of floor per inmate ☒ ☐ ☐ No smaller than 60 square feet ☒ ☐ ☐ Contain toilet, washbasin and drinking fountain ☒ ☐ ☐ Partitions or handrails located next to toilet fixture to Closure plates have been added to hand ☒ ☐ ☐ provide support railing. Padding on the floor ☒ ☐ ☐ Provide easy, unobstructed visual observation ☒ ☐ ☐ Safety Cells (WA) (2.5) No cells of this type in the facility. The remainder of the regulation was deleted from Contain 48 square feet with one floor dimension at ☐ ☐ ☒ this checklist. least 6 feet 3725 Orange Orange PD PHY 23-24 - 1 - A370 PHY CH-TH 1-78.dot (9/98) ARTICLE/SECTION YES NO N/A COMMENTS Shower-Delousing Room (3.4) They directly transport to Orange County Jail. ☒ ☐ ☐ Available Secure Vault or Storage Space (2.1) ☒ ☐ ☐ Available for inmate valuables Telephone (2.1) ☒ ☐ ☐ Available for inmate use per Penal Code § 851.5 Audio Monitoring (2.22) Video cameras are inside each cell. No audio monitoring in cells although each is equipped ☐ ☐ ☒ For facilities planned or constructed after 8-86 with a panic alarm button (sounds in the W/C’s office). Janitor Closet (2.20) ☒ ☐ ☐ Available Storage Rooms (WA) (2.21) ☒ ☐ ☐ Available Emergency Power (2.24) Available to maintain fire and life safety, security, ☒ ☐ ☐ communications and alarm systems Attorney Interview Space (2.26) ☒ ☐ ☐ Available 3725 Orange Orange PD PHY 23-24 - 2 - A370 PHY CH-TH 1-78.dot (9/98) BOARD OF STATE AND COMMUNITY CORRECTIONS - BIENNIAL INSPECTION ADULT DETENTION FACILITY LIVING AREA SPACE EVALUATION BSCC Code: 3725 FACILITY: Orange Police Department City Jail TYPE: THJ RC: 0 FIELD REPRESENTATIVE: Michael J. Bush DATE: 05/30/2023 ROOMS EACH ROOM Cell Applicable # EACH CELL Total DIMENSIONS FIXTURES* Location Type Standards Cells # RC RC (L x W x H) T U W F S Beds 32-33, Booking - 4 - - - 5.9’ x 5.1’ x 10.0’ - - - - - Enclosure 35-36 Notes: Booking rooms contain no furnishings; if extended detention – would provide chair. Non-rated cells. 44 Sobering 1986 1 - (4) (4) 9.0’ x 10.1’ x 1 - 1 1 - 10.0’ Notes: padded bench 30” w x 108”l x 20.5”h; floor padded; permanent approval granted for bench on 11/17/94. 45 Holding 1986 1 - (6) (6) 9.0’ x 10.1’ x 1 - 1 1 - 10.0’ Notes: sink/fountain separate from commode; 9’ bench; seating limits capacity. 46 Holding 1986 1 - (6) (6) 9.0’ x 10.1’ x 1 - 1 1 - 10.0’ Notes: 9’ bench; seating limits capacity. 47 Holding 1986 1 - (6) (6) 9.0’ x 10.1’ x 1 - 1 1 - 10.0’ Notes: 9’ bench; seating limits capacity. 48 Holding 1986 1 - (6) (6) 9.0’ x 10.1’ x 1 - 1 1 - 10.0’ Notes: 9’ bench; seating limits capacity. 49 Sobering 1986 1 - (4) (4) 9.0’ x 10.1’ x 1 - 1 1 - 10.0’ Notes: separate sink and toilet; padded bench 30” w x 108”l x 20.5”h; floor padded; handicap accessible; permanent approval granted for bench on 11/17/94. Overflow (used for Juveniles if secure detention is required) 42 Holding 1986 1 - (6) (6) 9.0’ x 10.1’ x 1 - 1 1 - 10.0’ 43 Holding 1986 1 - (6) (6) 9.0’ x 10.1’ x 1 - 1 1 - 10.0’ Notes: Ceiling mounted cameras in all cells. Closure plates have been installed to the handrails. *T = Toilets; U = Urinals; W = Wash Basins; F = Fountains; S = Showers in unit; If "Total RC" appears in brackets ( ), it is not part of the facility's rated capacity. "+" indicates that capacity includes prorated air space from adjacent areas. 3725 Orange Orange PD LASE 23-24 - 1 - A360 LAS Adult.dot (9/98)