February 17, 2025
Our Commitment to Remaining an Inclusive and Welcoming Community
The City of Bethlehem is currently home to approximately 78,000 diverse residents, with 30% identifying as Latino/Hispanic, 11% identifying as foreign born, and 25% disclosing that they speak a language other than English at home. The administration believes that whether your family has been here for generations, or whether you have been here for a month, that all are deserving of the opportunity to reside, thrive, and contribute to Bethlehem’s welcoming community. In this city, we believe in the power of coalition building and creating a safe and vibrant quality of life for all of our residents. We acknowledge that while many cities are seeking to respond to the recent threats of deportation by creating a “welcoming ordinance,” the City of Bethlehem already has practices and policies through City Hall and its Police Department which live into the recommendations of such criteria. In fact, many of these practices have been in place for years within the City of Bethlehem.
City Hall currently participates and facilitates the intentional celebration of various immigrant cultures, customs, and beliefs, and utilizes our office to refer immigrant communities to programs that can help obtain U.S. citizenship. We actively work with our community-based organizations, such as our public library, school district, faith communities, and other partners to provide our immigrant communities needed resources and supports. For this administration, it has been a fundamental principle for us to invest our time and resources into the community we serve under a strategy and philosophy entitled, “We Build Bethlehem,” which seeks to provide direct service delivery, financial support for our community-based partners to create equitable outcomes, and intentional partnerships to establish communal wellbeing for all residents, regardless of immigration status.
Communication is key in building trust, which is why the City’s departments and bureaus, including our Police Department, Health Bureau, and Community and Economic Development Department, all have language access plans to insure that the sharing of information is never compromised with those who do not speak English as their primary language. Additionally, the City of Bethlehem is currently undergoing a Communication Audit which will evaluate how our local emergency management efforts can inform the community of a crisis in their primary languages, with our engagement platform and city website already able to toggle its contents between English and Spanish.
In the midst of Executive Orders and federal policy changes, our Police Department remains committed to serving our community, and is in regular contact with Bethlehem Area School District and our faith community to make sure our citizens feel safe. With concerns around targeted deportation efforts coming to our police department, it’s important to note that each officer of the Bethlehem Police Department promises upon the start of their employment to protect and serve all residents without bias, prohibiting discrimination when it comes to race, color, sex, ethnicity, national origin, religious creed, gender, sexual orientation, gender identity, age, economic status, cultural affiliation, ancestry, handicap, disability. or any other identifiable categorization, including ability to speak English. Please see Chief Kott’s memo for a more in-depth review of the Bethlehem Police Department’s policies in practice. All of our employees follow a similar rule - provide the highest quality and respectful service to every resident no matter their story or how long they have resided in our city.
The City of Bethlehem’s Administration remains committed to being a welcoming community and fostering a culture of dignity and respect for all of our residents. In the midst of a changing federal landscape, we continue to be fully present and intentional about keeping our communication channels open, allowing our residents to feel safe and empowered. Over the past three years, with an increase in the last month, we are continuing to meet with residents and community groups, with professionals and leadership in our City departments and bureaus, to discuss, review, listen, and answer questions as they relate to our promise and commitment to being a city which is to remain inclusive and welcoming to all who visit or seek to call Bethlehem “home.”
In solidarity,
J. William Reynolds, Mayor of Bethlehem
Janine Carambot Santoro, Director of Equity and Inclusion
CITY OF BETHLEHEM, PENNSYLVANIA
DEPARTMENT OF POLICE
TO: Members of Bethlehem City Council
FROM: Michelle L. Kott, Chief of Police
DATE: 14 February 2025
RE: Welcoming City Ordinance
Recently, there have been several inquiries about the City’s Police Department procedures as they relate to the area of immigration. Specifically, questions have arisen about what are our current policies and would they be influenced if City Council passed any resolution/ordinance on the subject. The short answer is our current policies are strong in this area, for reasons I will lay out below, and additional language included in a resolution would not meaningfully strengthen any of our current policies. Not every police department can say that but we can and we are proud of that.
As a city resident, police officer for 20 years and someone who has been tasked with creating and building a modern police department as Chief over the last past five, I do have concerns regarding the recently proposed “Welcoming City law” that has been discussed. While the ordinance is well-intentioned, there are several areas of concern for our police department. Below, I outline these concerns and highlight the ways in which our current practices already align with many of the policies proposed in the ordinance.
One of the goals of the proposed law is to limit the involvement of local police in enforcing federal immigration laws. However, immigration enforcement is the responsibility of federal authorities, not cities. The Bethlehem Police Department does not participate in the ICE 287(g) program, which allows select state and local law enforcement officers to enforce federal immigration law. As such, our focus is solely on enforcing local and state laws, not immigration enforcement. Any change to the department’s participation in this program would require city council’s approval.
Additionally, the proposed city law would prohibit local law enforcement from inquiring about an individual’s immigration status unless required by law. As a Commission for the Accreditation of Law Enforcement Agency (CALEA)-accredited agency, we already have policies and directives in place to ensure that our officers adhere to strict guidelines regarding the prohibition against any form bias-based profiling. The United Sates Constitution requires that officers have reasonable suspicion or probable cause when conducting investigative detentions, traffic stops, arrests, searches, and seizures. Therefore, our officers would not inquire about an individual’s immigration status arbitrarily. However, given the myriad of situations that might at any time confront an officer on duty, and given the unpredictable nature of human behavior, it is impossible to say that such concerns could never become a vital part of understanding and assessing the totality of the situation the officer is faced with when handling a call for service.
Bethlehem PD has successfully maintained CALEA certification since 2004. CALEA accreditation represents the gold standard benchmark for public safety agencies. Of approximately 1,200 law enforcement agencies in Pennsylvania, Bethlehem PD is one of only nine (9) that are CALEA accredited. Nationally, only approximately 4% of law enforcement agencies are CALEA accredited. CALEA was created in 1979 by the National Organization of Black Law Enforcement Executives (NOBLE); by the International Association of Chiefs of Police (IACP); the National Sheriffs' Association (NSA); and the Police Executive Research Forum (PERF).
Accreditation requires that law enforcement agencies demonstrate: comprehensive and uniform written directives that clearly define authority, performance, and responsibilities; reporting procedures and analyses to make fact-based and informed management decisions; preparedness to address natural or man-made critical incidents; community relationship-building and maintenance; independent review by subject matter experts; and continuous pursuit of excellence through annual reviews and other assessment measures. In addition to the U.S., there are CALEA certified law enforcement agencies in other countries, including Canada, countries in the Caribbean, and in 24 states in Mexico. The board of CALEA commissioners and delegates includes members from the U.S. and Mexico.
It is also important that our officers are able to maintain their ability to exercise discretion in their duties, something which the proposed law would restrict. Discretion refers to the ability of officers to make judgment calls based on the unique circumstances of a situation. It is a critical element in law enforcement, allowing officers to assess factors and make on-the-scene judgments and decisions that often are not - and as a practical matter cannot be - addressed specifically in law, so as to best serve the interests of justice, safety, and community trust.
It is critical that our officers continue to maintain the ability to exercise discretion in a manner that upholds both the law and the ethical principles of justice. Selectivity in hiring, training programs, policies, mentoring, department culture, and supervision all support our officers in developing this skill and using it wisely. Furthermore, it is important to balance the need for accountability with the understanding that officers need the flexibility to make nuanced decisions based upon their training and experience, as well as the specific circumstances they are faced with. I ask that Council consider the importance of maintaining officers’ discretionary powers, and ensure that any changes to policing policies or practices take into account the value of discretion as an integral part of responsible law enforcement.
Additionally, I believe cooperation among federal, state, and local law enforcement is critical to public safety. I’m concerned that the proposed law’s limiting of cooperation with federal authorities could create complications in situations where there is a direct need to engage with federal agencies in City of Bethlehem criminal investigations and in keeping the peace in the city; for example, in cases involving undocumented individuals with serious criminal records, or in cases involving undocumented individuals who are being victimized.
Finally, I also think that the proposed Welcoming City law may provide the community with a false sense of security, as it does not – and cannot - supersede federal law. Per the proposed law, law enforcement is still required to cooperate with federal authorities as required by law - meaning that regardless of whether or not the proposed law passes, federal authorities are still authorized to come into the city to conduct immigration enforcement. And if and when they do, it is impossible to predict which circumstances might develop that would warrant a Bethlehem Police response and exercise of sound discretion.
In conclusion, City Council is the body with the ability to pass any resolution. While we recommend against passing anything for the reasons stated above, ultimately the language that has been discussed in other cities would not legally or practically meaningfully change the way that the department operates on a day-to-day basis. This is one of the reasons we don’t feel that any passage is necessary. As a department, we spend a lot of time making sure we hire great people to keep our residents safe and protect their Constitutional rights. At the top of the list of what makes a good officer is the judgment they bring to the job. I respectfully submit that the department has earned the trust of the City to continue to exercise that judgment and discretion wisely. Thank you and please let me know if you have any questions.
Michelle L. Kott, Chief of Police