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Home My WebLink AboutStaff Report 2605-6381CITY OF PALO ALTO CITY COUNCIL Special Meeting Monday, June 01, 2026 Council Chambers & Hybrid 5:30 PM Agenda Item 2.Study Session on Flock Automated License Plate Recognition Technology; CEQA status – categorically exempt. Public Comment, Staff Presentation City Council Staff Report From: City Manager Report Type: STUDY SESSION Lead Department: Police Meeting Date: June 1, 2026 Report #:2605-6381 TITLE Study Session on Flock Automated License Plate Recognition Technology; CEQA status – categorically exempt. BACKGROUND In April 2023, the City Council approved a three-year contract with Flock Safety (hereinafter “Flock”) for the deployment of twenty fixed automated license plate recognition (ALPR) cameras, as well as the associated Surveillance Use Policy.1 Based on the success of the first twenty ALPR cameras deployed, and the identification of specific areas where additional cameras would be useful, in December of 2024, the Council approved a five-year contract, which deployed ten additional ALPR cameras and extended the term of the contract for all thirty cameras thru December of 2029.2 In mid-2023, unbeknownst to many law enforcement agencies including PAPD, Flock had added a new “Nationwide Lookup” search feature. Using this feature, an out-of-state local law enforcement or federal agency could perform a broad search of data from Flock’s entire nationwide network of over 6000 cameras belonging to more than 4000 agencies, including the 20 cameras then-deployed in Palo Alto. The feature did not enable targeted searches of any specific agency’s data. These searches could only be performed system- wide and only when a full 7-digit license plate number was known. All searches required articulation of a legitimate law enforcement purpose. 1 City Council, April 3, 2023; Agenda Item #11; SR2301-0741, https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=82232&dbid=0&repo=PaloAlto&searchid=35d2643 9-835f-4015-b198-79ecd7231a2e 2 City Council, December 2, 2024; Agenda Item #11; SR #2408-3360, PAPD was first made aware of this issue in December 2025 and subsequently learned that Flock had already disabled the feature for PAPD by late October 2024 and for all California law enforcement agencies by March 2025. ANALYSIS An elderly man, who suffers from dementia, was discovered to have taken his caregiver’s vehicle without permission and was missing. Flock data was used to determine his path of travel and, ultimately, locate him safely within the hour; A despondent teenager suffering from a mental health crisis had made threats of suicide before leaving home in a vehicle. Flock data was used to determine their path of travel and a Flock real-time alert allowed officers to locate them safely and ensure they received appropriate care; Two suspects committed an armed robbery in Palo Alto after having just committed an armed robbery in another city. A Flock real-time alert allowed officers to locate the vehicle’s direction of travel within minutes, and additional Flock alerts in another city aided officers as they pursued the vehicle, apprehended the suspects, and recovered multiple firearms; Two suspects committed a robbery at a shopping center and injured a police officer during their escape. Palo Alto Flock data was used to identify the suspects and Flock data in other cities enabled PAPD detectives to locate the suspect vehicle and, ultimately, arrest both suspects within 24 hours. A suspect was arrested in connection with a series of felony retail thefts in Palo Alto and other cities throughout the region. Investigators were able to strengthen their case by combining Flock data from Palo Alto and other cities to confirm that the suspect’s vehicle had, in fact, been in the area of each of the thefts at the times of the thefts. Two suspects, responsible for dozens of residential burglaries throughout the region (including multiple occupied burglaries in Palo Alto), were identified and arrested through the investigative use of Flock data captured in multiple jurisdictions. The suspects were ultimately located and arrested in another city with the help of Flock data. A Flock real-time alert notified officers of the presence in Palo Alto of a vehicle wanted in connection with a shooting homicide in another city. PAPD officers located the vehicle and arrested the homicide suspect. To derive maximum benefit with the fewest cameras needed, the Department has placed its cameras at strategically selected locations based on several factors: crime statistics, common vehicular ingress and egress points, and traffic volume. The cameras at these locations have proven to be effective at providing officers with real-time alerts when vehicles of interest enter or flee the City via the most common ingress and egress points. The cameras are placed on roadways with high traffic volume, with an emphasis on ingress and egress routes and commercial and retail areas. Applicable Law and Policy California Civil Code § 1798.90.55 expressly prohibits sharing ALPR data with out of state or federal agencies. Additionally, California Government Code § 7284 et seq. (known as the California Values Act) prohibits the use or sharing of ALPR for immigration enforcement purposes. Beyond the restrictions imposed by California law, the Department’s Fixed ALPR surveillance use policy, approved by the City Council in 2023,5 provides in relevant part: Data is only accessible to trained PAPD staff with a legitimate law enforcement need, and all queries are logged and subject to audit. 5 Approval of the policy is available at: City Council, April 3, 2023, Action Minutes, https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=43006 The Department only shares its data with other local law enforcement agencies with whom an MOU is in place, and does not share data with any non-law enforcement entities. Data not saved as evidence in a specific criminal investigation is purged after 30 days. The Department makes accessible to the public, via its ALPR webpage,7 relevant policies as well as information concerning the number of cameras deployed, the data retention period, and the names of law enforcement agencies with whom it shares data by agreement. Flock Safety also maintains a publicly accessible Transparency Portal8 containing much of the same information. Palo Alto Data Sharing While its data was unknowingly included in the “Nationwide Lookup” searchable dataset for a period of time ending in October 2024, PAPD has worked with Flock to confirm that no PAPD data (i.e., license plates captured by Palo Alto cameras) was actually received by any out-of-state agency or federal agency as a result of any “Nationwide Lookup” search. In other words, PAPD had no records that matched the “Nationwide Lookup” searches performed by out of state or federal agencies. Even though no PAPD data was shared, PAPD reviewed a sampling of the searches performed by out-of-state local law enforcement and federal agencies via the “Nationwide Lookup” feature. The searches it reviewed all appeared to be linked to legitimate law enforcement investigations (e.g., burglary, vehicle theft, assault).3 Additionally, PAPD found that no searches had been performed by ICE, Customs and Border Patrol, or the Department of Homeland Security; keyword searches did not identify any searches that appeared to be associated with immigration enforcement or reproductive rights enforcement. Flock Updates Flock has implemented several feature changes in response to concerns regarding potential improper use.9 Among those changes: Disabling the “Nationwide Lookup” feature for all California agencies; Prohibiting any sharing agreements between California and non-California agencies; 7 City of Palo Alto’s Automated License Plate Recognition (ALPR) webpage; https://www.paloalto.gov/Departments/Police/Public-Information-Portal/Automated-License-Plate-Recognition- ALPR 8 Flock Safety, Palo Alto Police Transparency Portal webpage; https://transparency.flocksafety.com/palo-alto-ca-pd 9 Flock Safety, Flock Algins License Plate Reader Technology with State-Specific Legal Frameworks Blog, 2026; https://www.flocksafety.com/blog/flock-aligns-license-plate-reader-technology-with-state-specific-legal-frameworks Requiring a documented FBI National Incident-Based Reporting System (NIBRS) case type for all searches to make auditing easier; Filtering and blocking, by keyword, prohibited searches involving immigration or reproductive healthcare. If a search containing a blocked keyword is attempted, California agency data will not be queried and no data will be returned. Flock has also expanded its compliance team to ensure that new features are thoroughly vetted for state-specific legal compliance. In addition, Flock is in the process of implementing updated processes for notifying customers of new system functionality and any changes to user settings. Regional Use of Flock ALPR technology is widely used throughout Santa Clara County, with Flock being the predominant vendor. Nearly all agencies – as well as most agencies in adjoining counties – share their ALPR data with one another. ALPR data sharing among local law enforcement partners allows agencies to collaboratively investigate, identify and apprehend multi- jurisdictional offenders, or those who commit crimes in one jurisdiction but reside in another. No other fixed-ALPR vendor has significant market share in California. With that, as a result of recent concerns, several Santa Clara County jurisdictions have re- examined their continued use of Flock ALPR cameras. The City of Mountain View and Town of Los Altos Hills elected to discontinue use of Flock. The Santa Clara County Board of Supervisors aborted its planned roll-out of Flock ALPR cameras and is, instead, exploring alternative ALPR vendors. In the interim, the Sheriff’s Office has also ceased accessing Flock cameras owned by the contract cities of Saratoga and Cupertino. On the other hand, the city councils of San Jose and Sunnyvale recently approved the continued used of Flock ALPR with some minor policy modifications, and the cities of Santa Clara, Milpitas, Morgan Hill, Gilroy, and Los Gatos-Monte Sereno have continued to use Flock ALPR without interruption. The Town of Los Altos has indicated that it intends to continue its use of Flock ALPR and has a pending informational session scheduled for its city council. The City of Campbell is the lone city in the county that has been using an ALPR vendor other than Flock. In the greater Bay Area region, where Flock is similarly the predominant ALPR vendor, notably, the cities of San Francisco, Oakland, Richmond, Berkeley and East Palo Alto have recently approved the continued use of Flock ALPR, while Santa Cruz has discontinued use. Menlo Park, Atherton, and Redwood City continue to use Flock ALPR uninterrupted. Nationwide, nearly 6000 law enforcement agencies in 49 states currently use Flock ALPR cameras, including more than 300 law enforcement agencies in California. In total, fewer than 70 agencies (about 1% of user agencies) nationwide have discontinued their use of Flock (for any reason) since 2025, with fewer than 10 of those in California (about 3% of CA user agencies). which it shares, meet or exceed industry standards, the IPA will also assess PAPD’s internal policies and procedures with an eye toward areas where it may be able to do even better. FISCAL/RESOURCE IMPACT 13 ENVIRONMENTAL REVIEW ATTACHMENTS APPROVED BY: 13 City Council, April 3, 2023, Item #11, SR #2301-0741, Attachment A, p.68 Sections 6.2 and 6.3 of Exhibit J in Contract S23187316 between the City of Palo Alto and Flock Group, Inc.; https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=82232&dbid=0&repo=PaloAlto Surveillance Use Policy for fixed Automated License Plate Recognition ALPR) Technology In accordance with Palo Alto Municipal Code Section PAMC 2.30.680(d), the Surveillance Use Policy for the Police Department’s use of fixed ALPR technology is as follows: 1. Intended Purpose. The technology is used by the Palo Alto Police Department to convert data associated with vehicle license plates and vehicle descriptions for official law enforcement purposes, including but not limited to identifying stolen or wanted vehicles, stolen license plates and missing persons, suspect interdiction and stolen property recovery. 2. Authorized Uses. Department personnel may only access and use the ALPR system for official and legitimate law enforcement purposes consistent with this Policy. The following uses of the ALPR system are specifically prohibited: a. Harassment or Intimidation: It is a violation of this Policy to use the ALPR system to harass and/or intimidate any individual or group. b. Personal Use: It is a violation of this Policy to use the ALPR system or associated scan files or hot lists for any personal purpose. c. First Amendment Rights. It is a violation of this policy to use the LPR system or associated scan files or hot lists for the purpose or known effect of infringing upon First Amendment rights of any person. d. Invasion of Privacy: Except when done pursuant to a court order such as a search warrant, is a violation of this Policy to utilize the ALPR to record license plates except those of vehicles that are exposed to public view (e.g., vehicles on a public road or street, or that are on private property but whose license plate(s) are visible from a public road, street, or a place to which members of the public have access, such as the parking lot of a shop or other business establishment). 3. Information Collected. A fixed ALPR system captures the date, time, location, license plate (state, partial, paper, and no plate), and vehicle characteristics (make, model, type, and color) of passing vehicles. using the Palo Alto Police Department’s ALPR’s system and the vendor’s vehicle identification technology. 4. Safeguards. All data will be closely safeguarded and protected by both procedural and technological means. The Palo Alto Police Department will observe the following safeguards regarding access to and use of stored data (Civil Code § 1798.90.51; Civil Code § 1798.90.53): a. All ALPR data shall be accessible only through a login/password-protected system capable of documenting all access of information by name, date, and time. City Council Approved: April 3, 2023 b. Persons approved to access ALPR data under this policy are permitted to access the data for legitimate law enforcement purposes only, such as when the data relate to a specific criminal investigation c. Such ALPR data may only be released to other authorized and verified local enforcement officials and agencies for legitimate law enforcement purposes. d. Every ALPR system inquiry must be documented by either the associated case number or incident number, and lawful reason for the inquiry. 5. Retention. The City’s ALPR vendor, Flock Safety, will store the data (data hosting) and ensure proper maintenance and security of data stored in their data centers. Flock Safety will purge the data 30 days after collection; however, this will not preclude Palo Alto Police Department from maintaining any relevant vehicle data obtained from the system after that period if it has become, or it is reasonable to believe it will become, evidence in a specific criminal investigation or is subject to a discovery request or other lawful action to produce records. In those circumstances the applicable data should be downloaded from the server onto portable media and booked into evidence. Information gathered or collected, and records retained by Flock Safety cameras will not be sold, accessed, or used for any purpose other than legitimate law enforcement or public safety purposes. 6. Access by non-City Entities. The ALPR data may be shared only with other local law enforcement or prosecutorial agencies for official law enforcement purposes or as otherwise required by law, and as provided below: a. Requests i. A law enforcement agency may make a written request for specific data, including the name of the agency and the intended official law enforcement purpose for access ii. The request shall be reviewed by the Chief of Police or the authorized designee and approved before access is granted iii. The approved request is retained on file iv. Requests for ALPR data by non-law enforcement or non-prosecutorial agencies will be processed by the Department’s custodian of records and fulfilled only as required by law. b. Memorandaphilip of Understanding i. Access to searchable data by other local law enforcement agencies shall only be granted pursuant to an MOU with that specific agency ii. Such MOU will provide that access will only be used for legitimate law enforcement or public safety purposes c. The Chief of Police or the authorized designee will consider the California Values Act (Government Code § 7282.5; Government Code § 7284.2 et seq), before approving the access to ALPR data. The Palo Alto Police Department does not permit the sharing of ALPR data gathered by the City or its contractors/subcontractors for purpose of federal immigration enforcement. City Council Approved: April 3, 2023 7. Compliance Procedures. The Investigative Services Captain (or other police administrator as designated by the Police Chief) shall be responsible for compliance with the requirements of Civil Code § 1798.90.5 et seq. This includes, but is not limited to Civil Code § 1798.90.51; Civil Code § 1798.90.53): a. Only properly trained sworn officers, crime analysts, and police staff are allowed access to the ALPR system or to collect ALPR information. b. Ensuring that training requirements are completed for authorized users. c. ALPR system monitoring to ensure the security of the information and compliance with applicable privacy laws. d. Ensuring that procedures are followed for system operators and to maintain records of in compliance with Civil Code § 1798.90.52. e. The title and name of the current designee in overseeing the ALPR operation is maintained. Continually working with the Custodian of Records on the retention and destruction of ALPR data as required. f. Ensuring this policy and related procedures are conspicuously posted on the Department’s dedicated ALPR website. It is the responsibility of the Investigative Services Captain (or other police administrator as designated by the Police Chief) to ensure that an audit is conducted of ALPR detection inquiries at least once during each calendar year. The Department will audit a sampling of the ALPR system utilization from the prior 12-month period to verify proper use in accordance with the above authorized uses. The audit shall randomly select at least 10 detection browsing inquiries conducted by department employees during the preceding six-month period and determine if each inquiry meets the requirements established by policy. This audit shall take the form of an internal Department memorandum to the Chief of Police. The memorandum shall include any data errors found so that such errors can be corrected. After review by the Chief of Police, the memorandum and any associated documentation shall be filed and retained by the Department. City Council Approved: April 3, 2023 From:Fritz Koehler To:Council, City Subject:PA Study Session on Flock ALPR Technology (6/1/26)-- Public Comment Date:Monday, June 1, 2026 11:14:59 AM Attachments:PA Council Mtg (6-1-2026)-FK Letter.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Please see attached. Regards, Fritz This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report Powered by Mimecast June 1, 2026 Re: Flock Contract and Data Partnership- Caveat Emptor (Buyer Beware) Dear Mayor, City Council members, City Manager, City Attorney and Chief of Police, For over 30 years, my wife and I have enjoyed living in Palo Alto and also spending time in other communities surrounding Palo Alto. I’m a local attorney with many years of experience negotiating SaaS contracts similar to the one that the City has in place with Flock, and as a concerned Palo Alto resident, I feel compelled to make you aware of some serious risks and issues with continuing the City’s existing contractual relationship with Flock Group. Before I do that, however, please be advised that I do not legally represent the City, nor am I providing legal advice to the City. I would strongly encourage the City to seek separate legal advice with respect to the issues raised in this letter. Good Contract and Policy Not a Cure-All. In order to much better protect the City, its residents and other constituents, there are a number of provisions in the Flock contract that could be improved, including by better classifying and clarifying the different types of data involved with the Flock platform and services (for instance, data types such as aggregated data, derived data, inference data, metadata and training data) and each party’s associated rights and obligations with respect to each such data type, in order to better address data privacy and protection, security and liability issues. In addition, while the police department's internal compliance with the City’s “Surveillance Use Policy for Fixed Automated License Plate Recognition (ALPR) Technology” is important, Flock is not subject to that policy and there do not appear to be any policy flowdown provisions in the City’s Flock contract. The “Network Lookup” incident is a good example of how a policy that is only inward looking does not really provide the City with much protection for something like the Flock system, including protections such as a contractual right to request meaningful audits or written compliance certifications. In fact, Flock now has its own Customer Data Policy which likely conflicts or is inconsistent with the City’s Flock contract and its ALPR policy. Regardless of the actual terms of the contract, the City’s policy or Flock’s new Customer Data Policy, my biggest concern is with Flock itself and the high risk and potential liability that continuing to engage with Flock poses to the City due to Flock’s widespread poor data handling and protection practices, lack of customer transparency and overall untrustworthiness and arguable bad faith, which have all been widely reported by reputable sources and which the City itself has experienced. That risk and potential liability is likely to continue to increase over time given the real world business motivations and incentives that will drive Flock’s rapid growth goals and will likely result in questionable decision making and deficient business practices and internal controls. Flock Patent is Revealing. It’s hard to understand and evaluate that overall risk and Flock’s motivations without a good understanding of the Flock system itself. In order to do so, I would strongly encourage you to read Flock’s patent titled “Flock Patent: System and Method for Object Based Query of Video Content Captured by a Dynamic Surveillance Network“ (found at https://patentimages.storage.googleapis.com/77/9a/03/7b3b26499077d4/US11416545.pdf), which provides a good overview of how its system functions at the data type, footage and component level to surveil object types (including humans) and then store data and related footage. You will see that, from the start, the Flock system was intended to cover and surveil much more than just ALPRs. Flock has continued to add new services, features and compatible hardware devices (including drones and facial recognition) to its overall suite of offerings, in order to rapidly grow its business, meet its investors’ lofty expectations and build out its vision of being a leader of the mass surveillance market. It is not clear how Falcon cameras could be used to support those additional services or features, or even used by a Flock system administrator in noncompliant ways by turning on additional services or features at the system level without the knowledge of the City, but it would be worth determining if the Falcon cameras could support more than Falcon-based services. Inherent Compliance and Mismanagement Risk. A major risk area to consider is whether Flock can ensure that its features and functionality are compliant and will remain compliant on an ongoing basis with all applicable laws and with the contractual and policy requirements for its more than 6,000 customers. Flock has clearly failed to put in place a sufficient compliance program in the past and it is unlikely to do much better in the future despite what Flock may say or promise. Regardless of what Flock may do, it will not be sufficient to protect the City, its residents and other constituents due to the massive scale of the Flock system. If you have yet to do so, I would strongly encourage you to read the detailed memo from the Attorney’s Office for the City of Berkeley dated April 2026 which, among other things, warns that Flock’s services and technology may be incapable of complying with contractual obligations and city, state and federal data sharing restrictions, and that a city as large as Berkeley has limited recourse against Flock if Flock were to continue to have compliance lapses and other serious data handling issues (see https://www.dailycal.org/news/city/leaked-city-attorney-memo-shows-berkeley-risks-potential-mill ion-dollar-lawsuits-if-council-renews-flock/article_2a5efc3e-4d33-4b2f-8683-0e1395642fe8.html ). As shown in Flock’s patent and as is customary for SaaS offerings, Flock’s system is collecting, parsing, storing and querying data on a massive scale and storing that unencrypted data in a large one-size fits all data lake which likely only uses role-based logic to segregate and partition the City’s data from other data. As designed, there are no reliable ways for the City to monitor, audit, prevent or otherwise protect itself from Flock’s system administrators or anyone else at Flock accessing and sharing any of the City’s data or footage with any third party, including a federal agency, without leaving an audit trail behind. In fact, a 2021 U.S. Department of Homeland Security policy mandates that ALPR operators leave no trace of ICE in audit logs except for logs available only to ICE. In addition, the owner or subject of data generally does not have a right to be notified when a so-called FISA warrant under the U.S. Foreign Intelligence Surveillance Act is issued by a court for that data. It has also been widely reported that Flock is vying for contracts with multiple federal agencies (including US Border Patrol and the FBI), and federal agencies with direct access to Flock’s system raise a host of potential compliance risks. It is naive to think that certain government agencies will not test the limits of Flock’s system controls that help protect the City’s data, or that those agencies (and other agencies such as the DOJ with which they work closely with) will now be more keen to pursue access to the data of City residents or the data of other California residents despite the limited protections provided by California SB 34 and SB 54. Incentive to Scale and Monetize Customer Data. Flock is incentivized to rapidly grow, expand its business offerings and create additional revenue streams. An obvious way that it can do that is to leverage its massive data lake, and comingle that data with other first party and third party data sets to provide a more comprehensive dossier of the individual being targeted. Despite what Flock and local law enforcement agencies may say, Falcon is focused on surveilling people at scale and it’s not just about license plates. One clear example is that Flock is rolling out a new service called "Flock Nova" which combines Flock data with public database information (such as court filings, business registrations and property records) to allow for easier searches to get more background information about a particular individual. In order to boost its business, Flock is clearly trying to become a data aggregator and one-stop shop for discovering potential culprits/targets and then doing a broad background search. Based on its most recent private funding round, it has been reported that Flock has a current valuation of over $8 billion. With that lofty valuation which is many multiples above current revenue, the expectation of its investors is that Flock will continue to rapidly grow its revenue. It can probably only do that by rapidly growing the massive amounts of its monetizable data, increasing data access across its customer base to justify higher fees, and increasing the size and composition of its customer base, including tapping into the federal government which is the most obvious customer large enough to meet Flock's revenue goals. However, Flock’s high valuation by its investors only makes sense by placing more value on the growing massive data lake that Flock is creating as opposed to the uncertain revenue stream that it will generate in the future. In other words, at its core, Flock’s business model and incentive structure are all about its data lake and how it can be monetized. When the primary driver of a multi-billion dollar technology company is data monetization, we have seen time and time again that compliance can become an afterthought, that compliance has not been prioritized due to other business needs, and that compliance lapses or neglect are just a cost of doing business. Thank you for your service to the Palo Alto community which I deeply appreciate. You have a tough decision in front of you, but I would encourage all of you to not continue to trust Flock as a business partner and to terminate the City’s relationship with Flock. Flock’s incentives point in the wrong direction, and that does not bode well for a steward of the City’s data despite the contractual and policy provisions which may provide a false sense of protection from an untrustworthy business partner. Sincerely, Fritz Koehler From:Monica Teicher To:Council, City Subject:Flock surveillance is a dangerous weapon being weilded against our community Date:Monday, June 1, 2026 12:29:21 AM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Palo Alto City Council, My name is Monica Teicher, and my family owns property in Palo Alto. Given our investment in the City, I think it's very important that I state my opinion on the Flock camera system that the City is currently using. It has been demonstrated that any type of surveillance that is used for "law enforcement" can be misused in the wrong hands. We have precedent in the City of Mountain View, where data captured in the system's database was accessed by organizations outside of MVPD, which was prohibited in their contract. There were several instances of data access that the MVPD was unaware of for several months. https://www.mountainview.gov/Home/Components/News/News/1203/284 Flock is not a trustworthy company, and their contract should be terminated as soon as possible. We know that they are making their information available to ICE for their enforcement, regardless of the contracts signed. The ACLU noted that they are on their way to creating a massive surveillance that will include video feed from their cameras that can be used to track people's movements in the future. https://www.aclu.org/news/privacy-technology/flock-roundup Information from the system can be used to squash dissent and hinder our First Amendment right to free speech. Palantir is also aggregating and analyzing data obtained from different sources to create a comprehensive surveillance picture that makes us unsafe in all sorts of ways. I don't want to add to the mix the capability of following our movements indiscriminately, given the abuses committed by this administration. I urge you to do the responsible thing and protect the right to privacy of your citizens and the community at large by terminating Flock System's contract and covering the cameras while they are being taken down. Thank you, Mónica This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report From:Hansel Aguilar To:Council, City Cc:Clerk, City Subject:Public Comment for the Record: Evidence-Based Considerations Regarding ALPR and the Expansion of Surveillance Technologies Date:Monday, June 1, 2026 12:02:30 AM Attachments:2026-05-31-Aguilar_Letter_Palo_Alto_Council_ALPR.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Mayor and Members of the City Council: Please accept the attached letter as public comment for the record in advance of any forthcoming agenda item concerning the City's ALPR program or the expansion of surveillance technologies. I have copied the City Clerk to ensure inclusion in the official public correspondence file. I am a Santa Clara County resident writing in my personal capacity. The letter offers evidence- based considerations drawn from the independent research literature, the recent experience of neighboring Bay Area jurisdictions, and my own background in civilian oversight of law enforcement. The full text and supporting citations are in the attachment, with the body of the letter also pasted below for ease of review. I am grateful for the Council's service and for the opportunity to contribute to this discussion. Respectfully, -- Hansel Alejandro Aguilar, PhD "To give anything less than your best is to sacrifice the gift" ---Steve Prefontaine This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report Hansel Alejandro Aguilar, Ph.D. Santa Clara County, California Page 1 of 7 May 31, 2026 Honorable Mayor and Members of the City Council City of Palo Alto 250 Hamilton Avenue Palo Alto, CA 94301 Re: Evidence-Based Considerations Regarding ALPR and the Expansion of Surveillance Technologies Dear Mayor Veenker and Councilmembers: I write as a Santa Clara County resident with nearly fifteen years of experience in civilian oversight of law enforcement across multiple jurisdictions. I also write as a former law enforcement officer. I most recently served as the Director of Police Accountability for the City of Berkeley, and I hold a Ph.D. in sociology, with academic and practical focus on transnationalism, human rights, civil rights, and public accountability. I am writing in my personal capacity as a concerned member of the regional community; my professional affiliations are provided solely for identification. I offer this letter respectfully and not as a critique of the Palo Alto Police Department or its dedicated personnel. The issues raised here are common across jurisdictions and reflect a regional conversation that, over the past several months, has led Santa Cruz, Mountain View, Los Altos Hills, El Cerrito, and the Santa Clara County Board of Supervisors to reassess, suspend, terminate, or restrict their ALPR programs,1 and led the City of Berkeley and the City of Richmond to reassess and modify theirs.2 Palo Alto's own recent disclosure that hundreds of out-of-state agencies searched data from its cameras between July 2023 and October 2024, contrary to earlier public statements by city leaders3, places this Council squarely within that regional conversation. My purpose is to encourage the Council to ground its forthcoming decisions about ALPR, and about the broader expansion of surveillance technologies, in the best available empirical evidence and in durable civilian oversight infrastructure. The Independent Research Does Not Support the Vendor Narrative 1See, e.g., Mass surveillance fears push Silicon Valley city to scrap automated license plate readers, Press Democrat (Feb. 25, 2026); Los Altos Hills to remove ALPR cameras, Los Altos Town Crier (Jan. 28, 2026); California City Shuts Down Surveillance Cameras After Feds Accessed Data (Feb. 4, 2026) (discussing Mountain View, Los Altos Hills, Santa Cruz). The Santa Clara County Board of Supervisors voted Feb. 24, 2026 to prohibit the County Sheriff’s Office from contracting with Flock Safety for ALPR cameras in contract cities includin g Cupertino, Saratoga, and Los Altos Hills. See Palo Alto looks to audit Flock license plate cameras after breaches in other cities, Palo Alto Online (Mar. 6, 2026). Berkeley and Richmond ultimately opted for modified continuations of their ALPR programs rather than outright termination; both outcomes are discussed in the next footnote. 2Berkeley and Richmond reassessed but did not terminate. In Berkeley, the City Council voted 8–1 on May 7, 2026 to reject a proposed $2 million expansion that would have added drones, additional cameras, and investigative software, while narrowly approving a one-year extension of the existing 52-camera ALPR contract at a cost of up to $200,000. The vote followed the leak, publicly reported days before the meeting, of an April 24, 2026 confidential City Attorney memorandum warning that contracting with Flock carries legal risks the city’s own contrac tual protections cannot entirely fix. See Flock plate readers to stay; Berkeley nixes surveillance expansion, Berkeleyside (May 8, 2026), https://www.berkeleyside.org/2026/05/08/flock-safety-berkeley-surveillance-cameras-drones-nova-community-video-streams. In Richmond, Police Chief Timothy Simmons deactivated the ALPR system in late 2025 after discovering that Flock’s “national lookup” feature had rendered Richmond’s data accessible to outside agencies in violation of city policy and California law. See Richmond police chief shuts down license plate readers after discovering data was searchable, Richmondside (December 09, 2025), https://richmondside.org/2025/12/09/richmond-license- plate-reader-data-breach/; after several months of public debate, the City Council voted 4–3 on March 17, 2026 to reinstate the cameras through December 31, 2026 and directed the City Attorney to negotiate stronger data-sharing protections. See Richmond’s Flock license plate readers will be turned back on through 2026, Richmondside (Mar. 18, 2026), https://richmondside.org/2026/03/18/richmond-flock-cameras-license-plate- readers-on/; Richmond City Council extends Flock license plate reader contract amid privacy concerns, Local News Matters (Mar. 18, 2026). 3 Palo Alto license plate data searched by hundreds of out-of-state agencies, San José Spotlight / Palo Alto Weekly (April 27, 2026), https://sanjosespotlight.com/palo-alto-license-plate-data-searched-by-hundreds-of-out-of-state-agencies/ Hansel Alejandro Aguilar, Ph.D. Santa Clara County, California Page 2 of 7 ALPR vendors routinely describe their systems as engines of crime prevention and reduction. The independent research literature is markedly more cautious. The most current and comprehensive review, published last year in the Cambridge Journal of Evidence-Based Policing by Cynthia Lum, Christopher Koper, Hyunji Lee, Daniel Nagin, and Lawrence Sherman (several of the leading scholars in policing research), concludes that, after more than four decades of research on police technologies, “it is not clear that technologies in policing have made police more effective or have helped community members realize their expectations of the police.”4 As to ALPRs specifically, the authors find that the methodologically rigorous evaluations are “either equivocal or show limited effects of ALPRs on crime outcomes, even when conducted in very realistic contexts,” and that “the jury is still out on whether ALPRs are more effective in achieving public safety goals.”5 A central insight of this body of work is that ALPRs are not interventions in themselves. They are tools whose effect depends on the organizational strategy in which they are embedded. As the authors put it, “ALPR is just the scalpel, not the surgeon.”6 A national survey of agencies deploying ALPRs found that 59% provided officers complete discretion over how ALPR units were used, with no strategic guidance, and only 5% reported “almost always” providing such guidance.7 Absent targeted deployment, tracking, and assessment grounded in problem analysis, expensive new technology tends to reinforce existing practice rather than improve outcomes. A Careful Look at the Local Evidentiary Basis The Palo Alto Police Department's public materials8 describe ALPR as a tool that has produced "investigative success stories" and increases in recovered stolen vehicles. I do not question the sincerity of those attributions. I would, however, respectfully encourage the Council to scrutinize the analytic basis before authorizing further contract action or expansion. Two considerations: • Property crime trends across the Bay Area have moved in similar directions across jurisdictions with and without ALPR over this period. Drawing causal conclusions from pre/post comparisons in a single jurisdiction, without a comparison group or counterfactual analysis, is precisely the methodological problem flagged by the Lum et al. review and by the underlying randomized and quasi-experimental studies it summarizes.9 • The most relevant local counterfactual is instructive. Los Altos Hills, which deployed approximately 31 Flock cameras beginning in 2021 at a per-capita density far greater than that of Palo Alto, publicly concluded in January 2026 that despite a similar burglary decline, the ALPR system was not what produced it. Council members there explicitly identified other factors as more likely explanations and voted to terminate the contract.10 4Cynthia Lum, Christopher S. Koper, Hyunji Lee, Daniel S. Nagin & Lawrence Sherman, Measuring the Cost-Effectiveness of New Technologies in Policing: The Case of Automatic License Plate Readers (ALPR), 9 Cambridge J. Evidence-Based Policing, art. 4 (2025), at 2, https://doi.org/10.1007/s41887-025-00099-y. 5Id. at 6. 6Id. at 11. 7Cynthia Lum, Christopher S. Koper, James J. Willis, Stephen Happeny, Heather Vovak & Julie Nichols, The Rapid Diffusion of License Plate Readers in U.S. Law Enforcement Agencies, 42 Policing: An Int’l J. 376 (2019), discussed in Lum et al. (2025), at 13. 8 City of Palo Alto, Automated License Plate Recognition (ALPR), https://www.paloalto.gov/Departments/Police/Public-Information- Portal/Automated-License-Plate-Recognition-ALPR. 9Lum et al. (2025), at 6–8, reviewing Lum et al. (2011); Koper, Taylor & Woods (2013); Koper et al. (2022); Ozer (2016); Wheeler & Phillips (2018), among others. 10Los Altos Hills to remove ALPR cameras, Los Altos Town Crier (Jan. 28, 2026), https://www.losaltosonline.com/news/los-altos-hills-to-remove- alpr-cameras/article_59f90aa8-14c1-4309-9f7f-12d16c649d9e.html (noting Los Altos Hills had 31 deployed cameras and that the burglary decline was attributed by council members to factors other than ALPR). Hansel Alejandro Aguilar, Ph.D. Santa Clara County, California Page 3 of 7 ALPR may well have genuine investigative utility. The narrower point is that the strength of the causal public-safety claim being made for ALPR in Palo Alto warrants more rigorous analytic support than anecdotal success stories alone provide. A Distinct Concern: Federal Access to Locally Collected Data The empirical questions above would warrant caution on their own. A second dimension of this discussion has grown sharper over recent months, and I want to raise it plainly. The practical risk is that ALPR data collected in Palo Alto becomes available to federal agencies through technical and procedural pathways that California law prohibits but that the technology has repeatedly demonstrated vulnerabilities that local contractual safeguards have not fully prevented. I write this in part as someone whose own life informs the way I think about this risk. I came to this country from Honduras, and I have spent the bulk of my professional career on the civilian-oversight side of law enforcement. I raise that biographical detail not to elicit sympathy but because the people most directly exposed to the downstream consequences of a leaky surveillance network rarely sit on city councils, and discussions like this one are better when at least one such voice is in the record. The pattern is no longer speculative. Within the past several months alone: • Palo Alto itself was affected. Public records obtained by the Palo Alto Weekly and published April 27, 202611 confirmed that Palo Alto's ALPR cameras were part of Flock's nationwide searchable dataset between July 2023 and October 2024 without the city's knowledge, during which agencies from nearly every state, including federal agencies such as the Bureau of Alcohol, Tobacco and Firearms and the National Park Service, performed searches within that nationwide network. The Police Chief's position is that the searches were system-wide rather than targeted at Palo Alto's data specifically, and that Flock confirmed no Palo Alto camera data was actually returned to those agencies. I do not contest that account. The structural point is narrower: city leaders had publicly stated in prior meetings that out-of-state agencies could not access Palo Alto's data, the city was unaware the nationwide lookup feature had been enabled on its system, and the discovery came only through investigative journalism and a Public Records Act request, not through customer-side audits. • A public letter from U.S. Senator Ron Wyden dated October 16, 2025 confirmed, based on direct disclosures by Flock to his oversight staff, that U.S. Customs and Border Protection, Homeland Security Investigations (a division of Immigration and Customs Enforcement), the U.S. Secret Service, and the Naval Criminal Investigative Service had all been given pilot access to Flock’s nationwide network, and that CBP and HSI conducted approximately 200 and 175 searches respectively. Flock also acknowledged to Senator Wyden’s office that it had previously told state and local law enforcement customers, inaccurately, that it had no relationship with the Department of Homeland Security.12 • Richmond deactivated its ALPR system in late 2025 after the police chief discovered the same “national lookup” feature had been silently enabled, in violation of Richmond policy and California law. The cameras were reinstated in March 2026 only after months of public debate and on the condition that the city negotiate stronger contractual protections. 11 Palo Alto license plate data searched by hundreds of out-of-state agencies, San José Spotlight / Palo Alto Weekly (April 27, 2026), https://sanjosespotlight.com/palo-alto-license-plate-data-searched-by-hundreds-of-out-of-state-agencies/ 12Letter from Sen. Ron Wyden to Garrett Langley, CEO, Flock Group, Inc. (Oct. 16, 2025), https://www.wyden.senate.gov/imo/media/doc/wyden_letter_to_flock.pdf; see also Joseph Cox, ICE, Secret Service, Navy All Had Access to Flock’s Nationwide Network of Cameras, 404 Media (Oct. 17, 2025), https://www.404media.co/ice-secret-service-navy-all-had-access-to-flocks- nationwide-network-of-cameras/. The Wyden letter states that Flock confirmed to his office in September 2025 the pilot access to CBP, HSI, the Secret Service, and the Naval Criminal Investigative Service, and that the company had acknowledged “internal miscommunication” resulted in customers being “inaccurately informed that Flock did not have any relationship with DHS.” Hansel Alejandro Aguilar, Ph.D. Santa Clara County, California Page 4 of 7 • Mountain View disabled its entire ALPR fleet after discovering that Flock had configured one of its cameras to a “nationwide” setting without authorization, and that multiple federal agencies (including the Bureau of Alcohol, Tobacco, Firearms and Explosives, the GSA Office of Inspector General, and personnel at multiple military installations) had accessed city data for approximately seventeen months.13 • In Berkeley, a confidential City Attorney memorandum that leaked on the eve of the May 7, 2026 City Council vote warned that contracting with Flock may carry legal exposure that contractual safeguards alone cannot fully resolve, including potential Fourth Amendment, California sanctuary-law, and SB 34 liability, even where no data is in fact shared.14 • On May 18, 2026, 404 Media reported on Federal Bureau of Investigation procurement records seeking up to $36 million for nationwide access to license plate reader data, with Flock Safety and Motorola Solutions identified as the primary vendors positioned to provide the requested scope. The FBI Statement of Work, in its own words, seeks a “diverse and reliable range of collections across the United States.”15 I appreciate that the Palo Alto Police Department has affirmed in writing that it does not share data with federal or out-of-state agencies and that its policy prohibits immigration-enforcement use. I have no reason to doubt the sincerity of that commitment. The issue raised by the pattern above is not commitment. It is capability. Mountain View had the same commitment. Richmond had the same commitment. Berkeley’s own attorneys concluded, after careful review, that contractual commitments alone may not be sufficient to guarantee the result. The human stakes of these infrastructure decisions are not abstract. On May 27, 2026, an Associated Press investigation reported16 that at least ten people in ICE detention have died by suicide since January 2025, with seven of those deaths occurring since October. The pace is the highest in the agency's history, and public health experts characterized the increase as evidence that the 50% expansion in the detained population has overwhelmed the system's mental health care and oversight capacity. I raise this not to assert a direct causal chain between any particular ALPR query and any particular detention or death, which the public record does not establish, but to name what the system that local ALPR data flows into is now producing. A city that contracts with a vendor whose product is woven into that enforcement infrastructure, even with strong local policy guardrails, is making a choice about whether to participate in a supply chain whose downstream consequences are now publicly documented. For residents whose families came to this country from places where state surveillance has been used as a tool of political control and family separation, this is not an abstract concern. It is the concern. Better-Evidenced Alternatives Exist 13California City Shuts Down Surveillance Cameras After Feds Accessed Data (Feb. 4, 2026), https://www.gblock.app/articles/california-flock- cameras-ice-data (Mountain View audit revealed federal access to city data from August to November 2024 via a Flock configuration the city had not authorized). 14Leaked city attorney memo shows Berkeley risks potential million-dollar lawsuits if council renews Flock contract, The Daily Californian (May 5, 2026), https://www.dailycal.org/news/city/leaked-city-attorney-memo-shows-berkeley-risks-potential-million-dollar-lawsuits-if-council- renews-flock/article_2a5efc3e-4d33-4b2f-8683-0e1395642fe8.html (reporting that the April 24, 2026 City Attorney memorandum identified Fourth Amendment, California sanctuary-law, and SB 34 exposure). 15Joseph Cox, The FBI Wants to Buy Nationwide Access to License Plate Readers, 404 Media (May 18, 2026), https://www.404media.co/the-fbi- wants-to-buy-nationwide-access-to-license-plate-readers/ (reporting up to $36 million in proposed FBI procurement and identifying Flock and Motorola as the only realistic vendors capable of providing the requested scope; quotation in body is from the FBI Statement of Work as reported). 16 AP, ICE detainees dying by suicide at 'alarming' rate, AP investigation finds, PBS NewsHour (May 27, 2026), https://www.pbs.org/newshour/nation/ice-detainees-dying-by-suicide-at-alarming-rate-ap-investigation-finds. Hansel Alejandro Aguilar, Ph.D. Santa Clara County, California Page 5 of 7 The George Mason University Center for Evidence-Based Crime Policy maintains an Evidence-Based Policing Matrix that catalogs interventions with rigorous empirical support across crime types.17 For the property-crime concerns most often cited to justify ALPR expansion, the interventions with the strongest evidence base are problem-oriented policing tailored to specific theft patterns, hot-spots policing, Crime Prevention Through Environmental Design (CPTED), and target hardening. None of these requires suspicionless mass data collection on uninvolved residents. Problem-oriented policing, commonly structured through the SARA framework (Scan, Analyze, Respond, Assess), begins with specific analytic questions. What is actually being stolen: catalytic converters, packages, bicycles, items from vehicles? When and where do incidents cluster? Who is offending: local repeat offenders, organized crews, transient suspects? What environmental conditions enable the offenses, such as lighting, sight lines, access routes, and unsecured property? What is the victim profile? Once these questions are answered, the response usually suggests itself, and it is rarely “buy more surveillance.” For package theft it may be locker installations and porch-pirate awareness; for car burglaries, targeted patrols at hot times and places combined with “lock-it, hide-it, keep-it” campaigns; for catalytic-converter theft, etching programs and scrap-yard regulations. I would also respectfully suggest that the framing under which surveillance debates often unfold, the assumption that “public safety must inevitably trade against privacy,” concedes too much. That premise is one the surveillance-technology industry relies on; the better-evidenced alternatives above do not require that trade-off. Three Recommendations In that spirit, I respectfully offer three recommendations for the Council’s consideration: 1. Require Analytic Justification Before Any Expansion. Before the Council takes up any expansion of ALPR or the adoption of additional surveillance technologies (integrated data-analytics platforms, drones, fixed cameras, or otherwise), I would urge that the Police Department first be asked to articulate, in analytic detail: • the specific crime trends and patterns of concern, disaggregated well beyond high-level Part I categories (type, time, place, victim profile, suspected offender characteristics, and modus operandi); • the interventions, technological and otherwise, that have already been attempted to address those problems, and what was learned from them; and • the case for why a proposed new technology, evaluated against alternatives with stronger evidence bases, is the most appropriate response. The burden of justification should rest on the proposed solution, whether that solution is ALPR renewal, an analytic platform, or anything else. Communities are too often asked to evaluate specific solutions without ever being shown the underlying analysis. I do not assume that is what is occurring here. The structural way to prevent it, though, is to insist on the analytic work up front. The next two recommendations are structural complements designed to ensure that the analytic discipline above becomes a durable feature of City practice rather than an episodic ask. 17George Mason University, Center for Evidence-Based Crime Policy, Evidence-Based Policing Matrix, https://cebcp.org/evidence-based- policing/the-matrix/. Hansel Alejandro Aguilar, Ph.D. Santa Clara County, California Page 6 of 7 2. Use Your Existing Surveillance Technology Ordinance Meaningfully. Palo Alto already has a Surveillance Technology Ordinance, codified at Palo Alto Municipal Code §§ 2.30.620 to 2.30.690, the Surveillance and Privacy Protection Ordinance adopted in 2018. The ordinance requires Council approval for the acquisition, expansion, or material repurposing of any surveillance technology, an impact assessment, and an Annual Surveillance Report. The infrastructure for thoughtful, transparent surveillance governance already exists in this city's code. The question is whether it is being used. The most recent publicly accessible Surveillance Technology Report I have been able to locate is the September 21, 2020 staff report covering Fiscal Years 2019 and 202018, which predates Palo Alto's adoption of fixed ALPR in April 2023. I have not been able to locate any subsequent Annual Surveillance Report covering the period during which the ALPR program has been operational, including the period during which the nationwide lookup feature was active on the city's cameras. The OIR audit being commissioned should determine, as a threshold question, whether the Annual Surveillance Reports required under the ordinance have been produced for ALPR each fiscal year since adoption and where the public can access them. If they have not, the Council should treat that as a compliance question, not only a process gap. 3. Codify and Expand Civilian Oversight Capacity Beyond the Current Contracted Auditor. Palo Alto has maintained an independent police auditing function through contract with OIR Group since 200619, and the Council is now expanding OIR Group's scope to include an operational assessment of Flock's policies and procedures around security, transparency, sharing compliance, and reporting of system features and changes. This is a meaningful step. I would respectfully encourage two further moves. First, the audit's scope should be expanded beyond operational assessment to address what customer-side audits structurally cannot detect: vendor-level federal access, including through pilot programs of the kind Senator Wyden documented, and the categories of access that operate above the customer dashboard. The audit should also confirm whether the Annual Surveillance Reports required under PAMC § 2.30.6 70 have been produced and made publicly accessible. Second, the City's civilian oversight architecture should not depend on contractual renewal. While Palo Alto has been well-served by OIR Group for nearly two decades, the permanency and strength of a true civilian oversight system requires codification in the municipal code, not a contractual relationship that any future Council could decline to renew. A standing civilian oversight body, structured consistent with NACOLE principles, 20 would provide the institutional continuity and proactive engagement capacity that contract auditors performing periodic reviews cannot fully replicate. These are precisely the kinds of structural surveillance questions a robust and well- supported oversight system could engage with proactively, rather than addressing in piecemeal fashion as issues surface. Bay Area examples include the City of San Jose Office of the Independent Police Auditor, the City of Berkeley Police Accountability Board and Office of the Director of Police Accountability, and the City of Richmond Community Police Review Commission.21 Closing 18 City of Palo Alto, Surveillance Technology Reports for Fiscal Years 2019 and 2020, City Manager Report ID #11268 (Sept. 21, 2020), cityofpaloalto.org/files/assets/public/v/1/agendas-minutes-reports/reports/city-manager-reports-cmrs/year-archive/2020-2/id- 11268.pdf?t=64156.82](https://www.cityofpaloalto.org/files/assets/public/v/1/agendas-minutes-reports/reports/city-manager-reports- cmrs/year-archive/2020-2/id-11268.pdf?t=64156.82) 19 City of Palo Alto Independent Police Auditor, https://www.paloalto.gov/Departments/Police/Accountability/Independent-Police-Auditor 20National Association for Civilian Oversight of Law Enforcement, Thirteen Principles for Effective Oversight, https://www.nacole.org/principles. 21For Bay Area models, see City of San Jose, Office of the Independent Police Auditor, established by San Jose City Charter § 809 (adopted 1996), https://www.sanjoseca.gov/your-government/appointees/independent-police-auditor; City of Berkeley, Police Accountability Board and Office of the Director of Police Accountability, established by Measure II (Nov. 2020); City of Richmond, Community Police Review Commission, governed by Richmond Ordinances Nos. 15-84 N.S., 11-85 N.S., 3-16 N.S., 5-16 N.S., 02-19 N.S., 05-19 N.S., and 29-20 N.S., https://www.ci.richmond.ca.us/81/Community-Police-Review-Commission.. Hansel Alejandro Aguilar, Ph.D. Santa Clara County, California Page 7 of 7 None of the above is offered as a critique of the dedication of Palo Alto police personnel or of the Council's commitment to community safety. I have raised similar concerns with neighboring jurisdictions in recent months, including the City of Los Altos, and I share them with this Council in the same spirit of constructive engagement. The hope here is that the most durable public-safety decisions are those grounded in the best available evidence and supported by structures that allow the community to participate meaningfully in the trade-offs involved. The current regional moment, with neighboring jurisdictions actively reassessing the same technology, offers Palo Alto a useful opportunity to set a thoughtful, evidence-based example. I am happy to make myself available as a resource to the Council, City staff, or the Police Department if that would be useful. Thank you for your service and for your consideration. In Community, Hansel Alejandro Aguilar, Ph.D. | Practitioner of Civilian Oversight of Law Enforcement & Researcher Vice Chair, Membership and Support Committee | NACOLE* * The views expressed are my own. Affiliations are provided for identification purposes only. From:Lisa B To:Council, City Subject:Study Session on Flock Automated License Plate Recognition Technology (June 1, 2026) Date:Sunday, May 31, 2026 10:58:45 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i To the City Council, I am a Palo Alto resident asking the city to stop using hardware and software from Flock Safety. I have read and appreciate the Staff Report (Report #:2605-6381). I respect the Palo Alto Police Department’s work protecting the property and safety of those who live, work, shop, and visit here. But their responsibility is broader: they must operate lawfully and legitimately, protecting not only property but our privacy and constitutional rights. Flock systems—especially the tracking database that can be accessed or hacked— not only put our rights and more at risk but erode trust in the PAPD; that erosion may even limit their ability to combat crime. I don’t feel safer with this technology; I feel less safe. I found no mention in the Staff Report of rigorous evidence on the cost-effectiveness of linked ALPRs. Randomized studies have been conducted and did not demonstrate clear, generalizable benefits. The report provides anecdotes of Flock assisting PAPD investigations; while those successes are welcome, PAPD had successes before Flock. A technology that helps in isolated incidents does not justify broad, ongoing collection of movement data that threatens civil liberties. The report also shows concrete risks. Flock data from Palo Alto was “unknowingly included” in a “Nationwide Lookup” searchable dataset for a period of time, and worse misuse has occurred in nearby communities—evidence that this technology endangers our rights. While I recognize tradeoffs, my choice is clear. We were well protected by PAPD before this technology. The risk of further problems with Flock is high, and the potential consequences are enormous. When our privacy and constitutional rights are not protected, we are less safe. Please cancel this contract. Sincerely, Lisa Bernstein This message needs your attention This is a personal email address. This is their first email to you. Mark Safe Report 3405 Kenneth Drive From:Trina Lundstrom To:Council, City Subject:Flock Has Not Earned Our Trust Date:Sunday, May 31, 2026 7:50:51 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear City Council members, I am a local neighbor who drives through Palo Alto frequently, and a former long-time resident. I write to express my grave concern over the deployment of Flock Automated License Plate Readers (ALPRs) in Palo Alto. We cannot trust this company. Flock has repeatedly failed to establish data security, has lied regarding third party access, and has not taken responsibility for the abuse of Flock data by its own employees. A Flock ALPR contract means that Palo Alto turns over ownership and control of its data to a private company which has demonstrated shocking arrogance and negligence with regard to sensitive information. That is why, in 2026 alone, 37 different localities have canceled their Flock contracts, including our neighbors in Mountain View and Los Altos Hills. I attended the Mountain View City Council meeting where the Police Chief reported the many instances where Flock did not meet its promises. Please make Palo Alto number 38. Respectfully, Trina W. Lundstrom This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report From:Sue Dinwiddie To:Council, City Subject:FLOCK Date:Sunday, May 31, 2026 6:30:56 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear City Council Members, We have been Palo Alto residents since 1963. We are writing because we are most concerned about the use of FLOCK surveillance systems. There are a number or reasons for our concern: 1. An audit of FLOCK systems in Illinois last August revealed that FLOCK had initiated an unauthorized “pilot program” that gave the U.S. Customs and Border Protection direct access to local license plate readers on Illinois roads allowing for surveillance of drivers. We want to end lock-ups of innocent people (including some citizens) not help implement more. 2. FLOCK has failed over and over to establish data security, has lied regarding third party access, and has not taken any responsibility for the abuse of FLOCK data by its employees. 3. Use of FLOCK in our town makes people less likely to participate in Protests - a first amendment right in our constitution. And an action we believe is more important now than ever before. We could list many more reasons, and although a few buglers have been apprehended thanks to FLOCK, we believe the negative aspects far out weigh the positive. Therefore, we strongly urge you to cover the cameras and cancel the contract. Respectfully, Ken and Sue Dinwiddie 543 Jackson Drive Palo Alto, CA 94303 From:Toni Moos To:Council, City Cc:Toni Moos Subject:Flock Has Lost Our Trust Date:Sunday, May 31, 2026 5:16:58 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear Mayor and Members of the Palo Alto City Council, I am a Santa Clara resident who frequently spends time in Palo Alto — for work and play. I am writing to voice my serious concerns about the use of Flock surveillance systems. The issue is whether Flock Safety has demonstrated that it is a trustworthy steward of sensitive surveillance data belonging to Palo Alto residents and those who visit and drive past Palo Alto. Nearby cities, including Mountain View and others, have already suspended or terminated their Flock programs after discovering unauthorized data-sharing practices involving outside agencies. Mountain View’s Police Chief publicly stated that he lost confidence in the vendor after learning that local data had been made searchable by outside agencies in ways the city had not authorized. (mountainview.gov) If any other city vendor — financial, technology, healthcare, or otherwise — had been found enabling unauthorized access to sensitive resident data, the City would not simply renew the contract anyway. Why does Flock get a pass? Palo Alto residents are being asked to trust this company with extraordinarily sensitive information about where we live, where we worship, where our children go to school, and how we move through daily life. That trust has not been earned. Recent reporting revealed that Flock employees accessed live and recorded surveillance feeds from locations including children’s swimming pools, gyms, playgrounds, schools, and a Jewish community center as part of "product demonstrations for prospective customers". Think about that carefully. A private surveillance company used footage involving children at recreational facilities and footage connected to a religious institution as sales material. Even if technically permissible under their internal policies, it reflects profoundly poor judgment and a disturbing corporate culture surrounding privacy and surveillance. Most parents would be horrified to learn that footage connected to children’s activities could be accessed and showcased by employees of a private vendor in this way. This is exactly why trust matters. At the same time, reports indicate the FBI is seeking nationwide, near real-time access to commercial ALPR databases capable of tracking vehicles across the country. Flock is one of those vendors. (Slashdot News) Residents were told these systems would be limited local crime-fighting tools. Instead, they are becoming part of broader surveillance networks accessible far beyond local police departments. ALPR systems create searchable records of people’s movements, associations, and routines. Residents should not have to wonder: who can access their data, whether outside agencies are searching it, which we know they are... whether private employees are viewing sensitive footage, or whether these systems will continue expanding beyond what the public originally understood. Public safety matters deeply. But so do civil liberties, transparency, and accountability. Palo Alto should hold Flock to the same standards of honesty, compliance, and ethical conduct that it would demand from any other contractor doing business with the City. Sincerely, Toni Moos On behalf of Los Altos for Representation and Equity (LARE) From:Brian Jones To:Council, City Subject:Comment for ALPR Study Session, 6/1/26: We are the Product Date:Sunday, May 31, 2026 5:11:29 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Esteemed Council, An analysis of publicly available data on the Flock Safety corporation makes it clear that their business model has much in common with many recent tech firms: We are the product. Flock has raised around $858M over 9 investment rounds since 2017. The final round, not included in the previous link, was rumored to be $200M in April of 2026. The inexorable math of venture funding puts a lot of pressure on Flock. The most recent round values the company at around $8.2B. When investors put in so much money at such a high valuation, they expect a significant return. Can Flock's current business model support that valuation? Flock is believed to have more than 80,000 cameras nationwide; some sources say closer to 90,000. If we assume 80,000, and assume an annual revenue per camera of around $2500 each, that makes $200M in revenue. That implies a price-to-sales ratio of 41x -- much higher than the typical software ratio of 5x to 15x, and massively higher than the 0.5x to 2.5x expected for traditional companies, Such a high ratio can only mean that the investors expect sales to increase by 3- to 8-fold. And because they are a mature startup, already 9 years old, investors are going to expect that increase quickly. Another way to look at it is to consider their burn rate. The previous round, in March 2025, was for $275M. The last round, 13 months later, was $200M. That implies that they burned close to $275M in a year; let's be conservative and call it $250M. As we saw above, their revenue appears to be around $200M. That means that their sales are only covering about half their annual costs. They need to roughly double their revenue just to get to break-even, where their costs equal their revenues. All of this means that Flock needs to boost their revenues quickly. Reports suggest they already have around a quarter of US police departments; this is probably overweighted with large departments. So the potential revenue they can get by selling more ALPRs is limited to a best case of around 2x. This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report they need to find an additional $350M-$1.4B of revenue, probably in the next 18 months or so. How could they do that? The federal government is the most obvious customer large enough to put a substantial dent in that amount. Flock's new Condor cameras are designed to track people and are capable of performing facial recognition. While current contracts appear to prevent sale of data, Flock will clearly be under intense pressure to find revenue somewhere. In any case, it is clear that Flock's investors think it is a business like Facebook: it's not so much the customer revenue that makes it valuable, as it is the value of the data collected. It's the only way their investment makes sense. Thank you for your consideration, -Brian Jones From:Austin Marshall To:Council, City Cc:Clerk, City Subject:Public Comment for June 1, 2026 City Council Meeting -- Item 2, Flock Study Session Date:Sunday, May 31, 2026 4:13:54 PM Attachments:Public Comment - Austin M - Palo Alto City Council - Item 2 Flock Study Session - 2026-05-31.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear City Clerk, Please find attached my written public comment for the Palo Alto City Council’s regular meeting on June 1, 2026. This comment concerns Item 2, “Study Session on Flock Automated License Plate Recognition Technology; CEQA status – categorically exempt.” regarding the City's ongoing relationship with Flock Group Inc. DBA Flock Safety. Please include the attached letter in the public record for the meeting and distribute it to the Mayor and City Council for their consideration in connection with Item 2. Thank you, Austin M. Safety Over Surveillance Palo Alto Coalition Indivisible Palo Alto Plus This message needs your attention This is a personal email address. This is their first mail to some recipients. Mark Safe Report Austin M. May 31, 2026 Palo Alto City Council City of Palo Alto 250 Hamilton Ave. Palo Alto, CA 94301 Re: Public Comment on Regular City Council Meeting, June 1 , 2026 — Item 2 , “Study Session on Flock Automated License Plate Recognition Technology; CEQA status – categorically exempt.” Dear Mayor and Members of the Palo Alto City Council: I am writing to provide public comment on Item 2 on the June 1 , 2026 regular City Council agenda, titled “Study Session on Flock Automated License Plate Recognition Technology; CEQA status – categorically exempt.” The item relates to a staff report on the City’s relationship with Flock Group Inc. DBA Flock Safety. Respectfully, the City of Palo Alto will be on the wrong side of history if it continues to maintain a relationship in any form with Flock Group Inc., and indeed the credibility and integrity of the City is at stake. Flock Group Inc. exposed sensitive data on Palo Alto residents and community members in the broader region to out -of-state and Federal agencies in violation of California SB 34 and SB 54 1. Of particular salience is the recent news reported by 404media 2 that the FBI is seeking a single vendor for a nationwide network of license plate readers of its own. The path to such contract is paved by Palo Alto tax dollars and the sensitive personal data of Palo Alto residents and passers by. A s every contract and continued use of the company’s product is an endorsement. Every data point collected by the company contributes to a proprietary nationwide dataset the company 1 Palo Alto license plate data searched by hundreds of out -of-state agencies 2 https://www.404media.co/the -fbi -wants-to-buy -nationwide-access-to-license-plate-readers/ uses to train machine learning models that serve as a competitive moat, and every dollar spent with the company extends the runway of a wildly unprofitable venture-backed startup desperate to provide a return for investors like Peter Thiel, who bolsters his wealth built on mass surveillance by cozying up to the MAGA administration 3. Palo Alto’s admirable policies and safeguards meant to protect its citizens and vulnerable populations will be undermined if Flock wins the contract as a Federally controlled and operated ALPR network will not be subject to the City’s ALPR policy or professional norm s. With the recent news of incoming ICE facilities in Gilroy 4 and Dublin5, devastating ICE and CBP mass enforcement activity in the region like we have seen in Minneapolis and other cities will have been enabled by Flock. For these reasons and more, I respectfully urge the City Council to uphold its values, reject AI mass surveillance, and move to cancel the contract with Flock Group Inc. Thank you for considering my public comment. I ask that this letter be included in the public record for the June 1 , 2026 regular City Council meeting and associated with Item 2. Sincerely, Austin M . Safety Over Surveillance Palo Alto Coalition Indivisible Palo Alto Plus 3 https://www.theguardian.com/us -news/2018/oct/23/silicon -valley-tech-firms -making -money -trump-anti - immigrant-agenda-report 4 https://sanjosespotlight.com/federal-detention-center -planned -in -south-county/ 5 https://www.kqed.org/news/12082440/advocates-urge-demolition -of -fci-dublin-raising-worries-it-could - become-ice-jail From:Elliot Margolies To:Council, City Cc:Elliot Margolies Subject:No to Flock Camera Surveillance Date:Sunday, May 31, 2026 4:01:33 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear City Council members, I am a Palo Alto resident and I am sharing my concerns about Flock (license plate reader) technology and surveillance usage in the hope that you will terminate any contracts with that company and disallow current usage. This surveillance makes me and many in our community feel less safe, and suppresses our rights of free speech. The data Flock collects has been used by Homeland Security in their ongoing efforts to deport immigrants. An investigation into unauthorized “side-door” access to Flock data uncovered more than 4,000 lookups conducted through local law enforcement portals at the behest of federal immigration officials. We know that Flock ALPRs have been used multiple times in other places to monitor dissent, including law enforcement agencies searching for key words: “no kings,” “Hands Off,” and, simply, “protest.” So far in 2026 alone, 37 different localities have canceled their Flock contracts, including our neighbors in Mountain View and Los Altos Hills. Respectfully, Elliot Margolies This message needs your attention This is a personal email address. Mark Safe Report Powered by Mimecast From:John VanHorne To:Council, City Subject:No Flock Date:Sunday, May 31, 2026 4:01:04 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear City Council members, I am a Palo Alto resident, and I write to express my grave concern over the deployment of Flock Automated License Plate Readers (ALPRs) in Palo Alto. We cannot trust this company. I have read in more than one news article that Flock has repeatedly failed to establish data security, has lied regarding third party access, and has not taken responsibility for the abuse of Flock data by its own employees. A Flock ALPR contract means that Palo Alto turns over ownership and control of its data to a private company which has demonstrated shocking arrogance and negligence with regard to sensitive information. That is why in 2026 alone, 37 different localities have canceled their Flock contracts, including our neighbors in Mountain View and Los Altos Hills. Please make Palo Alto number 38. Respectfully, John Van Horne 200 Fulton St. Palo Alto, CA 94301 This message needs your attention This is a personal email address. This is their first email to you. Mark Safe Report From:David Waksberg To:Council, City Subject:Cancel Palo Alto"s Contract With Flock Date:Sunday, May 31, 2026 2:49:35 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i May 29, 2026 Dear Mayor Veenker, Vice-Mayor Stone, and Council Members Burt, Lauing, Lu, Lythcott-Haims, and Reckdahl Thank you for your leadership and service to Palo Alto. I write to express my grave concern over the deployment of Flock Automated License Plate Readers (ALPRs) in Palo Alto. After a thorough review of the information available to us, I have concluded that these surveillance cameras threaten, and indeed, cause, more harm to Palo Altans and our neighbors than they help. I wish to briefly review the harms and risks we have uncovered, as well as the “false advertising” that exaggerates claims of benefit to Palo Alto. Flock ALPRs are a part of a network; indeed, Flock promotes the “network effect” as a selling point. But efforts by local jurisdictions to limit the use of data from their communities have proven ineffective. Thus, an assessment of Flock deployment in Palo Alto must include the potential that our data will be used or misused by others. This also means that as we review harms and potential harms, we are not accusing or even suggesting malfeasance on the part of Palo Alto personnel, but rather that we can become implicated in downstream harms from Palo Alto data. This message needs your attention This is a personal email address. This is their first email to you. Mark Safe Report Discriminatory Profiling Flock claims that ALPRs don’t discriminate. However, they have emerged as a useful instrument for racial profiling. Last year, law enforcement agencies performed hundreds of data searches across thousands of Flock deployments using “Roma” and “Gypsy” as key words. In 2023, in Oak Park, IL, 84% of drivers pulled over in Flock-generated traffic stops were Black. Black people comprise 19% of the population. That represents an INCREASE from the 53% the year before Flock ALPRs were deployed. In 2025, Marimar Martinez, a Montessori school teaching assistant and U.S. citizen, was shot five times by Border Patrol agents in Chicago. DHS (mis)used Flock data to support their claim that Martinez was a “domestic terrorist.” When analyzed, the data showed Martinez driving to Target for school supplies. In August 2020, Brittney Gilliam, an African-American woman, was taking her 6-year-old daughter, her 12-year-old sister, and her 14- and 17-year-old nieces to get their nails done in Aurora, CO. Gilliam’s car was swarmed by Aurora police officers with their guns drawn. Flock ALPRs had confused Gilliam’s license plate with that of a stolen motorcycle from another state. In addition to traumatizing Gilliam and the four children in her car, the incident resulted in a $1.9 million lawsuit settlement by the City of Aurora. Suppression of Dissent and Politicized Abuse of Data Historically, when surveillance methods have been deployed, they have almost always ended up being used to monitor and suppress dissent. Flock ALPRs have been used multiple times to monitor dissent, including law enforcement agencies searching for key words: “no kings,” “Hands Off,” and, simply, “protest.” Other searches of Flock data corresponded with May Day rallies, protests against Trump Administration DOGE cuts, and protests against immigration policies. In May, 2025, the Johnson County, Texas Sheriff’s office conducted a nationwide search of 83,000 Flock ALPR’s using the key words: “had an abortion, search for female.” Flock ALPRs Used to Hunt Immigrants An audit of Flock systems in Illinois last August revealed that Flock had quietly initiated an unauthorized "pilot program" that gave the U.S. Customs and Border Protection (CBP) direct access to local license plate readers on Illinois roads, allowing federal agents to surveil drivers. An investigation into unauthorized “side-door” access to Flock data uncovered more than 4,000 lookups conducted through local law enforcement portals at the behest of federal immigration officials. Because these were performed by other agencies on behalf of ICE, local authorities were not aware their data was being used to search for immigrants. Leaky Data: No Security, No Privacy Flock systems have been shown to be remarkably unsecure. After a Dunwoody, GA resident filed records requests for ALPR data, he was shocked to discover that Flock personnel were routinely logging in to spy Dunwoody residents. Flock employees watched live feeds from the local Jewish Community Center, including: A children's swimming pool A local playground and school property Private interior fitness studios In January of this year, more than 60 Flock cameras were discovered broadcasting their feeds to the open, unencrypted Internet. Anyone with a web browser could access these images. Last year, a Congressional investigation discovered that the login credentials for at least 35 distinct Flock law enforcement customer accounts had been stolen by hackers using "infostealer" malware. Active law enforcement credentials were found listed for sale on Russian-language cybercrime forums. Any criminal or foreign spy who purchased those credentials could use Flock's "National Lookup" feature to track the real-time movements of vehicles across all 49 states where Flock operates. Do ALPRs Reduce Crime? Flock bases its crime-reduction claim on anecdotes and cherry-picked statistics. It may be too early in the life-cycle of this technology to really know; thus far, the evidence is not encouraging: Flock’s claims of crime reduction do not hold up under scrutiny. These data come from localized, short-term case studies. When data (including those from Palo Alto) are compared with similar areas that did not deploy ALPRs, no significant change is observed. For example, crime (both violent and property) sharply declined nationally from 2021- 2025. Neither Flock nor its customers have produced data that show any effectiveness beyond the national trends. Instead, Flock takes credit for macro trends on which ALPRs have no impact. relationships and trust among law enforcement and residents. Surely, wise use of technology plays a role. However, we question the allocation of precious resources toward ALPR subscriptions rather than investing in human resources in our community. Flock Has Not Earned Our Trust Flock has repeatedly failed to establish data security, has dissembled regarding third party access, and has not taken any responsibility for the abuse of Flock data by its own employees. A Flock ALPR contract means that Palo Alto turns over ownership and control of its data to a private company which has demonstrated shocking arrogance and negligence with regard to sensitive information. That is why, in 2026 alone, 37 different localities have canceled their Flock contracts, including our neighbors in Mountain View. I urge you to make Palo Alto number 38. Respectfully, David Waksberg, Palo Alto resident From:Linda Frommer To:Council, City Subject:Flock Automated License Plate Readers (ALPRs) in Palo Alto Date:Sunday, May 31, 2026 1:19:56 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Palo Alto City Council members, As a long-time Palo Alto resident I am writing today to oppose the use of ALPR and Flock surveillance in our city. While I firmly support our police department and believe they have protected our community well over the many years we have lived and raised our children here and while public safety must remain a high priority, I don't believe using ALPRs/Flock is the way to achieve it. I have deep concerns about how these systems can be abused and breached in unintended ways. Once the data is collected, it exists. Surveillance data in a national database held by a private company under pressure to show results to venture investors, poses a threat to our community's safety that far outweighs any benefit for local law enforcement. Flock ALPR cameras cross the line. I believe in our police department and their ability to keep us safe without this problematic and unsafe database. Please do the right thing. Cover the cameras; cancel the contract. Respectfully, Linda Frommer This message needs your attention This is a personal email address. This is their first email to you. Mark Safe Report From:Melissa Dinwiddie To:Council, City Subject:Please Value Safety Over Surveillance and Cancel Flock Date:Saturday, May 30, 2026 9:40:10 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Honorable Council Members, I’m the founder of Indivisible Palo Alto Plus, representing close to a thousand members. I write to strongly oppose the use of ALPR and Flock surveillance in Palo Alto. Because of the organizing work I do — peacefully promoting First Amendment and other Constitutional rights — the current federal administration would like to label me a “domestic terrorist.” Every week I drive to a meeting with our core leadership team, and the only route there takes me past multiple Flock surveillance cameras. These cameras do not make me feel safe. Quite the opposite. I’ve heard people say, “Don’t worry — it only tracks your car, not you.” That is a legal fiction. Courts have said so, and it doesn’t take much digging to see why. First: Your license plate is registered to you, at your home address. The moment a camera reads that plate, one DMV lookup later, that’s your name, your address, your movements. Virginia’s Supreme Court rejected this exact “it’s not personal data” argument from a police department and saw through it immediately. Consider this analogy: would you accept a camera on every street recording everyone who enters and exits every home — if the city said, “Don’t worry, we’re only tracking addresses, not people”? A plate number tied to a registered owner is your address. The surveillance is of you. The “but it might be a different driver” defense doesn’t hold either. When this system logs your car leaving your driveway at 7AM, at a medical office at 9AM, and at a political meeting at 7PM — that's not a vehicle's pattern. That’s your life, permanently recorded and searchable without a warrant. This is unacceptable, especially in a time of federal overreach. This message needs your attention This is their first email to your company. Mark Safe Report Second: despite the name, these cameras capture far more than license plates. Flock’s own website leads with “Get real-time alerts and rich vehicle details.” Further down: “No Plate? No Problem — turn images into actionable evidence, no plate required.” And while Flock may claim its cameras don’t capture personal or biometric data, the existence of search filters for race and gender tells a different story. I have full confidence in our Palo Alto officers. But we have seen Flock cameras used to track women seeking abortions, to assist ICE in tracking immigrants, and search terms like “No Kings” and “protesters” appearing in query logs. The problem isn't just the people using the cameras today — it’s the infrastructure we’re leaving in place for whoever comes next. We need safety. We do not need more surveillance. Please do the right thing and cover the cameras and cancel the Flock contract immediately. Respectfully, Melissa Dinwiddie Founder & Chief Catalyst Indivisible Palo Alto Plus (IPA+) From:Kat Snyder To:Council, City Subject:Public Comment: Flock study session Date:Saturday, May 30, 2026 8:46:13 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear Council, The police report for this study session does not assuage any of my former concerns. The success stories provided by police are “anecdata” and Flock often trains police to use these as effective talking points when selling the technology and the company. In point of fact, we don’t have useful data on how effective the ALPRs are for us. Crime (both violent and property) sharply declined nationally from 2021-2025. Neither Flock nor its customers have produced data that they are more effective than the national trends. Additionally, this study session does not address the PA Weekly’s investigation into Flock, which showed that “Between July 2023 and October 2024, tens of thousands of searches were performed by outside agencies and California law enforcement” on our data. It does not explain why local officials falsely swore up and down that no one could search our data. This report frustratingly moves the goalposts from the original “no outside searches happened” to “no results were returned from the outside searches.” The redacted audit logs that have just been posted to the Flock portal do not include the reasons for the search, so the public has no way to assess whether people are making inappropriate searches. Disturbingly, a 2021 Biden era DHS policy mandates that ALPR operators leave no trace of ICE in audit logs except for the logs available only to ICE. In other words, Flock can allow DHS to search through Palo Alto’s data without any evidence of that being left in our logs. The fact still remains that, once our data is moved off-premises (into the cloud), we can make no privacy guarantees. Our Surveillance Use Policy is both unenforced on our part, and unenforceable even though we know Flock is a bad faith actor. It is sheer luck that we did not share specific data with out-of-state agencies. Flock has got high market share because it’s good at getting police officers to do its marketing for it, not because it is a good product. The company has sloppy security that has been hacked multiple times. It also is dishonest about how it uses the data it collects. Mountain View’s Chief Canfield reported that Flock employees assured him there was no way for any department not on the transparency list to access their data, and during training never showed them the nationwide or statewide access switches. He considered that breach alone sufficient to recommend cancellation of Flock. We should follow his example and cancel our Flock contract, or at least cover up the cameras in the meantime. Take care, ~Kat Snyder Palo Alto Resident From:Justin G To:Council, City Subject:Flock Has Not Earned Our Trust Date:Saturday, May 30, 2026 6:40:46 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear City Council members, I frequently drive through Palo Alto, so I would like to express my concern over the deployment of Flock Automated License Plate Readers (ALPRs) in Palo Alto. We cannot trust this company. Flock has repeatedly failed to establish data security, has lied regarding third party access, and has not taken responsibility for the abuse of Flock data by its own employees. A Flock ALPR contract means that Palo Alto turns over ownership and control of its data to a private company which has demonstrated shocking arrogance and negligence with regard to sensitive information. That is why, in 2026 alone, 37 different localities have canceled their Flock contracts, including our neighbors in Mountain View and Los Altos Hills. Please make Palo Alto number 38. Best, Justin Sent with Proton Mail secure email. This message needs your attention No employee in your company has ever replied to this person. This is a personal email address. Mark Safe Report From:Nancy Devine To:Council, City Subject:Flock Surveillance Cameras Have Broken Our Trust Date:Saturday, May 30, 2026 4:46:18 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear City Council members, I am a Palo Alto native who attended all Palo Alto Public schools and currently shop, take yoga classes, and use the library in Palo Alto. I write to express my serious objection over the deployment of Flock Automated License Plate Readers (ALPRs) in Palo Alto. We cannot trust this company. My parents moved here from Chicago to start a family in a safe, family community. My father was a lawyer, a city council member, a vice mayor, and also a Judge of the Superior Court who served the people of California for more than 20 years. My father told me that while on the city council he had to work hard and stay late on the planning commission meetings to keep Palo Alto the safe environment for families he and others worked to create. I covered city council meetings as an intern at the former Palo Alto Times. I now live in Mountain View, and in Mountain View, Flock illegally allowed access to surveillance data to ICE for over one year, failing the data security, and BREAKING the contract. The City of Mountain View could not agree to renew Flock’s license because of these lies and contract breaches. This is a company that cannot be trusted. In Mountain View, or Palo Alto, or any city. Flock has repeatedly failed to establish data security, has lied regarding third party access, and has not taken responsibility for the abuse of Flock data by its own employees. Surveillance of the city is not a good way to promote community safety, and is one more tactic of an authoritarian system that cannot be trusted to resist using the surveillance against residents and visitors. We want safety yes, but there are other This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report ways, other technologies even, to ensure safety. And I feel certain that residents who feel VERY strongly about this will consider it a reason to vote for or against city council members in upcoming elections. A Flock ALPR contract would mean that Palo Alto turns over ownership and control of its data to a private company which has demonstrated shocking arrogance and negligence with regard to sensitive information. That is why, in 2026 alone, 37 different localities have canceled their Flock contracts, including my city of Mountain View and Los Altos Hills. Please make Palo Alto number 38. Respectfully, Nancy Devine Mountain View From:lindabaker To:Council, City Subject:Flock camera systems are not safe or secure Date:Saturday, May 30, 2026 4:19:30 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Honorable City Council members, I live near Palo Alto. I drive through town regularly and do much of my regular shopping in Palo Alto. I have serious concerns about Flock's AI-enabled Automated License Plate Readers in Palo Alto. The recent example in Dunwoody, GA is appalling and should be disqualifying by itself. A local resident filed records requests for ALPR data and discovered that Flock employees watched live feeds from the local Jewish Community Center, including a children's swimming pool, a children's gymnastics room where young athletes practice, a local playground and school property, and a private interior fitness studio. Flock also used live children's gymnastics feeds for sales demonstrations! This is not a breach - this is the system being used on purpose by a company with no ethics. In December 2025, more than 60 Flock cameras were discovered broadcasting their feeds to the open, unencrypted Internet. Anyone with a web browser could access these images. Last year, a Congressional investigation discovered that the login credentials for at least 35 distinct Flock law enforcement customer accounts had been stolen by hackers using "infostealer" malware. Active law enforcement credentials were found listed for sale on Russian-language cybercrime forums. Any criminal or foreign spy who purchased those credentials could use Flock's "National Lookup" feature to track the real-time movements of vehicles across all 49 states where Flock operates. I can opt out of social media, change my privacy settings on my phone, opt-out of cookies by California law, or ask a website to delete my data. None of this is true with Flock. This is warrantless mass surveillance without accountability or the ability to This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report truly audit, no true oversight or guardrails, and no way to assess or repair the damage when something goes wrong. For our safety, please cover the cameras and cancel the contract. Respectfully, Linda Baker From:Nicole Poon To:Council, City Subject:Concerns over surveillance cameras Date:Saturday, May 30, 2026 3:14:57 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear City Council members, I am a Los Altos resident who go to Palo Alto from time to time. I write to oppose the use of ALPR and Flock surveillance in Palo Alto. When I own a cell phone, I can decide to leave it at home, or I can turn it off. I can decide which operating system to run, which apps to install, and I have fine-grained control over privacy settings. I can clear my data. When I visit a website, I am presented with a choice to accept cookies, and as a California resident, I have a right to know what data a company has on me and request that it be deleted. I can decide which social media companies to participate with and which not to. If police want my location data from my cell phone carrier, they need a signed warrant from a judge. I have no such protections with Flock. I can’t stay home. And I can’t revoke consent that I have never granted. Surveillance is not safety. Please cover the cameras and cancel the contract. Respectfully, Nicole P. This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report From:Emily Berman To:Council, City Subject:Please no flock Date:Saturday, May 30, 2026 2:57:59 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Hi! I’m a resident of Palo Alto, and given Flock’s history of (at times, illegally relative to their contract terms!) sharing Bay Area info with ICE and others I am SO uncomfortable with the presence of their cameras here. Please let’s not give them our data willingly. Thanks, Emily Berman 673 Georgia Ave, Palo Alto, CA 94306 This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report From:Millie Chethik To:Council, City Cc:mchethik@gmail.com Subject:No Flock in Palo Alto Date:Saturday, May 30, 2026 2:56:44 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. > Dear City Council members, > > I am a Palo Alto resident and I write to express my grave concern over the deployment of Flock Automated License Plate Readers in Palo Alto. We cannot trust this company. > > Flock has repeatedly failed to establish data security, and has lied regarding third party access, and has not taken responsibility for the abuse of Flock data by its own employees. > > A Flock ALPR contract means that Palo Alto turns over ownership and control of its data to a private company which has demonstrated shocking arrogance and negligence with regard to sensitive information. That is why, in 2026 alone, 37 different localities have canceled their Flock contracts, including our neighbors in Mountain View and Los Altos hills. > > Please make Palo Alto number 38. > > Respectfully, > > Millie Chethik From:jk To:Veenker, Vicki; Council, City Subject:Flock ALPR cameras violate my privacy Date:Saturday, May 30, 2026 2:41:14 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Mayor and City Council members, I am a Palo Alto resident of 40+ years writing to oppose the use of ALPR and Flock surveillance in Palo Alto. Unlike my owning a cell phone where I have a individual control of my information, I have no control over the information Flock collects. With a phone I can decide to leave it at home, turn it off, decide which operating system to run, which apps to install, and I have fine-grained control over privacy settings. I can clear my data, choose to accept or deny cookies, and as a California resident, I have a right to know what data a company has on me and request that it be deleted. Flock surveillance is imposed upon me without my consent and with zero control. If police want my location data from my cell phone carrier, they need a signed warrant from a judge. I have no such protections with Flock. I can’t stay home. And I can’t revoke consent that I have never granted. This is an unlawful invasion of privacy. Surveillance is not safety. Please consider your constituents' safety above all and cover the cameras and cancel the contract. Respectfully, Jim Kozelka jk Treasurer, Peace Ambassador, “utility fielder” Indivisible Palo Alto Plus (IPA+) "Be truthful, gentle, and fearless" - Gandhi This message needs your attention This is their first mail to some recipients. Mark Safe Report From:Ben Junsy To:Council, City Subject:Flock Cameras Date:Saturday, May 30, 2026 2:27:45 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear City Council members, I write to oppose the use of ALPR and Flock surveillance in Palo Alto. I initially thought that it might be used conservatively, and called into action if needed to follow up on a crime. Clearly this is not the case. I am increasingly concerned that information from flock cameras may be used for inappropriate or malevolent purposes, and with little or no respect for an individual’s right to privacy. Please cover the cameras and cancel the contract. I am a Palo Alto resident. Thank you, Annie Hempstead This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report From:Judy Levy To:Council, City Subject:ELIMINATE Flock cameras in Palo Alto Date:Saturday, May 30, 2026 2:05:36 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear City Council members, I am in Palo Alto multiple times per week as I attend exercise classes and shop in Palo Alto. I'm writing because I have serious concerns about Flock Automated License Plate Readers (ALPRs) in Palo Alto. I've outlined my concerns below. ***Please join other local communities (eg Mountain View) and eliminate this incredibly unsecure, invasive government overreach into our privacy. ***I don't want to feel that I'm being spied upon/my constitutional rights infringed each time I visit your city***. Thank you. Judy Levy, Mountain View Flock systems have been shown to be remarkably unsecure. After a Dunwoody, GA resident filed records requests for ALPR data, he was shocked to discover that Flock personnel were routinely logging in to spy Dunwoody residents. Flock employees watched live feeds from the local Jewish Community Center, including a children's swimming pool, a children's gymnastics room where young athletes practice, a local playground and school property, and a private interior fitness studio. In December 2025, more than 60 Flock cameras were discovered broadcasting their feeds to the open, unencrypted Internet. Anyone with a web browser could access these images. Last year, a Congressional investigation discovered that the login credentials for at least 35 distinct Flock law enforcement customer accounts had been stolen by hackers using "infostealer" malware. Active law enforcement credentials were found listed for sale on Russian-language cybercrime forums. Any criminal or foreign spy who purchased those credentials could use Flock's "National Lookup" feature to track the real-time movements of vehicles across all 49 states where Flock operates. This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report Please cover the cameras and cancel the contract. Respectfully, Judy Levy. From:Phyllis Klein To:Council, City Subject:I am opposed to FLOCK in Palo Alto Date:Saturday, May 30, 2026 2:02:44 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear City Council members, I am a Palo Alto resident I write to oppose the use of ALPR and Flock surveillance in Palo Alto. When I own a cell phone, I can decide to leave it at home, or I can turn it off. I can decide which operating system to run, which apps to install, and I have fine-grained control over privacy settings. I can clear my data. When I visit a website, I am presented with a choice to accept cookies, and as a California resident, I have a right to know what data a company has on me and request that it be deleted. If police want my location data from my cell phone carrier, they need a signed warrant from a judge. I have no such protections with Flock. I can’t stay home. And I can’t revoke consent that I have never granted. In addition, I believe that our great police department can solve crimes without putting all residents and people who drive in Palo Alto into a national surveillance system that can be easily used to profile everyone from Black and Brown people to protesters that the government wants to silence. Although the company says it guarantees safety within the database, there have been breeches in security as with a quiet pilot program in Illinois that allowed ICE to access license plate information last August. After a Georgia resident filed records requests for ALPR data, he was shocked to discover that Flock personnel were routinely logging in to spy Dunwoody Georgia residents. Flock employees watched live feeds from the local Jewish Community Center, including a children's swimming pool, a children's gymnastics room where young athletes practice, a local playground and school property, and a private interior fitness studio. In December 2025, more than 60 Flock cameras were discovered broadcasting their feeds to the open, unencrypted Internet. Anyone with a web browser could access these images. Please also consider that the financial backers of FLOCK aretwo extremely wealthy men who have publicly endorsed authoritarianism on a national scale. Surveillance is not safety. For all the reasons I have listed above: Please cover the cameras and cancel the contract. Respectfully, Phyllis Klein From:cindyn11 To:Council, City Subject:No Flock surveillance in our community Date:Friday, May 29, 2026 5:44:51 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i I've lived in Palo Alto for forty years, raising kids, supporting schools and businesses, and voting in local elections. Hearing about Flock cameras and what Flock has allowed in terms of mis-using data across the country has given me great pause, and I wonder what the Palo Alto police and city council are THINKING. This dangerous contract sets up government, rogue law enforcement, and corrupt corporations to track every day civilians, and when needed, suppress our free expression and participate as designed by the US Constitution. This and any other tracking system that violates our fourth amendment rights needs to be stopped, now. No occasional benefit of solving the occasional crime is worth giving up our freedoms, no matter how good that feels in the short term. Cynthia Nelson Sent with Proton Mail secure email. This message needs your attention This is a personal email address. Mark Safe Report From:CaraSilver@proton.me To:Council, City Subject:Public Comment re June 1 City Council Study Session on Flock Date:Friday, May 29, 2026 4:33:38 PM Attachments:2026-05-29 Silver Letter to Palo Alto Council re Flock.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Please see attached comment letter. Thanks much, Cara Silver Sent with Proton Mail secure email. 1 May 24, 2026 Re: Public Comment - Agenda Item No. 5, May 26, 2026 Flock License Plate Reader Contract Renewal Dear Mayor and Councilmembers: I am the co-lead of the Immigrant Rights Action Team of Indivisible Palo Alto Plus and a member of the newly formed coalition Safety Over Surveillance (SOS) Palo Alto. I am also a municipal attorney, and in this capacity have reviewed thousands of Service Agreements. For the past year, I have been monitoring actions taken by Santa Clara County cities with respect to Flock contracts. The collection of detailed data, held by a private company with documented privacy abuses and close ties to the federal government, creates a mass surveillance state in a time of egregious federal overreach. As residents and local governments learn more about this technology, alarm bells are going off across the country. This is profoundly unsafe. And it is about much more than license plates. As discussed in more detail below, I have grave concerns about the existing terms and conditions contained in Flock standard contracts as well as the new terms and conditions that Flock is rolling out. The Legal Framework There are several constitutional and statutory safeguards regarding automated license plate readers (ALPR’s). Both the federal and state constitutions provide a right to privacy from government surveillance. The application of this principle to Flock technology is the subject of many recently ﬁled lawsuits. For example, a recent class action was ﬁled against the City of San Jose under a privacy theory. The suit argues that Flock’s ALPR network violates privacy protections: “No officer ever has to establish probable cause, swear to the facts in a warrant application, or await the approval of a judge. . . .Officers can run searches based on a hunch, idle curiosity, or even personal animus. Around the country, officers have been caught using [automated license-plating reader] databases to stalk their ex- partners, monitor protestors and even track down a woman who reportedly had an abortion.”1 A similar class action lawsuit was ﬁled against Flock in San Francisco Superior 1 https://www.kqed.org/news/12080233/san-jose-residents-sue-city-saying-ﬂock-safety-cameras-allow- mass-surveillance. 2 Court.2 And a class action lawsuit was ﬁled against Home Depot alleging that it had turned over surveillance data to law enforcement agencies without a warrant.3 California also has two statutory schemes preventing the sharing of ALPR-collected data. First, SB 54, known as California’s sanctuary state law, prohibits all cities from sharing data with ICE and Border Patrol. Second, SB 34, the ALPR privacy law, prohibits sharing data with federal and out of state agencies. Importantly, SB 34 contains a $2,500 penalty for data sharing violations as well as a private cause of action. A recently leaked legal memorandum from the City of Berkeley’s Attorney’s Office about Flock Safety warned that Flock technology might be incapable of complying with city, state and federal unauthorized data sharing restrictions even with the addition of strenuous contractual safeguards.4 Flock’s Collection of Data Via a Nationwide Database is Inherently Risky ALPR technology is a powerful surveillance system that can be used to invade the privacy of individuals and violate the rights of entire communities, particularly vulnerable residents. ALPR systems collect and store location information about drivers that can be built into a database that, in turn, reveals sensitive details about where individuals work, live, associate, worship, seek medical care, and travel.5 As with other surveillance technologies, police often disproportionately deploy license plate readers in communities experiencing poverty and historically overpoliced communities of color, regardless of crime rates.6 ALPR information has also been shared with immigration authorities such as 2 https://www.classlawgroup.com/ﬂock-license-plate-cameras-face-class-action-lawsuit-by-gibbs-mura-a- law-group. 3 https://www.dailyjournal.com/article/390841-home-depot-sued-over-license-plate-reader-use-in-parking- lots 4 https://www.dailycal.org/news/city/leaked-city-attorney-memo-shows-berkeley-risks-potential-million- dollar-lawsuits-if-council-renews-ﬂock/article_2a5efc3e-4d33-4b2f-8683-0e1395642fe8.html. 5See, e.g., Automatic License Plate Readers, ELECTRONIC FRONTIER FOUNDATION(Mar.29, 2023)https://www.eff.org/sls/tech/automated-license-plate-readers; You Are Being Tracked: How License Plate Readers Are Being Used to Record Americans’ Movements, AMERICAN CIVIL LIBERTIES UNION (July 2013) https://www.aclu.org/issues/privacy-technology/you-are-being-tracked. 6 Dave Maass and Jeremy Gillula, What You Can Learn from Oakland’s Raw ALPR Data, ELECTRONIC FRONTIER FOUNDATION(Jan. 21, 2015)https://www.eff.org/deeplinks/2015/01/what-we-learned-oakland- raw-alpr-data; Barton Gellman and Sam Adler-Bell, The Disparate Impact of Surveillance, THE CENTURY FOUNDATION (Dec. 21, 2017)https://production-tcf.imgix.net/app/uploads/2017/12/03151009/the- disparate-impact-of-surveillance.pdf; see also, e.g., Kaveh Waddell, How License-Plate Readers Have Helped Police and Lenders Target the Poor, THE ATLANTIC(Apr. 22, 2016) https://www.theatlantic.com/technology/archive/2016/04/how-license-plate-readers-have-helped-police- 3 Immigration and Customs Enforcement (“ICE”) and Customs and Border Protection (“CBP”) to identify, detain, and deport immigrant community members.7 The possibility of human workarounds at every level undermines any technical safeguards Flock may claim. Search term blocking relies on officers accurately labeling search intent—a system easily defeated by entering vague reasons like "investigation" or incorrect justiﬁcations, made either intentionally or not. And, of course, words like "investigation" or "missing person" can mean virtually anything, offering no value to meaningful oversight of how and for what the system is being used. The recently employed drop down menu options make it even easier for users to select a search term that would “pass” a network audit. The same can be said for case number requirements, which depend on manual entry. This can easily be circumvented by reusing legitimate case numbers for unauthorized searches. Audit logs only track inputs, not contextual legitimacy. Flock's proposed AI- driven audit alerts, something that may be able to ﬂag suspicious activity after searches (and harm) have already occurred, relies on local agencies to self-monitor misuse— despite their demonstrated inability to do so.8 Even the most restrictive department policy may not be enough. Austin, Texas, had implemented one of the most restrictive ALPR programs in the country, and the program still failed: the city's own audit revealed systematic compliance failures that rendered its guardrails meaningless.9 Palo Alto’s Data Was Accessed by Federal and State Agencies Like other police departments in the bay area, the Palo Alto Police Department has repeatedly stated that none of the City’s data has been accessed by federal agencies. The Council has also represented that its internal policies guard against such unauthorized access. Unfortunately, both representations have been proven wrong as recently reported and-lenders-target-the-poor/479436/ (summarizing data indicating that Oakland Police Department deployed ALPRs “disproportionately often in low-income areas and in neighborhoods with high concentrations of African-American and Latino residents”). 7 Saira Hussain and Adam Schwartz, EFF Files New Lawsuit Against California Sheriff for Sharing ALPR Data with ICE and CBP, ELECTRONIC FRONTIER FOUNDATION (Oct. 19, 2021) https://www.eff.org/deeplinks/2021/10/eff-ﬁles-new-lawsuit-against-california-sheriff-sharing-alpr-data-ice- and-cbp 8 https://www.eff.org/deeplinks/2025/06/ﬂock-safetys-feature-updates-cannot-make-automated-license- plate-readers-safe. 9 Id. 4 by Palo Alto Online.10 From late 2023 to October 2024, Flock secretly enabled the “nationwide search” feature for all local police departments. While the City claims there was no data released to out-of-state agencies, there are several problems with this assertion: • First, the fact that a particular license plate was not found in Palo Alto, is in fact an important data point in an investigation. It shows that the particular car was not in Palo Alto and thus the outside agency may focus elsewhere on its search. • The staff report states it must consult with Flock to determine whether data was disclosed to outside agencies. Indeed, it is Flock that prepares the monthly network audits showing which agencies searched the City’s system and for what purpose. However, the Department of Homeland Security’s privacy policy prohibits ALPR vendors from releasing ICE queries to its customers: “The LPR vendor is not permitted to share ICE query information with third parties without ICE’s express permission, including other customers, business parties, or any other individual or entity.”11 Thus, Flock is not legally permitted to disclose whether ICE searched Palo Alto’s records during this time period. • The City also claims that no immigration-related searches were performed. However, the network audits released pursuant to the PRA request do not show the reason for the search. Audits from other agencies who have responded to similar PRA requests clearly show that some of the searches performed during this period included “ICE” and “immigration”. Either Palo Alto mysteriously was not included in the “nationwide lookup” searches that other local agencies received or an adequate veriﬁcation was not performed to determine the reasons for the search. The Flock Contract Has Troubling Terms and Conditions Flock encourages all of its city customers to sign a template contract that on its face appears to protect city data, but in reality contains large loopholes. Further, Flock is rolling out new terms and conditions that continue to cut inroads into data privacy. As Flock’s success depends on a connected network of data, this is not surprising. For example, Paragraph 4.1 of the Flock contract permits Flock to release City data in response to a judicial subpoena: 10 https://www.paloaltoonline.com/police/2026/04/22/palo-alto-license-plate-data-searched-by-hundreds- of-out-of-state-agencies/ 11 https://www.dhs.gov/sites/default/ﬁles/publications/privacy-pia30b-ice- acquisitionanduseoﬂprdatafromacommercialservice-june2021_0.pdf 5 For clarity, Flock may access, use, preserve and/or disclose the Footage to law enforcement authorities, government officials, and/or third parties, if legally required to do so or if Flock has a good faith belief that such access, use, preservation or disclosure is reasonably necessary to: (a) comply with a legal process or request; (b) enforce this Agreement, including investigation of any potential violation thereof; (c) detect, prevent or otherwise address security, fraud or technical issues; or (d) protect the rights, property or safety of Flock, its users, a third party, or the public as required or permitted by law, including respond to an emergency situation. Flock may store deleted Footage in order to comply with certain legal obligations, but such retained Footage will not be retrievable without a valid court order. Since the contract permits Flock to make the decision on whether the data release is “legally required” without requiring the City’s permission to disclose such data, we must rely on Flock’s “good will’ in interpreting and applying this contract provision. However, Flock’s reputation for illegal releases belies this ability.12 And Flock continues to update its standard contract terms to carve out more rights to Flock and less rights over data to municipalities.13 Flock Has Every Incentive to Expand Its System and Use Palo Alto’ Data to Assist in Federal Searches and Incursions into Our Privacy. Flock’s business model depends on ultimately creating an integrated database which can then be marketed to the federal government. On May 14, 2026, the FBI released an RFP for a nationwide RFP that can provide ALPRs for tracking subjects on roads and highways over the US and its territories. The requirements include: • The bidder must provide law enforcement and/or commercial license plate reader data provided through the Contractor’s existing platform. The system must cover 75 percent of locations. • The system must offer the ability to search for license plate information and other descriptive data such as vehicle description information, time/date criteria, and geo-location criteria. • The system must provide search result notiﬁcations. The Contractor system must have the ability to access and/or query cameras across the United States and its 12 https://www.aclu-co.org/press-releases/coalition-of-civil-rights-and-advocacy-organizations-deeply- concerned-about-use-of-ﬂock-cameras-for-ice-surveillance/. 13 https://www.aclu.org/news/privacy-technology/ﬂocks-terms-and-conditions 6 territories. The Contractor system must be capable of providing this data in near real time. • Contractors have to be able to share/create maps depicting camera coverage (i.e. heat mapping), and provide the FBI the source of information (i.e. red-light cameras, repossession vendors, speed cameras, etc.). • The FBI must be able to search the database for partial or full plate numbers, plate states, addresses, locations where a plate was scanned, and vehicle makes and models.14 It is widely reported that Flock will be bidding on this contract. This bid’s success will rely on the most robust and comprehensive network Flock can demonstrate. For all these reasons, I urge the Council to take the following actions: 1. Cancel the existing contract with Flock and not exercise any of the renewal provisions; 2. If the Council is not inclined to immediately cancel the Flock contract, a. Direct the Police Auditor to meet with representatives from Safety over Surveillance Palo Alto to ensure their concerns are addressed in the audit and b. Direct the City Attorney to review the Berkeley City Attorney legal memorandum and opine whether the concerns addressed in the Berkeley memorandum apply to the Palo Alto contract. Sincerely, Cara Silver Safety over Surveillance Palo Alto Indivisible of Palo Alto 14 https://arstechnica.com/tech-policy/2026/05/fbi-seeks-us-wide-access-to-license-plate-cameras-wants- data-in-near-real-time/ From:govbria@icloud.com To:Council, City Subject:Safety over surveillance! Date:Friday, May 29, 2026 4:18:16 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear PA City Council, The success stories provided by police are “anecdata” and Flock often trains police to use these as effective talking points when selling the technology and the company. In point of fact, we don’t have useful data on how effective the ALPRs are for us. Crime (both violent and property) sharply declined nationally from 2021-2025. Neither Flock nor its customers have produced data that they are more effective than the national trends. Additionally, this study session does not address the PA Weekly’s investigation into Flock, which showed that “Between July 2023 and October 2024, tens of thousands of searches were performed by outside agencies and California law enforcement” on our data. It does not explain why local officials falsely swore up and down that no one could search our data. This report frustratingly moves the goalposts from the original “no outside searches happened” to “no results were returned from the outside searches.” The redacted audit logs that have just been posted to the Flock portal do not include the reasons for the search, so the public has no way to assess whether people are making inappropriate searches. Disturbingly, a 2021 Biden era DHS policy mandates that ALPR operators leave no trace of ICE in audit logs except for the logs available only to ICE. In other words, Flock can allow DHS to search through Palo Alto’s data without any evidence of that being left in our logs. The fact still remains that, once our data is moved off-premises (into the cloud), we can make no privacy guarantees. Our Surveillance Use Policy is both unenforced on our part, and unenforceable even though we know Flock is a bad faith actor. It is sheer luck that we did not share specific data with out-of-state agencies. Flock has got high market share because it’s good at getting police officers to do its marketing for it, not because it is a good product. The company has sloppy security that This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report Mountain View’s Chief Canfield reported that Flock employees assured him there was no way for any department not on the transparency list to access their data, and during training never showed them the nationwide or statewide access switches. He considered that breach alone sufficient to recommend cancellation of Flock. We should follow his example and cancel our Flock contract, or at least cover up the cameras in the meantime. ALPRs threaten our safety AND our democracy. Please vote to do the right thing. Cancel our Flock contract. Thank you. Best, Brinda Govindan From:CaraSilver@proton.me To:Council, City Cc:David Waksberg Subject:Comment Letter for June 1 Flock Study Session Date:Friday, May 29, 2026 1:44:10 PM Attachments:Letter to PACC re June 1 meeting re Flock.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Please see attached comment letter for the June 1 study session on Flock cameras. Thank you, Cara Silver Safety over Surveillance Palo Alto Sent with Proton Mail secure email. 1 May 29, 2026 Re: June 1 City Council Agenda Item No. 2 Dear Mayor Veenker, Vice-Mayor Stone, and Council Members Burt, Lauing, Lu, Lythcott- Haims, and Reckdahl: Thank you for your leadership and service to Palo Alto. We write to express our grave concern over the deployment of Flock Automated License Plate Readers (ALPRs) in Palo Alto. After a thorough review of the information available to us, we have concluded that these surveillance cameras threaten, and indeed, cause, more harm to Palo Altans and our neighbors than they help. We wish to brieﬂy review the harms and risks we have uncovered, as well as the “false advertising” that exaggerates claims of beneﬁt to Palo Alto. Flock ALPRs are a part of a network; indeed, Flock promotes the “network effect” as a selling point. But, as we will point out, efforts by local jurisdictions to limit the use of data from their communities have proven ineffective. Thus, an assessment of Flock deployment in Palo Alto must include the potential that our data will be used or misused by others. This also means that as we review harms and potential harms, we are not accusing or even suggesting malfeasance on the part of Palo Alto personnel, but rather tthat we can become implicated in downstream harms from Palo Alto data. Discriminatory Proﬁling Flock claims that ALPRs don’t discriminate. However, they have emerged as a useful instrument for racial proﬁling. Last year, law enforcement agencies performed hundreds of data searches across thousands of Flock deployments using “Roma” and “Gypsy” as key words. 2 In 2023, in Oak Park, IL, 84% of drivers pulled over in Flock-generated traffic stops were Black. Black people comprise 19% of the population. That represents an INCREASE from the 53% the year before Flock ALPRs were deployed. In 2025, Marimar Martinez, a Montessori school teaching assistant and U.S. citizen, was shot ﬁve times by Border Patrol agents in Chicago. DHS (mis)used Flock data to support their claim that Martinez was a “domestic terrorist.” When analyzed, the data showed Martinez driving to Target for school supplies. In August 2020, Brittney Gilliam, an African-American woman, was taking her 6-year-old daughter, her 12-year-old sister, and her 14- and 17-year-old nieces to get their nails done in Aurora, CO. Gilliam’s car was swarmed by Aurora police officers with their guns drawn. Flock ALPRs had confused Gilliam’s license plate with that of a stolen motorcycle from another state. In addition to traumatizing Gilliam and the four children in her car, the incident resulted in a $1.9 million lawsuit settlement by the City of Aurora. Suppression of Dissent and Politicized Abuse of Data Historically, when surveillance methods have been deployed, they have almost always ended up being used to monitor and suppress dissent. Therefore, we were anxious to review the record: have law enforcement agencies used Flock ALPRs to monitor constitutionally protected non-violent protest? Flock ALPRs have been used multiple times to monitor dissent, including law enforcement agencies searching for key words: “no kings,” “Hands Off,” and, simply, “protest.” Other searches of Flock data corresponded with May Day rallies, protests against Trump Administration DOGE cuts, and protests against immigration policies. In May, 2025, the Johnson County, Texas Sheriff’s office conducted a nationwide search of 83,000 Flock ALPR’s using the key words: “had an abortion, search for female.” Flock ALPRs Used to Hunt Immigrants An audit of Flock systems in Illinois last August revealed that Flock had quietly initiated an unauthorized "pilot program" that gave the U.S. Customs and Border Protection (CBP) direct access to local license plate readers on Illinois roads, allowing federal agents to surveil drivers. An investigation into unauthorized “side-door” access to Flock data uncovered more than 4,000 lookups conducted through local law enforcement portals at the behest of federal immigration officials. Because these were performed by other agencies on behalf of ICE, local authorities were not aware their data was being used to search for immigrants. 3 Leaky Data: No Security, No Privacy Flock systems have been shown to be remarkably unsecure. After a Dunwoody, GA resident ﬁled records requests for ALPR data, he was shocked to discover that Flock personnel were routinely logging in to spy Dunwoody residents. Flock employees watched live feeds from the local Jewish Community Center, including: • A children's swimming pool • A children's gymnastics room where young athletes practice • A local playground and school property • Private interior ﬁtness studios In January of this year, more than 60 Flock cameras were discovered broadcasting their feeds to the open, unencrypted Internet. Anyone with a web browser could access these images. Last year, a Congressional investigation discovered that the login credentials for at least 35 distinct Flock law enforcement customer accounts had been stolen by hackers using "infostealer" malware. Active law enforcement credentials were found listed for sale on Russian-language cybercrime forums. Any criminal or foreign spy who purchased those credentials could use Flock's "National Lookup" feature to track the real-time movements of vehicles across all 49 states where Flock operates. Do ALPRs Reduce Crime? Flock bases its crime-reduction claim on anecdotes and cherry-picked statistics. It may be too early in the life-cycle of this technology to really know; thus far, the evidence is not encouraging: Flock’s claims of crime reduction do not hold up under scrutiny. These data come from localized, short-term case studies. When data (including those from Palo Alto) are compared with similar areas that did not deploy ALPRs, no signiﬁcant change is observed. For example, crime (both violent and property) sharply declined nationally from 2021-2025. Neither Flock nor its customers have produced data that show any effectiveness beyond the national trends. Instead, Flock takes credit for macro trends on which ALPRs have no impact. Experts maintain that best practice in crime reduction involves building relationships and trust among law enforcement and residents. Surely, wise use of technology plays a role. However, we question the allocation of precious resources toward ALPR subscriptions rather than investing in human resources in our community. 4 Flock Has Not Earned Our Trust Flock has repeatedly failed to establish data security, has dissembled regarding third party access, and has not taken any responsibility for the abuse of Flock data by its own employees. A Flock ALPR contract means that Palo Alto turns over ownership and control of its data to a private company which has demonstrated shocking arrogance and negligence with regard to sensitive information. That is why, in 2026 alone, 37 different localities have canceled their Flock contracts, including our neighbors in Mountain View. We urge you to make Palo Alto number 38. Respectfully, American Friends Service Committee (AFSC) Blue Turn Indivisible Envision Transform Build East Palo Alto (ETB) Indivisible Mid-Peninsula Indivisible Palo Alto Plus Los Altos for Representation and Equity (LARE) Multi-Faith Voices for Peace and Justice Services, Immigrant Rights & Education Network (SIREN) Silicon Valley Democratic Socialists of America Together We Will — Palo Alto/Mountain View Youth United for Community Action (YUCA) Cc: David Waksberg, Palo Alto resident From:Cybele LoVuolo-Bhushan To:Council, City Subject:Flock Study Date:Friday, May 29, 2026 1:23:39 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Hello Palo Alto City Council members, Referencing the Study Session on the ALPR FLOCK Cameras. As a U. S. born citizen of Italian and East European extraction, I have a duty to write in opposition to the use of Flock cameras in Palo Alto. The unfortunate reality is that our current government is building detention centers to hold recent immigrants, no matter their age, or health condition. This appears to be a case of history repeating itself like the Japanese internment camps: we are not even at war with the countries that our immigration system is targeting. Much has changed from the previous administration where the rule of law (courts, etc.) was followed (with at least one notible exception during the Obama administration). The Flock cameras are enabling the current administration to track each and every person in our town. This is no way to encourage respect for our government. In fact, it does just the opposite: it creates undue suspicion and cuts off innovative ideas due to preoccupation with the technology of surveillance, again, creating a kind of us against them attitude. Please do not renew the contract with the Flock company. Stop their use in Palo Alto so our community can renew it's unity where trust is the first approach. Thank you. Sincerely, Cybele (nee Judith) LoVuolo-Bhushan 3838 Mumford Place Palo Alto 94306 From:Peter Giovannotto To:Council, City Subject:Letter of Support for Continued Police use of Flock Technology Date:Friday, May 29, 2026 10:47:31 AM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Members of the Palo Alto City Council, I am writing to express my strong support for the Palo Alto Police Department’s continued utilization of Flock Automated License Plate Recognition (ALPR) technology. As a long-time resident, local business owner, and someone deeply invested in our city, I view Flock cameras as essential infrastructure for public safety. Effective policing requires efficient technology. This is especially critical now, as budget constraints and officer retention issues have reduced our active headcount, limiting the manual tools and coverage officers can provide on the ground. Data from the initial deployment demonstrates that the system works exactly as intended. It provides the department with objective, actionable leads that cut down investigation times and clear cases efficiently. This capability is uniquely valuable for cross-jurisdictional crimes— where an incident occurs in one Flock-partner city, but the vehicle moves into another. Without this network, tracking these vehicles quickly would be nearly impossible. With it, locating and apprehending suspects becomes highly efficient. In an environment where law enforcement resources must be allocated precisely, a passive, tech-driven deterrent and investigative tool is a practical necessity. It serves as a force multiplier, allowing our remaining officers to focus their field efforts where they are most effective. Furthermore, the PAPD has established clear, transparent protocols to ensure the technology is used strictly for its intended public safety purposes with appropriate oversight. The evidence shows these guardrails are working. I ask that the City Council to maintain its commitment to public safety by continuing to authorize and fund the Flock ALPR system. Providing our officers with reliable, up-to-date tools is a practical necessity for keeping Palo Alto safe, secure, and at the forefront of modern policing. Sincerely, Peter Giovannotto This message needs your attention This is their first email to you. Mark Safe Report -- Peter Giovannotto 459 Hamilton Avenue, Suite 105, Palo Alto, CA 94301O: (650) 328-7480 | C: (650) 464-1403 | W: www.vrent.com From:Evan Reade To:Council, City; Veenker, Vicki; Lauing, Ed; Reckdahl, Keith; Burt, Patrick; Lythcott-Haims, Julie; Stone, Greer; Lu, George Cc:Reifschneider, James; Shikada, Ed Subject:PAPD use of Flock Cameras, Agenda Item #2, June 1, 2026 Date:Thursday, May 28, 2026 5:08:42 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear Madam Mayor Veenker, Dear Members of the City Council: I am writing to urge you to continue to support the use of Flock Automated License Plate Recognition (ALPR) technology by the Palo Alto Police Department. As a lifelong Palo Alto resident and as a former Palo Alto police officer it is my view that the first duty of our local government is so provide for the safety and security of those who live, work, or visit in our city. I know that many of you feel the same way. To fulfill this duty our police department must be provided with the most up-to-date and effective tools and technology to do so. The Flock ALPR technology is one such tool. As the report in your packet notes: "The deployment of Flock ALPR cameras in Palo Alto began in July 2023 . The Department has used these cameras to great effect. Real-time alerts generated by the ALPR cameras have resulted in the recovery of dozens of stolen vehicles and stolen license plates, and the apprehension of numerous wanted persons. In addition, ALPR has been used to safely locate multiple missing persons. Data captured by the ALPR cameras has also assisted investigators in the after-the-fact identification and arrest of numerous felony suspects." The report goes on to list just a few of the many incidents in which this technology has been successfully utilized, and I am certain that Chief Reifschneider can cite to you many more. It is a fact that with the use of Flock technology the PAPD has: saved lives, recovered stolen property, arrested dangerous criminals. In addition, the presence of Flock cameras in our city no doubt acts as a deterrent to would-be criminals who might choose to go to other cities or towns not covered by Flock to commit crime. In short, the presence and use of Flock technology has made our city a safer place for all. Like all tools and technologies, ALPR technology must be utilized as designed, and misuse must be avoided. It is clear from the staff report that prudent and thoughtful policies have been implemented by the PAPD to prevent misuse, and reviews conducted to date have found no evidence of misuse. Moreover, I have faith that Chief Reifschneider and his command staff, along with our City Attorney and you, the members of our City Council, are all firmly committed to protecting all members of our community from the misuse of this technology, and to maintaining transparency in respect to all steps in the process of its implementation. I am also confident that if any misuse does come to light, the Chief and you will immediately investigate the circumstances and take appropriate action. I applaud you for examining this important issue and for your commitment to public safety. I urge you to agree that our police department needs to continue to be equipped with and to have access to this vital technology that helps solve and prevent crimes and save lives, thereby safeguarding the welfare and property of all who are present in our community. Sincerely, Evan G. Reade Sharon Ct. Palo Alto From:Hamilton Hitchings To:Council, City Cc:Reifschneider, James; Perron, Zachary Subject:ALPR Options for City Council Date:Tuesday, May 26, 2026 12:53:48 PM Attachments:ALPR Options for Palo Alto City Council v4 2026-5-26.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Attached are options for City Council to consider in-between keep the status quo and ban ALPRs. Hamilton Hitchings ALPR Analysis for Palo Alto City Council I support using ALPR technology for legitimate public safety purposes, especially real-time alerts for stolen cars, AMBER Alerts, Silver Alerts, and vehicles tied to serious crimes. The biggest privacy risk is not the real-time hot-list alerts. It is the historical database of where ordinary residents drive, and who can search it. Flock has shown that it is not a trustworthy custodian of this data. In Palo Alto, unapproved “Nationwide Lookup” and “Statewide Lookup” features were enabled for roughly two years without informing us. Flock has since turned these off. But in August 2025, an Illinois state audit found that Flock gave the U.S. Customs and Border Protection access to Illinois ALPR data, violating state law and prompting Evanston to shut down its cameras and terminate its contract. In addition, rogue officials and bay area police departments have shared data with Federal agencies including SFPD, Marin PD, Contra Costa departments, Gilroy PD and possibly Oakland PD in violation of California state law. Currently the level of regional Palo Alto license plate data sharing is enormous. In March 2026, there were about 200,000 searches of Palo Alto license plate data by regional law enforcement agencies, including 46K by CHP and 29K San Francisco Police, compared with about 1,000 by Palo Alto Police. The results of these searches are saved for years. That is not targeted local policing; that is a regional surveillance dragnet. Lastly there is the risk of Federal agencies subpoenaing our license plate data via national security letters without our local police department being informed. Here are some policy options: 1. Disable sharing of Palo Alto Flock data with outside agencies, except through a written request reviewed by a PAPD captain and run by a trained Palo Alto officer. This would likely reduce searches of Palo Alto data by roughly 100 times, while still allowing legitimate assistance in serious cases. Unfortunately, this will reduce PAPDs collaboration with other departments who use Flock for their joint crime solving. 2. Disable storing Flock historical data by purging the data within minutes of uploading it, as New Hampshire requires by law. I do not recommend this since it removes a powerful investigative tool for PAPD. 3. Evaluate Flock replacements to find a preferred reputable vendor in collaboration with Mountain View and Santa Clara County and other local agencies displeased with Flock. Switch to a secure architecture: either a private cloud controlled by the city, or a local enterprise system hosted on city-owned infrastructure. Reputable vendors worth evaluating include Genetec AutoVu, LensLock / PlateSmart, Rekor, Leonardo ELSAG, and Axon. The goal should be to keep the useful public safety tools like real-time alerts, sharply limit mass historical searches, and over the long-term switch to a trustworthy vendor on a secure architecture. June 1, 2026 Study Session:Flock Automated License Plate Recognition (ALPR) Technology www.PaloAlto.gov Flock ALPR – Study Session •ALPR Overview •PAPD Use •Legal Considerations •Flock Timeline •Flock Updates •PAPD Updates •Regional Use of Flock •Contract Status •Independent Police Auditor Report 2 Flock ALPR Overview – What is it? 3 Automated License Plate Recognition (ALPR) technology uses a combination of cameras and computer software to scan the license plates of passing vehicles. These computer-readable images allow law enforcement to compare plate numbers against plates of wanted vehicles and vehicles associated with wanted persons, missing persons, etc. Flock ALPR Overview – What Information is Captured? •A fixed ALPR system is designed to capture: •license plate; •vehicle characteristics; •the date, time, and location •Fixed ALPR cameras placed in high-volume traffic areas, with an emphasis on ingress and egress 4 1 Flock ALPR Overview– What Information Is Not Captured? •PAPD has located and oriented its ALPR cameras specifically to capture images of rear license plates, not vehicle occupants or pedestrians •The Flock Falcon ALPR system does not capture the name, address or personal information of the owner or occupants •According to Flock and our experience with the system the Flock Falcon ALPR system does not use facial recognition or log human characteristics (e.g., age, race, gender) 5 Flock ALPR Overview– Uses & Benefits BENEFITS ✓Real-time Alerts ✓Deterrence ✓Increased Efficiency ✓Force-multiplier ✓Solve Crimes Already Committed ✓Regional Coordination ✓Network Effect USES •Proactive real-time alerts •Reactive (Investigative) •Searchable database •Overlay data with sharing agencies 6 PAPD Use of Flock - Successes Criminal Cases •Located and arrested suspects in Palo Alto and East Palo Alto armed robberies •Located and arrested suspect in shooting homicide in another Bay Area city •Identified, located and arrested suspects responsible for dozens of burglaries in multiple bay area cities (including multiple overnight, occupied residential burglaries in Palo Alto) •Intercepted numerous known organized retail theft suspects en route to our commercial areas. Non-criminal Cases •Safely located multiple missing, endangered seniors with cognitive issues •Safely located a missing, suicidal teen Statistics •130+ cases where Flock data has played an important role since 2024 •13% reduction in residential burglaries 2025-2026 YTD •24% reduction in auto burglaries 2025- 2026 YTD •27% reduction in total thefts annually (in dollars) since 2024; 64% since 2023 7 ALPR – Legal Considerations Palo Alto Municipal Code •Council approved Surveillance Use Policy specific to Flock ALPR State Law •Prohibits out of state sharing •Criminal penalties for unauthorized access or use 8 ALPR – Surveillance Use Policy Components Access •Need to know and right to know only; •Individual log-in (with dual authentication) and purpose required; •Agency controls with whom data is shared; •Local law enforcement only •Via individual MOU Data Retention •Automatically purged after 30 days Auditing •Queries logged and auditable •Compliance officer 9 1 Flock ALPR – Timeline •April-November 2023 – First PAPD Flock cameras (20) installed •Mid-2023 – Flock activated a “Nationwide Lookup” feature for all customers •feature allowed users to search a combined dataset of all agency users and 6000+ cameras •Only full 7-digit license plates could be searched (e.g., no partial plates or vehicle descriptions) •Did not allow targeted searches of any specific agency •October 2024 – Flock disabled Nationwide Lookup feature for PAPD (all CA users disabled by early 2025) •January-March 2025 – (10) Additional PAPD Flock cameras installed •December 2025 – PAPD first learned of activation of Nationwide Lookup feature 10 1 Flock ALPR – Nationwide Lookup Impact •PAPD data was included in overall nationwide dataset •No PAPD data was received by any out of state or federal agency •PAPD review of network audit logs showed: •No searches performed by ICE, CBP, or DHS for any purpose •No searches by any agency appear to be associated with immigration or reproductive care enforcement •No targeted searches of Palo Alto data by out of state or federal agencies •No searches by out of state or federal agencies after feature was disabled in October 2024 11 •Increased staffing and resources, with emphasis on state-specific legal compliance •Improved search audit functionality (e.g., ease of use, customization) •Improved product update communication •User setting updates logged and communicated to customer •Added Restrictions •Disabling the “Nationwide Lookup” feature for all California agencies •Prohibiting any sharing agreements as between California and non-California agencies •Filtering and blocking, by keyword, prohibited searches involving immigration or reproductive healthcare •Requiring a documented FBI NIBRS case type for all searches Updates to Flock Policies, Procedures, and Features 12 •Augmented organization (PAPD user) audits with network (outside agency user) audits •Increased frequency of audits (monthly versus quarterly) •Only local agency to publish: •Monthly organization and network audits •All historical organization and network audits (2023-present) Updates to PAPD Auditing and Transparency 13 •More than 300 law enforcement agencies in California currently use Flock.No other fixed ALPR vendor has any significant market share. •Since 2025, 9 CA agencies (3% of CA agency users) have discontinued use of Flock. •Nearly every Santa Clara County and Bay Area law enforcement agency currently uses Flock ALPR cameras •Numerous Bay Area cities have recently re -examined their use of Flock •Councils in San Jose, Sunnyvale, Los Altos, East Palo Alto, San Francisco, Oakland, Richmond, and Berkeley have voted to continue their use of Flock. •Santa Clara, Los Gatos-Monte Sereno, Campbell, Milpitas, Gilroy, Morgan Hill, Menlo Park, Atherton, and Redwood City have continued their use without disruption. •Mountain View, Los Altos Hills, and Santa Cruz have discontinued use •Santa Clara County halted a planned Flock deployment Regional Use of Flock 14 Santa Clara County Use of Flock Agency ALPR Flock Campbell PD ✓✓ Gilroy PD ✓✓ Los Altos PD ✓✓ Los Gatos-Monte Sereno PD ✓✓ Milpitas PD ✓✓ Morgan Hill PD ✓✓ Mountain View PD No No Palo Alto PD ✓✓ San Jose PD ✓✓ Santa Clara PD ✓✓ Santa Clara County Sheriff No No* Sunnyvale DPS ✓✓ 15 *Never had Flock cameras Flock ALPR – Current Contract Status •5-year contract with Flock Safety (thru December 6, 2029) •Total estimated remaining costs of deployment: •$93,500 annually in FY 27, FY28, FY29 •One-third of costs in FY27 and FY28 covered by Organized Retail Theft grant funding •Termination Options •Termination-for-convenience with:30 days notice, $500/camera removal fee,Prorated balance of subscription cost refunded •Termination for cause:Notice and opportunity to remedy alleged breach 16 •Flock has assured staff that it will fully cooperate with any audit and has consistently inquired re the status of the city’s audit since first discussed in January •City auditor unable to perform audit due to perception of conflict •Independent Police Auditor (OIR Group) to produce a report containing: •an operational assessment of Flock’s policies and procedures around security, transparency, sharing compliance, and reporting of system features and changes •an assessment of PAPD’s internal policies and procedures with an eye toward areas where it may be able to do better Flock ALPR – IPA Report 17