Governance, Cost, and Oversight Review of Flock Safety ALPR Deployment in Lincoln, California
Prepared for Public Review and City Council Consideration Prepared by:
Jake Poulsen
Lincoln Resident
January 13, 2026
Purpose:
This report evaluates the governance, cost, transparency, and oversight of the Lincoln Police Department's use of Flock Safety automated license plate reader technology, based on publicly available records and records currently being requested through applicable public disclosure laws.
Table of Contents:
1. Executive Summary
2. Program Overview
3. Cost, Budget Impact, and Records Requests
4. Oversight and Audit Practices
5. Scope of Coverage and Public Notice
6. Constitutional and Fourth Amendment Considerations
7. Recommendations
8. Conclusion
9. Appendices
Disclaimer:
This report relies on publicly available documents, correspondence, and statements, as well as records currently being requested through applicable public disclosure laws. It does not allege misconduct by any individual or agency.
1. Executive Summary
This report reviews the governance, cost, transparency, and oversight of the Lincoln Police Department's use of Flock Safety automated license plate reader technology. The system continuously collects vehicle location data in public space and makes that data searchable by authorized users within Lincoln Police Department and numerous external law enforcement agencies.
Based on publicly available records, transparency portal disclosures, and direct correspondence with Lincoln Police Department staff, this report finds that the public currently lacks meaningful visibility into how the system operates in practice. Specifically, residents cannot independently verify how often searches are conducted, how audit reviews are performed, how misuse is identified or addressed, or how frequently outside agencies access locally collected data. Camera locations are not publicly disclosed, limiting public awareness of where and when vehicle monitoring occurs.
The total financial scope of the program is also unclear. While subscription costs are documented, a consolidated accounting of total program cost, including installation, maintenance, training, staff time, and administrative oversight, is not publicly available in a single location. Comparable jurisdictions show that ALPR programs can scale quickly and result in substantial recurring expenses.
This report does not allege misconduct by any individual or agency. Instead, it identifies structural governance gaps that rely almost entirely on internal controls without independent verification or routine public reporting. Given the scale, sensitivity, and networked nature of the system, these gaps present risks to public trust, fiscal oversight, and long term accountability.
The recommendations that follow focus on transparency, cost clarity, access limitation, independent oversight, and formal review prior to any renewal or expansion of the program.
2. Program Overview
Flock Safety is a vendor-provided automated license plate reader system that captures images of vehicles in public space and converts them into searchable records containing license plate numbers, date, time, and location. The system operates continuously once installed and stores data for a retention period set by the customer agency.
The City of Lincoln currently operates 23 Flock Safety cameras installed in public rights of way.
Data is retained for 30 days and is accessible to sworn officers, dispatchers, and a crime analyst. Supervisors are able to audit user activity internally. Lincoln Police Department also participates in interagency data sharing arrangements that allow authorized users from numerous external law enforcement agencies to query locally collected data.
Details regarding audit frequency, audit standards, misuse thresholds, and corrective actions are governed internally and are not publicly disclosed.
3. Cost, Budget Impact, and Records Requests
Publicly available records show that Lincoln's Flock Safety program involves recurring subscription costs tied to camera count and contract duration. However, a consolidated public accounting of total program cost is not currently available. This includes installation, maintenance, training, system administration, staff time, and policy oversight.
Without a single consolidated cost summary, residents and elected officials cannot easily evaluate the true financial impact of the program or assess how costs may change over time.
As a comparison, Placer County Sheriff's Office approved a two year Flock Safety agreement totaling $238,600 in March 2023. In November 2024, the contract was amended by $91,000, bringing the total to $329,600 to support expanded deployment and continued service. These increases were directly tied to additional cameras and subscription costs.
While Lincoln's deployment differs in scale, this example demonstrates that ALPR programs represent significant and growing financial commitments. Without transparent cost reporting, long term budget implications are difficult to assess prior to renewal or expansion.
4. Oversight and Audit Practices
Lincoln Police Department policies require users to state a purpose for each search and allow supervisors to audit system activity. However, these oversight mechanisms are entirely internal. Audit frequency, standards, findings, and corrective actions are not disclosed publicly, and there is no independent or civilian review process.
Camera locations are not publicly disclosed. As a result, residents cannot determine where vehicle monitoring occurs or evaluate the geographic scope of the program. Available public information suggests camera placement emphasizes coverage of major travel routes, which may result in broader monitoring patterns than narrowly targeted deployments.
Transparency portal data also shows that Lincoln participates in extensive interagency data sharing, allowing hundreds of external agencies to query locally collected data. While such sharing may serve investigative purposes, it significantly expands access beyond the originating agency without corresponding public reporting on usage volume or oversight outcomes.
Taken together, these practices require residents to rely on internal assurances without independent verification. For a system that continuously collects location linked data and shares it across a large network, this governance model presents clear transparency and accountability limitations.
5. Scope of Coverage and Public Notice
Camera locations are not publicly disclosed, which prevents residents from understanding the geographic scope of vehicle monitoring. While the City may view location secrecy as a security measure, the result is that the public cannot determine when or where data collection occurs or evaluate whether coverage is narrowly tailored or functions as perimeter based monitoring.
Without location level transparency or standardized reporting, elected officials and residents lack the information necessary to assess proportionality, effectiveness, or risk.
6. Constitutional and Fourth Amendment Considerations
The use of automated license plate reader technology also raises constitutional considerations under the Fourth Amendment, which protects against unreasonable searches and seizures.
While license plates are visible in public, courts have increasingly recognized that the aggregation of location data over time can implicate reasonable expectations of privacy, even when individual data points are collected in public space.
ALPR systems differ from traditional observation in that they enable continuous, automated, and retrospective tracking of vehicle movements at scale. When combined with long retention periods, advanced search capabilities, and broad interagency access, these systems can allow detailed reconstruction of an individual's movements without judicial oversight.
Recent court decisions have emphasized that prolonged or comprehensive location tracking may require heightened safeguards, particularly in the absence of warrants, individualized suspicion, or strict use limitations., particularly when conducted without a warrant, individualized suspicion, or clear limitations on use. While this report does not allege unconstitutional conduct by the Lincoln Police Department, the absence of independent oversight, limited public reporting, and expansive data sharing increase the risk that ALPR data could be used in ways that raise Fourth Amendment concerns.
Robust governance, access limitations, audit transparency, and clear usage boundaries are therefore not only matters of public trust, but also important safeguards to reduce legal and constitutional risk to the City. Failure to address these issues prior to renewal or expansion may expose the City to future litigation, evidentiary challenges, or civil rights claims as legal standards continue to evolve.
7. Recommendations
Based on the findings in this report, the following actions are recommended to strengthen transparency, accountability, and fiscal oversight of the City of Lincoln's use of Flock Safety ALPR technology:
• Implement Routine Public Reporting on System Use
Require standardized public reports at regular intervals detailing usage metrics, audit activity, interagency access volume, and compliance reviews, beyond high level transparency portal summaries.
Require Consolidated Public Cost Reporting
Direct staff to publish an annual, publicly accessible accounting of total ALPR program costs, including subscriptions, installation, maintenance, training, system administration, staff time, and any related overhead.
• Establish Independent or Civilian Oversight
Create an independent review mechanism for ALPR audits and policy compliance, rather than relying exclusively on internal supervisory review. • Limit Interagency Access by Default
Require formal justification, documentation, and periodic review for external agency access to locally collected ALPR data, with access minimized unless clearly necessary. • Improve Public Notice of Program Scope
Provide generalized public disclosure regarding the methodology and scope of camera placement and coverage areas to allow residents and elected officials to understand the geographic reach of the program without compromising specific investigative details. • Condition Contract Renewal or Expansion on Review
Require formal City Council review and approval prior to any renewal, expansion, or material modification of the ALPR program or vendor agreement. • Pause Expansion Pending Records Review
Defer any program expansion until outstanding public records requests related to cost, governance, audit practices, and data sharing have been fulfilled and evaluated.
8. Conclusion
The use of automated license plate reader technology represents a significant policy choice with long term implications for public trust, fiscal responsibility, and data governance. While Flock Safety provides investigative capabilities that may support law enforcement objectives, the system also enables continuous collection and broad sharing of location linked vehicle data.
This review finds that current governance relies primarily on internal controls with limited public visibility into cost, oversight practices, audit outcomes, and interagency access. Without consolidated reporting and independent review, residents and elected officials are unable to fully evaluate proportionality, effectiveness, or risk.
The recommendations outlined in this report are intended to strengthen transparency and accountability without alleging misconduct or undermining legitimate law enforcement activity.
Addressing these governance gaps prior to renewal or expansion will better position the City to make informed decisions, reduce institutional risk, and maintain public confidence in the responsible use of surveillance technology.
9. Appendices
Appendix A: Source Documents and Records
This report was compiled using publicly available documents, official correspondence, and records obtained or requested through public disclosure processes. These materials include, but are not limited to:
• Lincoln Police Department ALPR and related policies
Flock Safety Transparency Portal data for Lincoln Police Department Correspondence with Lincoln Police Department personnel City and county contract records related to Flock Safety ALPR services Public meeting agendas and minutes referencing ALPR deployment Additional records related to cost, governance, audit practices, and data sharing are currently being requested through applicable public records laws. Any responsive documents received will be added to the public record.
Appendix B: Video Sources and Public Statements
The following videos and public resources are included to provide additional context and independent reporting related to automated license plate reader systems. They are not primary evidence for this report, but illustrate recurring concerns raised nationally regarding oversight, false positives, and governance.
YouTube - Investigative reporting on Flock https://youtu.be/uB0gr7Fh6lY?si=Tf025xDC Safety security vulnerabilities mooV QYa
YouTube - Reporting on alleged Flock https://youtu.be/vU1-uiUIHTo?si=8KBsBn92t Safety data exposure incidents 26shtlE
YouTube - "Hello police? I'd like to report a https://youtu.be/5aBagdonnXs?si=HOWnFE journalism." UwtQ7Lzxpd
deflock.me - Public ALPR resource https://deflock.me
Appendix C: Comparative Legal and Regulatory Developments This appendix provides comparative context regarding legal, regulatory, and civil liability developments related to automated license plate reader (ALPR) systems in other jurisdictions.
The items listed below illustrate how courts, regulators, and civil rights organizations are increasingly scrutinizing ALPR deployment, governance, data sharing, and constitutional implications. Inclusion of these examples does not imply factual similarity to the City of Lincoln's program.
Item Why it matters Link
California Attorney State lawsuit alleging https://oag.ca.gov/news/press-rele General v. City of unlawful sharing of ALPR ases/attorney-general-bonta-sues- El Cajon (2025) data with federal and el-cajon-illegally-sharing-license-pl out-of-state agencies. ate-data-out
Demonstrates regulatory
enforcement risk and limits
•
•
Item Why it matters Link
on interagency data sharing
under California law.
EFF and ACLU Civil liberties lawsuit alleging https://www.eff.org/press/releases/l lawsuit challenging warrantless ALPR searches awsuit-challenges-san-joses-warra San José ALPR violate California ntiess-alpr-mass-surveillance use (2025) constitutional privacy
protections. Illustrates
evolving legal theories
around mass location
surveillance.
Norfolk, Virginia Federal litigation challenging https://ij.org/press-release/public-in federal lawsuit over the scale and data-sharing terest-law-firm-responds-to-flock-s Flock ALPR practices of a Flock-operated afety-pausing-federal-access-to-lic network (2025) ALPR network, including ense-plate-reader-cameras/ concerns regarding federal
access.
San Francisco Reporting on a lawsuit https://sfstandard.com/2025/12/29/ lawsuit over SFPD challenging the san-francisco-police-flock-license-p Flock ALPR constitutionality of a citywide late-cameras-lawsuit/ network 2025) Flock ALPR deployment,
illustrating litigation exposure
in large jurisdictions.
Aurora, Colorado Demonstrates how ALPR https://www.pbs.orq/newshour/nati settlement after misidentification can escalate on/family-of-black-girls-handcuffed- mistaken into high-risk encounters and held-at-gunpoint-by-colorado-polic stolen-vehicle stop result in significant civil e-reach-1-9-million-settlement (2024) liability.
Sugar Land, Texas Recent reporting on https://www.chron.com/news/houst Flock ALPR expansion of Flock cameras on-texas/article/sugar-land-housto expansion amid alongside growing public n-surveillance-cameras-21291218. scrutiny (January scrutiny and mention of a php
2026) Texas state investigation.
Appendix D: Illustrative Camera Location Screenshots
This appendix contains illustrative screen captures from publicly accessible mapping tools that depict commonly reported ALPR camera locations within and around the City of Lincoln. These images are provided for contextual purposes only and are not intended to represent official, complete, or current camera placement. Camera locations are not publicly disclosed by the City, and no claim is made regarding the accuracy or completeness of the locations shown. i citers
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