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Agenda Report

Rancho Palos Verdes City Council
August 18, 2026

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Agenda Report
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August 18, 2026
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Rancho Palos Verdes City Council
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Text extracted from the city's file for reading and search. Open the original on rpv.granicus.com. That file is the official record.

CITY COUNCIL MEETING DATE: 08/18/2026
AGENDA REPORT AGENDA HEADING: Regular Business
AGENDA TITLE:

Consider a report on the use of Automated License Plate Reader camera systems within the City.

RECOMMENDED COUNCIL ACTION:
1) Receive and file a report on the use of Automated License Plate Reader (ALPR) cameras located in certain neighborhoods and in select public rights-of-way throughout the City; and,
2) Receive and file a presentation from Flock Safety regarding the use, data retention, and privacy policies of their ALPR camera systems operated in certain City neighborhoods.

FISCAL IMPACT: None
Amount Budgeted: N/A
Additional Appropriation: N/A
Account Number(s): N/A
ORIGINATED BY: Allison Don, Sr. Administrative Analyst, Public Safety AD REVIEWED BY: Jennifer Schmid, Public Safety Manager JS
Catherine Jun, Deputy City Manager CJ
APPROVED BY: Ara Mihranian, AICP, City Manager
ATTACHED SUPPORTING DOCUMENTS:

A) February 2024 City Council Staff Report (Linked)
B) LASD County Sheriff’s Department’s (LASD) ALPR Privacy Policy (Page B-1) C) Letter to Senator Allen and Asm. Al Muratsuchi re: Senate Bill 34 (Page C-1) BACKGROUND:

During the July 7, 2026 City Council meeting, Mayor Seo requested Staff return with a report that provides an overview of ALPR camera systems operating in the City. The request stems from an increase in inquiries from residents, neighborhood groups, and the general public regarding the presence and use of ALPR cameras in the City, with an emphasis on Flock Safety systems (Flock) that are utilized by certain neighborhoods to 1 CITYOF RANCHO PALOS VERDES
deter crime and provide vehicle license plate information to authorized law enforcement agencies for use during criminal investigations. In particular, questions have been raised regarding the purposes for which the systems are used; how license plate data is accessed, stored, and utilized by authorized groups; and potential implications for privacy protections.

This staff report provides general information about the role of ALPR systems in the City, while addressing the aforementioned issues.

The City has also invited a representative from Flock to present additional information about their ALPR systems to the City Council tonight. The representative will address the following topics and will be available to answer questions from the Council:
• Overview of how Flock cameras operate and how they collect and process data. • Entities or users authorized to access Flock camera footage and data, including data retention and storage policies.
• Flock’s response to privacy concerns raised by the public. • Discussion of how Flock has prepared smaller scale operators such as neighborhoods and homeowners associations (HOAs) to comply with all applicable state and federal regulations and court rulings. • Specific, actionable steps that users can take to bring their ALPR systems into compliance with all applicable regulations
Overview of ALPR Technology
Before providing information about ALPR camera systems, they must be distinguished from traditional, home surveillance cameras that the public is more likely to be familiar with. ALPR cameras and home surveillance cameras are both tools used to combat crime, but they serve different purposes, utilize different technologies, have varying costs, and are subject to different data and privacy regulations. “Security camera” is sometimes used as an umbrella term for both types of cameras. Their differences are outlined below:

ALPR Cameras Surveillance Cameras
Summary
ALPRs scan license plates, and
computer software compares
them against law enforcement
databases that have logged
those plates for various
purposes including identifying
stolen vehicles, Amber Alerts,
missing persons, and felons.

Surveillance cameras are generalpurpose video recording devices designed to provide a visual feed
and detect broad motion around
property.

Primary Uses
Support law enforcement efforts
such as identifying stolen
vehicles or assisting with
investigations tied to vehicles
General crime deterrence,
monitoring property/visitors,
package tracking, and home or
business monitoring.
2 ALPR Cameras Surveillance Cameras
Data and
Privacy
Requirements
Strict state data
retention/deletion timelines,
access logging, legal warrant
requirements for access, and
sharing bans with outside
agencies.

Less strict regulations on data
retention and sharing. Video
recording is generally permitted in
public areas if it respects
reasonable expectations of
privacy (e.g. No
bedrooms/bathrooms). Audio
recording faces strict state
regulations.

Major
Companies in
the Market
Motorola Solutions (Vigilant
Solutions), Flock Safety,
Leonardo (ELSAG), Axis
Communications, and Plate
Recognizer.

Ring, Blink, Google Nest,
SimpliSafe, Arlo, and Reolink.

In summary, an ALPR camera system is specifically designed to identify vehicle license plates and make that information searchable, often times by authorized law enforcement agencies to support ongoing investigations. This ability to collect, retain, search, and share license plate information is what distinguishes ALPR technology from conventional surveillance cameras, which law enforcement agencies do not have immediate access to, and subjects its use to more specific data security, access, retention, and privacy requirements under State law.

Within Rancho Palos Verdes, ALPR technology is generally used through two distinct structures, each with different ownership, access, and operational responsibilities.

1. The Peninsula-wide Vigilant/Motorola ALPR camera system is jointly funded by the four Peninsula cities and is accessed only by their respective law enforcement agencies (LASD and Palso Verdes Estates Police Department (PVEPD)); no other entity or individual (including the participating cities) may access that system’s data or footage.

2. Flock Safety ALPR camera systems are independently leased or purchased by certain neighborhoods and HOAs, some of which receive partial financial assistance through the City’s Public Safety Reimbursement Grant Program.

While both camera systems collect license plate information for public safety purposes, the entities that contract for, operate, and access the systems differ significantly. These distinctions are important because, as discussed below, State law places specific responsibilities on the entities that operate ALPR systems or access the information they collect.
3 DISCUSSION:

State Law Governing ALPR Data and Privacy
California Senate Bill 34 (SB 34) of 2015, codified under California Civil Code Title 1.81.23 § 1798.90.5 et seq. in 2016, regulates how ALPR systems collect, store, and manage vehicle data in California. The core requirements of SB 34 include:

1. Usage and Privacy Policy: ALPR Operators must adopt and post a formal, written policy detailing data collection, use, maintenance, sharing, and commitment to individual privacy.

2. Data Security: Operators must implement reasonable security procedures and practices to protect collected plate data from unauthorized access, destruction, modification, or disclosure.

3. Restricted Data Sharing: Sharing or selling ALPR data to non-law enforcement entities or out-of-state/federal agencies is strictly limited or prohibited unless meeting specific lawful criteria.

4. Access Logging: Operators must maintain detailed logs tracking who accesses the ALPR database and for what official purpose.

5. Data Breach Notification: SB 34 expanded California's data breach law so that an individual’s license plate data—when tied to an ALPR system—counts as personal information triggering breach notifications.

The statute defines and distinguishes between:
• ALPR Operators – Those who run or maintain the system • ALPR End-Users – Those who are authorized to search or view the data Furthermore, the statute requires a usage and privacy policy be implemented. That policy—which must be made publicly available in writing—must describe how ALPR data will be used, stored, managed, and shared.

The February 2026 second appellate court ruling in Bartholomew v. Parking Concepts, Inc. shifted how this law is enforced, stating that a failure to implement or publicly post a specific ALPR privacy policy is itself a legally actionable "harm" that carries financial penalties. The court ruled that individuals have a statutory right to know who collects their data. Failing to post a policy directly violates that right, meaning plaintiffs do not need to show an actual data breach, misuse, or monetary loss to sue for the penalty. The court affirmed there is no small operator exemption and no legal requirement for a plaintiff to give a business a warning or "notice to cure" before filing a lawsuit. 4 Five months later, however, a different appeals court (fifth appellate court) in Mata v.

Digital Recognition Network, Inc. (DRN) reached the opposite conclusion, finding there must be a showing of concrete harm from a failure to implement or publicly post a specific ALPR privacy policy, such as unauthorized access, unauthorized use, or a data breach.

In Mata, the court ruled that one cannot sue under California’s ALPR law simply because one failed to implement or publicly post a specific ALPR privacy policy. There must be evidence of actual “harm” meaning something real and concrete—not just that one’s license plate data was collected or that there was a technical failure to implement or publicly post a specific ALPR privacy policy. Mata explained that the kinds of harm the Legislature had in mind include instances such as one’s ALPR data being accessed by someone who shouldn’t have it, used in an unauthorized way, or exposed in a data breach. These two 2026 California appellate decisions seemingly point in opposite directions leaving the law unsettled for now.

Flock Cameras in Neighborhoods
The City estimates that ten neighborhoods who received financial assistance through the City’s Public Safety Reimbursement Grant Program contracted with Flock to install 19 ALPR cameras. The number provided represents Staff’s best estimate based on current available information and should not be considered a comprehensive count of all active Flock Cameras within the City. These systems are generally installed at neighborhood entrances or other strategic locations to capture license plate information associated with vehicles entering or traveling through a neighborhood. These cameras are contracted for and managed by the participating neighborhood or HOAs rather than the City.

Flock provides its ALPR systems through annual subscription agreements rather than through the sale of camera equipment. The subscription generally includes the camera hardware, installation, maintenance, and access to Flock’s cloud-based software.

Neighborhood Flock end users are able to access information captured by their cameras.

The Los Angeles County Sheriff’s Department (LASD) may also access Flock data for investigations and law enforcement purposes to identify whether any vehicle associated with a law enforcement “hot list” is detected. These neighborhoods do not have access to these LASD law enforcement alerts.

Lastly, additional information about the type of activity that the cameras record, the data retention length, and privacy policies will be presented in detail by Flock’s representative tonight.

As discussed above, SB 34 requires ALPR Operators and End-users to implement a usage and privacy policy. Thus, the recent Bartholomew ruling has increased the legal risk to HOAs and other entities who may or may not have been informed by their ALPR company of their requirement to adopt and post a usage and privacy policy. Staff have recently become aware of at least two lawsuits filed against HOAs in Rancho Palos Verdes related to ALPR cameras.
5 Public Safety Reimbursement Grant Program
The Public Safety Reimbursement Grant Program seeks to enhance public safety by providing partial financial assistance to individuals and neighborhoods for the acquisition of safety-enhancing tools and technologies, such as security and ALPR cameras. This program has been in place since 2016.

The City has reimbursed neighborhoods (including HOAs) for both surveillance and ALPR cameras. Individuals are eligible for reimbursement of 50% of eligible costs, up to $100, while neighborhoods consisting of five or more individuals are eligible for reimbursement of 50% of eligible costs, up to $2,500.

The City’s Public Safety Reimbursement Grant Program maintains a distinction between the City’s role in providing partial financial assistance for these cameras and the participant’s responsibility for acquiring, installing, and operating the security camera system. The Program’s Distinction of Responsibilities advises participants that the neighborhood is the primary signatory of the security camera system, and the City only provides partial grant funding to assist with the acquisition.

Vigilant/Motorola Cameras in Palos Verdes Peninsula
In 2016, the Palos Verdes Peninsula (Peninsula) cities of Rancho Palos Verdes, Palos Verdes Estates, Rolling Hills, and Rolling Hills Estates established a regional effort to combat crime through the purchase and installation of ALPR cameras placed at strategic main ingress and egress locations throughout the Peninsula. The establishment of the ALPR camera system involved the development of a cost-sharing formula and Memorandum of Understanding (MOU) to fund the joint project. The ALPR cameras were purchased from Vigilant Solutions, which has since been acquired by Motorola Solutions.

In 2024, the Peninsula cities replaced several of the ALPR cameras in the system, which had reached their end of useful life (Attachment A).

The images captured by the cameras are accessed and processed by the law enforcement agency for each city (LASD for Rancho Palos Verdes, Rolling Hills Estates, and Rolling Hills, and the Palos Verdes Estates Police Department for Palos Verdes Estates). Cities do not have any authorized access to view the camera or obtain any footage.

Under Civil Code § 1798.90.5, SB 34’s disclosure and privacy policy obligations attach to “ALPR operators” and “ALPR end-users.” In the opinion of City staff and legal counsel, the City of Rancho Palos Verdes is neither an ALPR operator nor an ALPR end-user, since it cannot access any data from the cameras. Motorola Solutions has confirmed that City of Rancho Palos Verdes staff have never had access to the license plate data captured by Vigilant/Motorola ALPR cameras nor the software used to view and analyze them.

Indeed, LASD maintains an ALPR Privacy Policy, which establishes rules for the collection of ALPR data, use of ALPR technology, data retention and destruction, 6 information sharing, and oversight and accountability (Attachment B). Notable features of the policy include:
• Only approved LASD staff – with successful background checks, appropriate security clearance, and ALPR training – are allowed to access ALPR data. • Data can only be accessed for legitimate law enforcement purposes. Data may not be used for any non-work-related purpose.
• ALPR data is not shared with any contracted, commercial, or private entity. • All access to the system is logged. An audit trail that identifies each individual who accessed ALPR information, the nature of the information requested and/or accessed, and the specific purpose, is retained by LASD for a minimum of two years.
• ALPR data is permanently deleted after five years unless it is part of a criminal case file.
• Inter-agency data sharing may only occur upon the execution of an inter-agency agreement by which each agency agrees that all ALPR data will be gathered, accessed, utilized, and disclosed in accordance with applicable law. Notably, SB 34 prohibits data sharing with out-of-state or federal agencies, including ICE.

LASD’s policy appears to comply with all applicable federal, state, and county laws including SB 34 (California Civil Code sections 1798.90.5 – 1798.90.55). In the interest of clarity and transparency, staff have added this information to the City’s website.

ADDITIONAL INFORMATION:

Education and Advocacy
In an effort to be a trusted partner, City staff have been researching the issue, posing questions to Flock Safety and Motorola Solutions, forwarding resources to HOA members, and advocating for changes at the State level. On August 4, 2026, the City sent a letter to State Senator Ben Allen and State Assemblymember Al Muratsuchi requesting that the legislature review SB 34 and the Bartholomew decision and consider remedies to the unintended consequences on HOAs (Attachment C).

Flock Safety Representative
Representatives from Flock Safety will be attending tonight’s meeting to provide a presentation on their camera system. The City Council is being asked to grant additional time to the representatives for their presentation.

CONCLUSION:

The City Council is being asked to receive and file this report and the presentation by Flock Safety. The report provides an overview of the ALPR systems operating within the City, applicable data use and privacy requirements, and other pertinent information.

ALTERNATIVES:
7 The following alternative actions are available for the City Council’s consideration:

1. Do not approve one or more recommendations and direct staff accordingly, which may include requests to return with additional information or updates.

2. Continue the agenda item to a date certain or uncertain with or without discussion.

3. Take other action.
8 The Los Angeles County Sheriff’s Department’s
Automated License Plate Recognition (ALPR) Privacy Policy The purpose of this privacy policy is to ensure that all conduct of the Los Angeles County Sheriff’s Department (Department) and its personnel related to the capture, use, retention, and dissemination of information obtained through the use of the Automated License Plate Recognition (ALPR) System complies with all applicable federal, state, and local laws.

ALPR technology is a valuable tool for law enforcement and when used appropriately serves to enhance public safety. As with any law enforcement capability, the technology must be used in a manner that is consistent with the United States Constitution, including the Fourth Amendment, and other applicable statutory authorities.

The Department acknowledges and fully intends to comply with the array of statutes, regulations, and policies that guide law enforcement on how it may and may not collect, retain, and disclose data, as well as requirements regarding notification in the event of a data breach.

I. Authorized Purposes for Use of ALPR Technology
The Department intends to the use ALPR technology for the following public safety purposes:
 Investigation for prosecution or exoneration of suspected criminal (including terrorist) incidents.
 Identification and/or location of wanted persons.
 Enforcement of sanctions, orders, or sentences.
 Crime prevention/general law enforcement purposes.
 Crime analysis.
 Investigatory leads in subsequent investigations.

II. Persons Authorized to Use or Access ALPR Technology/Data Designated personnel appropriately trained on use of ALPR may gather data using ALPR technology.

Information collected via ALPR technology will be analyzed only by qualified individuals who have successfully completed a background check, have appropriate security clearance and have been approved and trained accordingly.

Sworn personnel or authorized civilian personnel (role-based such as crime analyst) will have general user access to the LASD ALPR database, as appropriate, to query information.

Sworn personnel or authorized civilian personnel (role-based) of the Advanced Surveillance and Protection Unit (ASAP) or Sheriff’s Data Network (SDN) Unit will have administrative user access to the LASD ALPR database, as appropriate, to control:

B-1
 The information to which a particular group or class of users can have access based on the group or class.
 The information a class of users can access, including specific sites and/or data being utilized in specific investigations.
 Sharing capabilities with other law enforcement agencies.  Any administrative or functional access required to maintain, control, administer, audit, or otherwise manage the data or equipment.

III. Guidelines Regarding Appropriate Use
ALPR data must be collected in a fair and lawful manner in the routine duties of law enforcement.

LASD will not seek or retain information about individuals or organizations solely on the basis of religious, political, or social views or activities, participation in a particular noncriminal organization or lawful event, or race, ethnicity, citizenship, place of origin, age, disability, gender, or sexual orientation.

Department members shall use information-gathering and investigative techniques that are the least intrusive means necessary in the particular circumstances to gather information the Department is authorized to seek and/or retain.

Data shall only be accessed for appropriate, job-related functions. Data shall not be used for any non-work-related purpose, and all uses shall take into consideration the privacy, civil rights, and civil liberties of individuals.

IV. Quality Assurance
The Department will investigate in a timely manner alleged errors and deficiencies (or will refer them to the originating agency) in order to correct, or refrain from using protected information found to be erroneous or deficient. Original data will not be altered, changed, or modified in order to protect the integrity of the data.

LASD will make every reasonable effort to ensure that information retained is derived from dependable and trustworthy sources which convey accurate, current, and complete information, including the relevant context in which the information was sought or received.

The labeling of retained information (hotlist Information) will be evaluated by LASD or the originating agency when new information is gathered that may impact the reliability (content validity / software misread) of previously retained information.

LASD will conduct periodic data quality reviews of information it originates and make every reasonable effort to ensure that the information from the ALPR System is correct.

V. Sharing and Disclosure
LASD does not share ALPR data with any contracted, commercial, or private entity.

B-2
The provision of data hosting or towing services shall not be considered the sale, sharing, or transferring of ALPR information (see CA Civil Code 1798.90.55.(b)).

Information gathered or collected and records retained by LASD may be accessed or disseminated for legitimate law enforcement, criminal justice, or public safety purposes only to persons or entities authorized by law to have such access and only for those uses and purposes specified in the law. An audit trail sufficient to allow the identification of each individual who accessed information, and/or received information retained by LASD; the nature of the information requested and/or accessed, and the specific purpose will be retained by LASD for a minimum of two (2) years.

Information gathered or collected and records retained by LASD will not be:
 Sold, published, exchanged, or disclosed for commercial purposes.  Disclosed or published without authorization.
 Disseminated to persons not authorized to access or use the information.

LASD shall not confirm the existence or nonexistence of information to any person or agency that would not be eligible to receive the information unless otherwise required by law.

LASD shares ALPR data with other law enforcement agencies upon the execution of an inter-agency agreement by which each agency agrees that all ALPR data will be gathered, accessed, utilized, and disclosed in accordance with applicable law, and further agrees:
 ALPR data shall be available only to authorized users for legitimate law enforcement purposes.
 Reasonable efforts will be made to ensure the accuracy of its data.  Shared hotlist data will not be stored for more than 24 hours without refresh.  Internal audits will be conducted periodically to ensure information is up to date and user queries are made for legitimate law enforcement purposes only.  Audit trails shall be maintained by each agency as defined by their policy.

VI. Information Retention and Destruction
ALPR data will be maintained in accordance with applicable laws and County / Department retention policies. Data associated with a specific investigation or prosecution will be retained until final disposition of the case, or until the data has no further value.

Information will be reviewed for record retention (validation or purge) at five (5) years, and when information has no further value or meets the criteria for removal by applicable law, it will be purged or permanently deleted except in cases such as:
 ALPR records related to a prosecution will be maintained until a final disposition has been reached in the case.
 ALPR records can be maintained in the criminal case file and retained for the maximum period of time associated with such record.

B-3
 ALPR records associated with criminal investigations will be maintained in the criminal case file and retained for the maximum period associated with such record.
 Whenever otherwise directed by an executive of the Department for a particular case or internal investigation.

LASD retains the right to remove ALPR data earlier, based on limitations of data storage requirements and other limitations including privacy concerns.

VII. Accountability
All personnel authorized to use or access ALPR technology or data will be accountable for knowledge of this policy.

Department members shall report errors and suspected or confirmed violations of Department policies relating to protected information to their supervisor or manager.

All access to the system will be logged, and the Department will maintain an audit trail of requested and accessed information, including the purpose of the query. Periodic, random audits will be conducted to ensure and evaluate compliance with system requirements and with the provisions of this policy and applicable law. Audit trails will be maintained by LASD for a minimum of two (2) years.

LASD will annually conduct an inspection of the audit information contained in its database system(s). The inspection will be conducted by the ASAP Unit. The ASAP Unit has the option of conducting random inspections, without announcement, at any time and without prior notice. The inspection will be conducted in such a manner as to protect the confidentiality, sensitivity, and privacy of the Department’s information system(s).

VIII. Custodian of ALPR System and Records
Primary responsibility for the maintenance and operation of the ALPR database and coordination of personnel and agencies receiving, seeking, and evaluating the information as well as quality, analysis, destruction, sharing, disclosure, or dissemination of further information will be assigned to the Advanced Surveillance and Protection Unit (ASAP). The ASAP Unit will serve as the Department’s custodian of records for the ALPR System and data.

IX. Training
Field Operations Directive 09-004 (FOD) provides guidelines and procedures on the usage of ALPR equipment and has been provided and briefed to training staff at all stations regarding ALPR equipment usage and access. All personnel authorized to use or access ALPR technology have been provided with all relevant policies, directives, and procedures related thereto and are accountable for knowledge thereof.

B-4
There are formal training classes on the authorized search engines which access and query ALPR data. Training is also conducted by station training personnel and the ASAP Unit. The basic ALPR software interface is intuitive and specific queries can only be done after all the information is collected, including search purposes and identifying information as to the individual conducting the search. There are also detailed help tutorials within the basic ALPR software to assist with helping each user to run certain basic queries.

B-5
City of Rancho Palos Verdes

ADMINISTRATION DEPARTMENT
CITY MANAGER’S OFFICE
30940 HAWTHORNE BLVD./ RANCHO PALOS VERDES, CA 90275-5391 /(310) 544-5207 / FAX (310) 544-5291 / WWW.RPVCA.GOV August 4, 2026
The Honorable Ben Allen
Member, California State Senate
1021 O Street, Suite 7610
Sacramento, CA 95814
The Honorable Al Muratsuchi
Member, California State Assembly
1021 O Street, Suite 5310
Sacramento, CA 95814
RE: The Unintended Consequences of Automated License Plate Recognition (ALPR) Privacy Laws on Homeowners’ Associations
Dear Honorable Legislators,
On behalf of the City of Rancho Palos Verdes, I am writing to bring your attention to an unintended consequence of California's Automated License Plate Recognition (ALPR) privacy laws following the recent Bartholomew v. Parking Concepts, Inc. decision.

Rancho Palos Verdes is home to several homeowners' associations (HOAs) that have voluntarily invested in ALPR technology to enhance neighborhood safety. License plate reader systems have served as valuable tools in deterring crime and have provided information to the Los Angeles County Sheriff's Department during criminal investigations. These partnerships reflect a shared commitment to public safety.

Recently, three HOAs within our City were served with lawsuits alleging violations of California's ALPR privacy requirements due to the absence of publicly posted privacy and usage policies. We recognize and support the Legislature's commitment to protecting Californians' privacy through SB 34 and the corresponding provisions of the Civil Code (Title 1.81.23 commencing with Section 1798.90.5). However, the February 2026 Bartholomew v. Parking Concepts, Inc. court decision appears to say that the absence of a publicly available ALPR usage and privacy policy constitutes harm in and of itself. As a practical matter, this decision has significantly increased the litigation risk facing private ALPR operators — including volunteer-led community organizations — that may have been unaware of these compliance obligations.

These HOAs are nonprofit, volunteer-led neighborhood organizations with limited administrative and financial resources. They adopted ALPR systems to improve neighborhood safety and to serve as responsible partners to local law enforcement.

C-1
Senator Ben Allen and Assembymember Al Muratsuchi
August 4, 2026

Page 2 ends

They have sought to balance public safety with individual privacy, but they often lack the legal expertise and compliance infrastructure necessary to navigate an increasingly complex regulatory environment. The current situation risks creating a chilling effect.

Faced with the prospect of costly litigation, HOAs and other community organizations may decide to discontinue the use of ALPR systems altogether.

We respectfully ask the Legislature to consider both legislative and operational responses to these unintended consequences. Potential approaches could include:
• Providing a reasonable cure period before private litigation may proceed for technical compliance deficiencies, such as failing to publicly post a required privacy policy.
• Directing the appropriate state agency to develop standardized model ALPR privacy and usage policies that HOAs, small nonprofit organizations, and other non-law enforcement users can readily adopt.
• Expanding education and outreach efforts so that small organizations understand their obligations under California law before becoming subject to litigation. • Evaluating whether additional statutory protections are appropriate for nonprofit community organizations that make good-faith efforts to comply with ALPR requirements while supporting legitimate public safety objectives.

California has long demonstrated that privacy and public safety need not be mutually exclusive. We believe there is an opportunity to preserve the important privacy protections established by the Legislature while ensuring that well-intentioned community organizations are given the guidance, education, and reasonable compliance pathways necessary to meet their obligations. We appreciate your continued leadership on these important issues and would welcome the opportunity to discuss our City's experience and to assist in developing practical solutions.

Sincerely,
Ara Mihranian
City Manager
City of Rancho Palos Verdes
cc: Rancho Palos Verdes City Council
Gail Lorenzen, Rancho Palos Verdes Neighborhood Watch
Kathy Edgerton, Rancho Palos Verdes Council of Homeowners Associations C-2

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