TO:
FROM:
DATE:
SUBJECT:
CITY OF RANCHO PALOS VERDES
HONORABLE MAYOR & CITY COUNCIL MEMBERS
CITY CLERK
AUGUST 18, 2026
ADDITIONS/REVISIONS AND AMENDMENTS TO AGENDA
Attached are revisions/additions and/or amendments to the agenda material presented for tonight's meeting.
Item No.
1 Description of Material
Corrections to Staff Report; Email exchange between Staff and: Sharon Yarber; Robert Cullinan; Email from Marie Chura
** PLEASE NOTE: Materials attached after the color page(s) were submitted through Monday, August 17, 2026 **
Respectfully submitted,
L:\LATE CORRESPONDENCE\2026\2026 Coversheets\20260818 additions revisions to agenda.docx Subject:
Attachments:
FW: Late Correspondence: August 18, 2026 Regular Business Item 1 ALPR Staff Report 2026_Late Correspondence.pdf
From: Allison Don <adon(wrpvca.g_g_y>
Sent: Tuesday, August 18, 2026 3:13 PM
To: CC <[email protected]>; Teresa Takaoka <TeriT('.!"ilrpvca.gov> Cc: Ara Mihranian <[email protected]_\_l>; Jennifer Schmid <jschmid(curp_\_l,C:il"'gQy>; Catherine Jun <ru!!l@[p):l_c_ci_,gQ\_/> Subject: Late Correspondence: August 18, 2026 Regular Business Item 1 Good Afternoon Mayor and City Council,
Attached to this email is a late correspondence item: the Agenda Report for the Automated License Plate Reader Camera Systems, which is Item 1 of Regular Business.
The report contains minor corrections:
• The Council Meeting referenced on Page 1 has been changed from July 7 to July 21. • The number of neighborhoods in the Public Safety Reimbursement Grant Program referenced on Page 5 has been updated from 1 Oto 12.
Thank you,
Allison Don
Sr. Administrative Analyst, Public Safety
City of Rancho Palos Verdes
[email protected]"" • (31 O) 544-5322
1 /.
CITYOF RANCHO PALOS VERDES
CITY COUNCIL
AGENDA REPORT
AGENDA TITLE:
MEETING DATE: 08/18/2026
AGENDA HEADING: Regular Business
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 f+D REVIEWED BY: Jennifer Schmid, Public Safety Manager 9-g Catherine Jun, Deputy City Manager CQAPPROVED BY: Ara Mihranian, AICP, City Manager4t.
ATTACHED SUPPORTING DOCUMENTS:
A) February 2024 City Council Staff Report (Linked)
B) LASO County Sheriff's Department's (LASO) 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 21, 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 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
ALPRs scan license plates, and Surveillance cameras are generalcomputer software compares purpose video recording devices them against law enforcement designed to provide a visual feed Summary databases that have logged and detect broad motion around those plates for various property.
purposes including identifying
stolen vehicles, Amber Alerts,
missinq persons, and felons.
Support law enforcement efforts General crime deterrence, Primary Uses such as identifying stolen monitoring property/visitors, vehicles or assisting with package tracking, and home or investiqations tied to vehicles business monitoring.
ALPR Cameras Surveillance Cameras
Strict state data Less strict regulations on data
retention/deletion timelines, retention and sharing. Video access logging, legal warrant recording is generally permitted in Data and requirements for access, and public areas if it respects Privacy sharing bans with outside reasonable expectations of Requirements agencies. privacy (e.g. No
bed rooms/bath rooms). Audio
recording faces strict state
requlations.
Motorola Solutions (Vigilant Ring, Blink, Google Nest,
Major Solutions), Flock Safety, SimpliSafe, Ario, and Reolink.
Companies in Leonardo (ELSAG), Axis
the Market Communications, and Plate
RecoQnizer.
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 (LASO 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.
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.
Five months later, however, a different appeals court (fifth appellate court) in Mata v.
Digital Recognition Network, Inc. (ORN) 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 12 neighborhoods who received financial assistance through the City's Public Safety Reimbursement Grant Program contracted with Flock to install 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 (LASO) 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 LASO 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.
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 (LASO for Rancho Palm~ 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, LASO maintains an ALPR Privacy Policy, which establishes rules for the collection of ALPR data, use of ALPR technology, data retention and destruction, information sharing, and oversight and accountability (Attachment B). Notable features of the policy include:
• Only approved LASO 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 LASO 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:
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.
Subject: FW: Flock cameras and drones
From: Ara Mihranian <[email protected]>
Sent: Monday, August 17, 2026 3:31 PM
To: Sharon Yarber <[email protected]>; CC <CC(ci1rpvca.gov> Cc: Jennifer Schmid <[email protected]>; Allison Don <adon(wrpvca.gqy:>; Catherine Jun <s;:[email protected]_v> Subject: RE: Flock cameras and drones
Good afternoon Sharon,
The City Council and I are in receipt of your email describing your opposition to the use of Flock cameras and the LASD's drones in our City.
Your email will be provided as late correspondence on both of these agenda items.
I will also be sure to forward your email to our Flock representatives and the Captain of the Lomita Station for their awareness.
Ara
Ara Michael Mihranian
City Manager
[email protected]
Phone - (310) 544-5202
Address:
30940 Hawthorne Blvd.
Rancho Palos Verdes, CA 90275
Website: WWW,IPY~i!,gQ11
From: Sharon Yarber <sharon(a)sharonyarber.com>
Sent: Sunday, August 16, 2026 12:22 PM
To: CC <[email protected]\.'>
Cc: Ara Mihranian <[email protected]'v'.>
Subject: Flock cameras and drones
Dear Mayor Seo and Members of the City Council,
► GUITON
Google Play
When Flock cameras were first proposed for installation in the City, I expressed concerns about unconstitutional invasion of privacy and my opposition to their use (to no avail). I am glad the issue is being revisited, but I am disappointed that, once again, money and concerns about liability, rather than the core reasons for reevaluation, are the motivation for the upcoming discussion.
1 When these cameras were installed widely around LA County I personally experienced my concerns become reality. This was probably 1 O or more years ago. I was having a telephone discussion one day with a fellow real estate attorney (not someone in law enforcement) and we were talking about these surveillance cameras. He asked me what my car's license plate number was and I gave it to him. Within a matter of a few minutes he sent an email to me with a picture of the rear of my car and license plate number, and the time and location of the car. He jokingly asked me "So what were YOU doing on such and such a date on South Figueroa Street at 9:1 O AM?" It was obvious from the photo that I was on Fig at 9th street (by the Original Pantry), and as it was a weekday I knew I was on my way to my office a couple of blocks away. I asked him how he got that info and he demurred.
So, how DID he get that information which is ONLY supposed to be used by law enforcement? Well, I guess he had a friend who was a cop who gave him that information in violation of policy. Policies and procedures only work when they are followed, and we know that they are OFTEN not followed.
Every time our privacy rights are whittled away a little bit at a time, it is always under the guise of "enhanced safety". That's a nice ruse but it doesn't work for me. Sure, lots and lots of things could enhance our safety. We went from TSA scanning of our bags and metal detectors to X-ray images that see through our clothing! What's next? Strip searches? Body cavity searches? They'd sure increase safety, but I have a better idea. Instead of harming innocent people take the bad guys off the streets and KEEP them off? Instead of more gun "safety" laws, which have proved time and again they don't work, how about capital punishment when warranted, life without parole meaning NO PAROLE EVER. No 20 -30 year sentences and the bad guy is out in 8 years for "good behavior" and then he returns to his criminal ways.
I want to see us get rid of the Flock cameras altogether. PLEASE! As for the drones, you have to be kidding. Now drones will be our first responders? Drones will absolutely be used in such a way that invasions of privacy will occur regularly. An analogy of drones to helicopters is ludicrous.
Drones are not allowed to fly above 200' from the ground below. Helicopters don't fly below 200' unless landing.
Drones can fly over private property (backyards) at very low altitudes and capture pictures of someone sunbathing nude (note - I do NOT do that -:;. ).
Drones have been used to fly INTO RESIDENCES per the information from the sheriff in the staff report provided to support use of drones. What happens if a drove flies into the wrong residence? What happens if another company or agency's drones are utilized, as the report describes. Sure, they are supposed to provide Lomita Sheriff with a copy of the information gathered but there's no indication that the third party is required to destroy its copy. Who monitors the use or misuse by the third party of the information gathered? Explain how drones are a "de-escalation tool". The list of instances when they can be used includes "other approved uses". What are those and who decides to give approval? What is the retention policy for the information gathered? What are the consequences for anyone who violated policy, including failure to log a deployment? What exactly is the training protocol? There is mention of a Civilian Oversight Committee but no information about who is on the Committee, how many members will serve, length of their terms, or by whom they are selected. Can residents of the cities apply to serve on the Committee? If so, consider my application as already having been submitted!
Drone cameras can ZOOM into the windows of residences? Sure, that sounds just wonderful if the window is on the house of the bad guy, though that is likely a 4th Amendment violation, but what happens if you zoom into the wrong window by mistake and observe people engaging in perfectly legal but potentially quite embarrassing conduct? The opportunities for errors. misuse and abuse are endless.
Again, "increased safety" is the purported justification. What's next? We might as well bug every home and office to pick up any conversations that might take place wherein a terrorist attack is being plotted? That would increase safety would it not? With "smart" TVs and Alexas we are already pretty close to being there. 2 I never thought 1984 would come to fruition but it has. But instead of the "evil" government imposing these invasions of our privacy and violations of our constitutional rights, WE THE STUPID PEOPLE have invited the invasion by our own acquiescence to these "safety" measures.
I vehemently oppose the entering by the City of RPV into the MOU and do NOT want to see any drones flying around me or my house or my City.
Thank you for your attention to this matter and for your consideration of my viewpoints! Sincerely,
Sharon Yarber
3 Subject: FW: City Council meeting 8/18/26
From: Catherine Jun <[email protected]>
Sent: Tuesday, August 18, 2026 3:10 PM
To: CC <[email protected]>; CityClerk <[email protected]>
Cc: Allison Don <[email protected]>; Jennifer Schmid <[email protected]> Subject: RE: City Council meeting 8/18/26
Hi Robe1i,
Thank you for your email and sharing your concerns with us. We understand that these types of cameras have been eliciting a wide range of opinions from different communities, which is what prompted us to share more information about them during tonight's City Council meeting. Tonight's presentation will be about how the Flock systems work, how HOAs and law enforcement agencies (not the City) utilize the data, and recent comi rulings that affect their use. Flock will also be present to provide an overview of their systems. We appreciate your feedback and will convey it to the City Council in advance. We also encourage you to attend the meeting in person or watch online, and if you have any further questions or concerns afterwards, please reach out to me anytime.
Sincerely,
Catherine Jun
Deputy City Manager
cjun@rp~
(310) 544-5203
30940 Hawthorne Blvd.
Rancho Palos Verdes, CA 90275
www. rpvca...grut
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Sent: Monday, August 17, 2026 7:49 PM
To: CC <[email protected]>; Paul Seo <[email protected]>
Subject: City Council meeting 8/18/26
Some people who received this message don't often get email from [email protected]. Learn why this is important
Dear Mayor and Councilmernbers,
1 I.
I am unable to attend the meeting tomorrow but wanted to share my opinion about an agenda item that will be reviewed during the meeting.
I am deeply opposed to the use of Flock or other surveillance systems in our community. I know that neighbors feel the same way and may not be aware of the discussion planned for tomorrow.
Apart from the violation of privacy, these systems are a very poor use for our tax dollars. The systems are well understood to have cybersecurity flaws, insecure databases, wide access by unauthorized parties, significant errors leading to improper police actions, lack of local oversight, and future troubling add-on technologies that profile persons and personal communications devices.
Didn't LAPD just suspend a contract with Flock? Why would our Council consider such a system? There is significant legal exposure for our city if this moves forward.
Further, exactly what problem are you trying to solve with Flock? I am unaware of the type of lawlessness that might prompt consideration of such a system.
While police departments use license plate readers for their own use, systems like Flock sell-out our privacy to a corporation without our consent. Our community expects more from our city representatives and we are watching.
Regards,
Robert Cullinan
3073 Crest Road
Rancho Palos Verdes, CA 90275
2 Subject: FW: Flock questions for tonight, Aug 18, 2026 RPV City Council Meeting From: [email protected] <[email protected]> I Sent: Tuesday, August 18, 2026 1:09 PM To: CC <[email protected]'>
Subject: Flock questions for tonight, Aug 18, 2026 RPV City Council Meeting To Members of the City Council,
Sorry for the late email, but I have a few questions regarding the Flock camera system in our city and wonder if you could ask these questions of the Flock representative and the Sheriff tonight.
Thank you
Marie Chura
President
La Cresta HOA
Regarding the Flock cameras in some of our RPV neighborhoods, has Flock shared data from these cameras with anyone?
We know that the Sheriff has access to the Flock camera data. Has the Sheriff shared this information (or allowed access) with any organization, federal or state? Does Flock typically store data over 30 days - or only upon request from a law enforcement agency?
1 I.