Agenda packet — San Carlos City Council, October 13, 2026

CITY OF SAN CARLOS
City Council/Housing Authority
Regular Meeting
Tuesday, October 13, 2026 7:00 PM
Council Chambers, City Hall
600 Elm Street, San Carlos, CA 94070
www.cityofsancarlos.org
AGENDA
This meeting will be conducted both in-person at City Hall and virtually via Zoom. Members of the public will have the option to observe the meeting and address the City Council as outlined below.

In-Person Participation:
• Location. City Hall – 600 Elm Street, Council Chambers. • Provide Public Comment. To address the City Council, fill out a Request to Speak Form located in the back of the Council Chambers and submit it to the City Clerk; or, you may raise your hand when the Mayor calls for public comments.

Remote Participation:
• Observe via:
- Zoom. https://us02web.zoom.us/j/88256140939; or call 1-669-900-9128 and enter the Meeting ID #: 882 5614 0939
- Meeting Webportal. www.cityofsancarlos.org/agenda - Local TV. Comcast Channel 27 and AT&T Uverse Channel 99 • Provide Public Comment. If you plan to make a public comment, please observe the meeting via Zoom (see above access information), and during the public comment period for the agenda item you wish to address, use the “raise hand” feature. If joining Zoom by phone, press *9 to “raise hand”.

Councilmembers may participate in this meeting remotely pursuant to Government Code 54953.8.

MAYOR: Pranita Venkatesh
COUNCIL: John Dugan, Neil Layton, Sara McDowell, Adam Rak 1 1. CALL TO ORDER

2. TELECONFERENCE ANNOUNCEMENTS BY COUNCIL

3. PLEDGE OF ALLEGIANCE

4. CHANGES TO THE ORDER OF THE AGENDA

5. PRESENTATIONS
a. Recognize 2026 Civics Academy Graduates.
b. Present a Proclamation Recognizing October 2026 as Domestic Violence Awareness Month.

6. COUNCIL COMMUNICATIONS AND ANNOUNCEMENTS
Council Communications and Announcements are brief items from members of the City Council regarding upcoming events in the community and correspondence that they have received. They are informational in nature and no action will be taken on these items at this meeting.

7. PUBLIC COMMENT
Persons wishing to address the City Council on matters NOT on the posted agenda may do so. Each speaker is limited to two minutes; however, speaking time may be reduced at the Mayor’s discretion based on the number of speakers. General Public Comment may also be limited to a total of 30 minutes, with any remaining public comment heard at the end of the agenda, if time permits.

If the item you are speaking on is not listed on the agenda, please be advised that the City Council may briefly respond to statements made or questions posed as allowed under the Brown Act (Government Code Section 54954.2). The City Council's general policy is to refer items to staff for attention, or have a matter placed on a future City Council agenda for a more comprehensive action or report and formal public discussion and input at that time.

8. CONSENT CALENDAR
a. Motion to Waive Reading of All Ordinances.
b. Approve the City Council September 14, 2026 Regular Meeting Minutes. c. Adopt a Resolution Amending the City of San Carlos’ Conflict of Interest Code. 2 d. Accept the Quarterly Reports from the City's Commissions and Boards. e. Authorize the City Manager to Sign a Letter Prepared by Staff in Response to the 2025-2026 San Mateo County Civil Grand Jury Report Titled "Is our Flock of ALPR Cameras Properly Tended?"
f. Authorize Cancellation of the December 28, 2026 City Council Meeting. g. Adopt Ordinance 1639 Amending San Carlos Municipal Code Title 18, Sections

18.05.020 – Mixed-Use Districts Land Use Regulations, 18.06.020 – Commercial Districts Land Use Regulations, 18.07.020 – Industrial Districts Land Use Regulations, and 18.23 – Standards for Specific Uses and Activities, for a Tobacco Retailer Permit Requirement.

9. REPORTS TO COUNCIL
Reports to the Council are updates on key City Projects by City Staff and City Council Subcommittees. They are informational in nature, and no action will be taken on these items at this meeting.
a. Receive an Update on Winter Storm Season Preparedness.

10. STUDY SESSION
a. Receive a Presentation on Entertainment Zones and Provide Direction on Whether to Establish an Entertainment Zone in San Carlos.

11. AGENDA SETTING
Items discussed in this Agenda Setting Section will be considered by the Council for placing on a future agenda. No action will be taken on these items at this meeting.

12. ADJOURNMENT
Any writings or documents provided to a majority of the City Council regarding any item on this agenda will be made available for public inspection upon request.

In compliance with the Americans with Disabilities Act and Title VI, and as outlined in the City’s Reasonable Accommodations Policy, if you need special assistance or translation services to participate in this meeting, please contact the City Clerk’s Office at (650) 802-4222 or via email at [email protected]. Notification in advance of the meeting will enable the City to make reasonable arrangements to ensure accessibility to this meeting. 3 San Carlos City Council/Successor Agency to the
Redevelopment Agency/Housing Authority Regular Meeting
Council Chambers, City Hall
600 Elm Street, San Carlos, CA 94070
September 14, 2026 7:00 PM

MINUTES

ROLL CALL

City Council Present: Pranita Venkatesh, Mayor
Adam Rak, Vice Mayor
John Dugan, Councilmember
Neil Layton, Councilmember
Sara McDowell, Councilmember

Staff Present: Nil Blackburn, Assistant City Manager
Rendell Bustos, Senior Planner
Vinnie Chen, Assistant Planner
Rucha Dande, Principal Planner
Sajuti Haque, Economic Development and Housing Manager
Hanieh Houshmandi, Senior Traffic Engineer
Kathy Kleinbaum, City Manager
Steven Machida, Public Works Director
Rebecca Mendenhall, Administrative Services Director
Crystal Mui, City Clerk
Amy Newby, Parks and Recreation Director
Lisa Porras, Planning Manager
Laura Richstone, Senior Planner
Stefanie Rogers, Senior Administrator Clerk
Gregory Rubens, City Attorney
Adolfo Ruelas, Economic Development Coordinator
Al Savay, Community Development Director
Tracy Scramaglia, Assistant Public Works Director
Deanna Skaggs, Assistant Planner

1. CALL TO ORDER
Mayor Venkatesh called the meeting to order at 7:00 p.m.

2. TELECONFERENCE ANNOUNCEMENTS BY COUNCIL
None.

3. PLEDGE OF ALLEGIANCE
Mayor Venkatesh led the Pledge of Allegiance.

4. CHANGES TO THE ORDER OF THE AGENDA
None.

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5. PRESENTATIONS
a. Present Proclamations Recognizing RethinkWaste’s 2026 Trash to Art Contest Winners.

Mayor Venkatesh presented proclamations to the 2026 RethinkWaste Trash to Art Contest winners – Parker, Kenna, and Kiran and Miss Martin's 3rd grade class.

Vice Mayor Adam Rak, who serves as the RethinkWaste Boardmember, commended the annual contest and encouraged greater school participation. b. Present a Proclamation Recognizing September 2026 as Suicide Prevention Month.

Mayor Venkatesh presented a proclamation declaring September 2026 as Suicide Prevention Month to Sylvia Tang, Co-Chair of San Mateo County's Suicide Prevention Committee. Ms. Tang emphasized the importance of open conversation about suicide and highlighted available resources. She also acknowledged Council Member McDowell's leadership in the Mayor's Mental Health Initiative and thanked city staff for their proactive year-round engagement on suicide prevention.

6. COUNCIL COMMUNICATIONS AND ANNOUNCEMENTS
Mayor Venkatesh thanked Parks and Recreation staff for the Day of Service, noting community participation in park maintenance.

Vice Mayor Rak also acknowledged the Day of Service at Vista Park, the History Museum's annual ice cream social, and the open house for Aashvi Smiles, a new dental office near the train station.

Mayor Venkatesh additionally welcomed Muditā as a new San Carlos business.

7. PUBLIC COMMENT
Mark Iwanowski spoke on behalf of resident Linda Preston. He raised four concerns regarding the Harrington Park bid process and requested that the downtown plan portion of the 2026 Strategic Work Plan (item 8h) be pulled from the Consent Calendar pending public answers to his concerns.

Angela Giannini White, a resident, expressed concerns regarding the Harrington Park Project.

John Durkin, a resident, expressed concerns with the cost of the downtown park refresh.

8. CONSENT CALENDAR
Public Comment
- Mark Iwanowski, a resident, reiterated concerns about the Harrington Park Project and requested the Project be pulled from the Strategic Work Plan.

- Ken Castle, a resident, requested reopening the discussion regarding the closure of the 700 block of Laurel Street.

- Angela Giannini White, a resident, also spoke in support or reopening the 700 block of Laurel Street.

MOTION: Adopt City Council Consent Calendar Items ‘a’ through “j”.

MOVER: Dugan

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SECONDER: Layton
AYES: Dugan, Layton, McDowell, Rak, Venkatesh
NAYS: None
RESULT: Motion Passed 5 – 0
a. Motion to Waive Reading of All Ordinances.
b. Approve the August 10, 2026 City Council Special and Regular Meetings Minutes. c. Adopt a Resolution Adopting an Updated Salary and Benefit Resolution for the Part-Time Employee Group Effective January 1, 2027. Resolution 2026-107 d. Adopt a Resolution Approving and Adopting an Updated Comprehensive Master Salary Schedule for Fiscal Year 2026-27 in Accordance with Title 2 of the California Code of Regulations Section 570.5 and the California Public Employees’ Retirement System (CalPERS). Resolution 2026- 108
e. Adopt a Resolution Authorizing the Execution of a License Agreement Between the City and Bianchini's Supermarket, Inc. for Continued Use of a Portion of the South Plaza Parking Lot for Trash Collection and Storage Purposes. Resolution 2026-109 f. Adopt a Resolution Authorizing the Execution of a Professional Services Agreement with Shawn Spano for Meeting Facilitation Services for a Five-Year Term in an Amount Not to Exceed $75,000. Resolution 2026-110
g. Deny Claim of Allison Kim.
h. Approve Updates to the City's 2026 Strategic Work Plan Items. i. Deny Claim of Leslie DeCristoferi.
j. Adopt a Resolution Authorizing the Execution of an Amendment to the Joint Use Agreement Between the City of San Carlos and San Carlos School District for Adjustments to the District’s Field Maintenance Scope of Services. Resolution 2026-111

9. STUDY SESSION
a. Receive a Presentation and Provide Direction on Updates to the Formula Business Ordinance.

Assistant Planner Deanna Skaggs presented a work program for studying the Formula Business Ordinance and, along with Community Development Director Al Savay, responded to Council questions.

Public Comment
- Ken Castle, a resident, advocated for Burlingame's downtown model and provided Council with a handout.
- David Carroll, a resident, spoke in opposition to the Formula Business Ordinance.

Council provided the following direction to staff:
- Incorporate an analysis of the age of the downtown area and any prior revitalization efforts into the staff’s research and outreach.

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- Develop a robust outreach strategy including in-person meetings with downtown business owners and property owners; and engagement with the Youth Advisory Council and the Adult Community Center community.
- Explore ways to attract visitors from neighboring communities by partnering with the Chamber of Commerce, local restaurants, and businesses to gather input and identify opportunities. - Include survey questions on the types of businesses residents feel are missing from downtown, what would attract visitors from neighboring communities, and whether they would support allowing additional formula businesses.
- Expand the jurisdictional comparison to include Burlingame, Los Gatos, Carmel-by-the-Sea, and other relevant cities, with attention to downtown revitalization history, mix of business types, and economic characteristics.
- Evaluate and present a range of options, including: maintaining the status quo; repealing the Ordinance; converting the Conditional Use Permit requirement to a Minor Use Permit requirement; adjusting the location threshold; distinguishing between national, regional, and local chains; and establishing an overall cap on formula businesses. - Consult with commercial brokers and include an assessment of available and under-marketed downtown spaces, as well as building size and lease constraints. - Return with findings and a recommendation at a subsequent study session, with an effort to complete the work ahead of the June 2027 target date.

10. NEW BUSINESS
a. Consideration of Adopting a Resolution Supporting SamTrans’ Coordination with Caltrans and the City of San Carlos to Plan, Design, and Implement Complete Street Improvements on El Camino Real in San Carlos as Part of the El Camino Real Multimodal Plan.

Planning Manager Lisa Porras opened the item and introduced the SamTrans team: Project Manager Cassie Halls, Government Affairs Officer Charlsie Chang, and Principal Engineer Consultant Erin Ferguson. The team presented the Central El Camino Real Multimodal Plan, covering San Carlos, Belmont, San Mateo, and a portion of Redwood City Ms. Halls, Ms. Porras, Senior Traffic Engineer Hanieh Houshmandi, and Ms. Chang responded to Council questions.

Public Comment
- Ken Castle, a resident, expressed concerns about dedicated bike lanes and bus rapid transit lanes and provided the Council with a handout.
- Andrew Hsu, a resident, spoke in support of the proposed Resolution. - Jennifer Rosse, a resident, spoke in support of protected bike lanes, and stated that residents on the east side would like additional opportunities to provide input as the plan develops. - Arley Lewis, a resident, spoke in support of the proposed Resolution.

Council provided the following feedback:
- Provide more proactive maintenance efforts along El Camino Real, including weed removal m plans.

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and upkeep of transit stops, as short-term actions to complement long-term plans.

Packet Pg. 7
- Prioritize safety elements as the plan advances.
- Conduct thorough and ongoing community engagement throughout the environmental and design phases, including discussions about placemaking opportunities, to ensure the final design reflects San Carlos’ vision.
- Consider usage data before supporting dedicated bus lanes.

MOTION: Adopt Resolution 2026-112 supporting SamTrans’ coordination with Caltrans and the City of San Carlos to plan, design, and implement complete street improvements on El Camino Real in San Carlos as part of the El Camino Real Multimodal Plan.

MOVER: Rak
SECONDER: Dugan
AYES: Rak, Dugan, Layton, McDowell, Venkatesh
NAYS: None
RESULT: Motion Passed 5 – 0
b. Consideration of Introducing an Ordinance Amending San Carlos Municipal Code Chapter 5.43 - Sidewalk Vending, to Conform with SB 635 and Making Findings Pursuant to the California Environmental Quality Act.

City Attorney Greg Rubens presented a proposed ordinance to bring the City's sidewalk vending regulations into compliance with Senate Bill 635.

Public Comment
- A resident raised concerns about pedestrian safety on Eucalyptus Avenue when sidewalk vendors reduce the available pedestrian space.

Council Member Rak requested that the public commenter’s concern be shared with the Sheriff's Department to address safety issues related to sidewalk vending.

MOTION: Introduce Ordinance No. 1638 amending San Carlos Municipal Code Chapter

5.43 - Sidewalk Vending, to conform with SB 635 and making findings pursuant to the California Environmental Quality Act with an amendment to add ‘whippets’ to the list of items prohibited from being vended.

MOVER: McDowell
SECONDER: Layton
AYES: McDowell, Rak, Dugan, Layton, Venkatesh
NAYS: None
RESULT: Motion Passed 5 – 0

11. AGENDA SETTING
a. Consideration of Agendizing an Item to Receive an Update on the Implementation of the Protected Tree Ordinance.

Vice Mayor Rak requested that an item be placed on a future agenda to provide a status update on the Protected Tree Ordinance, including an assessment of potentially conflicting provisions, the tree-removal permitting process, and compliance with replacement tree requirements.

Public Comment
- Vincent Gr

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- Vincent Gritsch, a resident, spoke in support of agendizing the proposed item.

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Council proposed expanding the scope to include the Citywide Tree Maintenance Program and an overview of the state of the urban tree canopy. The item received Council support and will be placed on a future meeting agenda.

12. ADJOURNMENT
Mayor Venkatesh adjourned the meeting at 9:39 p.m.

Crystal Mui,
City Clerk

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CITY COUNCIL

STAFF REPORT
MEETING DATE: October 13, 2026
ITEM TITLE: Adopt a Resolution Amending the City of San Carlos’ Conflict of Interest Code.

RECOMMENDATION:

Staff recommend that the City Council adopt a Resolution amending the City’s Conflict of Interest Code.

FISCAL IMPLICATIONS:

There are no fiscal implications, and no additional funding is needed.

BACKGROUND:

The City’s Conflict of Interest Code (“Code”) designates which public officials and consultants are required to file a Statement of Economic Interests (Form 700) and what they must disclose. In 1990, Government Code §87306.5 was added to the Political Reform Act requiring every local agency to review their codes on at least a biennial basis (to be conducted each even numbered year) to ensure that the code reflects the organization’s current staffing.

The City Council approved San Carlos' first Code revision and report in September 1992 and submitted it to the Fair Political Practices Commission (FPPC). The Code was modified again in 1994 and has undergone biennial review since 1998.

Certain City positions are covered by state law and are required to comply with state regulations, while other positions are governed only by local conflict of interest codes. Employees performing ministerial or manual tasks and members of advisory, non-decision-making boards and committees are not usually subject to the Code. Other employees in decision-making positions, or those dealing with the expenditure of local funds, have a disclosure obligation. They are referenced under the Code as designated employees and their economic disclosure is outlined in "disclosure categories" in the Code.

A 45-day written comment period opened on August 29, 2026, and closes at 5:00 p.m. on October 13, 2026. During this period, interested persons may submit written comments or express concerns regarding the proposed Code amendments. Requests for a public hearing were required no later than 15 days before the close of the comment period (by 5:00 p.m. on September 28, 2026); that deadline has passed with no requests, so no public hearing will be scheduled. As of the writing of this report, the City has received no written comments.

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ANALYSIS:

Accurate disclosure is essential to monitor whether officials have conflicts of interest and to help ensure public trust in government. Staff reviewed the current Code and recommend adding the following positions as they were added to the organization since 2024:
• Assistant Building Official, Disclosure 1
• Assistant Public Works Director, Disclosure 1
• Principal Engineer, Disclosure 1
A red-lined version of the proposed Code is included as Exhibit A to the Resolution.

An individual whose position title is listed in the Code shall file an FPPC Form 700 with the City of San Carlos under the designated disclosure category and is required to comply with the ethics training requirements of California Government Code §§53234, et seq.

ALTERNATIVES:

The options available to the City Council include:

1. Adopt a Resolution amending the City’s Conflict of Interest Code; or

2. Do not adopt the Resolution; or

3. Provide staff with alternative direction.

Respectfully submitted by:

Crystal Mui, City Clerk
Approved for submission by:
____________________________
Kathy Kleinbaum, City Manager
ATTACHMENT(S):

1. Resolution with Exhibit A – Proposed Designated Officers and Employees (red-lined)

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RESOLUTION NO. 2026 – ____

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN CARLOS AMENDING THE CITY OF SAN CARLOS’ CONFLICT OF INTEREST CODE.

WHEREAS, the Political Reform Act requires certain city officials, specified in section 87200 of the California Government Code, to file economic disclosure forms (Form 700) and abstain from making or participating in making governmental decisions which have a reasonably foreseeable material effect on an economic interest; and
WHEREAS, the Political Reform Act also requires cities to adopt a local Conflict of Interest Code that enumerates specific city positions other than those specified in Government Code Section 87200, which involve making or participating in making decisions which have a reasonably foreseeable material effect on an economic interest, and to designate for each position the specific types of investments, business positions, interests in real property and sources of income which are reportable based on the scope of the decision making authority of the position; and WHEREAS, state law requires every local government agency to perform review of its Conflict of Interest Code biennially; and
WHEREAS, the San Carlos City Council adopted a revised Conflict of Interest Code in 1992 by Resolution No. 1992-085, which was modified in 1994 and then biennially since 1998; and WHEREAS, the City Council has reviewed said Conflict of Interest Code and has determined that amendments are required (as shown in red in Exhibit A); and WHEREAS, the Conflict of Interest Code adopted by this Resolution accurately reflects the duties of each position and the appropriate disclosure categories for each position.

NOW, THEREFORE, BE IT RESOLVED, that all previously adopted Resolutions amending the City's Conflict of Interest Code are hereby rescinded; and the Conflict of Interest Code for the City of San Carlos, is hereby amended to read as follows:

CITY OF SAN CARLOS

CONFLICT OF INTEREST CODE
The Political Reform Act (Government Code Section 81000, et seq.) requires state and local government agencies to adopt and promulgate conflict of interest codes. The Fair Political Practices Commission has adopted a regulation (2 California Code of Regulations Section 18730) that contains the terms of a standard conflict of interest code, which can be incorporated by reference in an agency's code. After public notice and hearing, the standard code may be amended by the Fair Political Practices Commission to conform to amendments in the Political Reform Act. Therefore, the terms of 2 California Code of Regulations Section 18730 and any amendments to it duly adopted by the Fair Political Practices Commission are hereby incorporated by reference. This regulation and the attached Exhibit A, designating positions and establishing disclosure categories, shall constitute the Conflict of Interest Code of the City of San Carlos.

Individuals whose position title is listed in Exhibit A shall file a Statement of Economic Interest (FPPC Form 700) with the City of San Carlos under the designated disclosure

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category and is required to comply with the ethics training requirements of California Government Code §§53234, et seq.

Statement of Economic Interests will be retained by the City Clerk and will be available for public inspection and reproduction pursuant to Gov. Code Sec. 81008.

1. If no comments are received pursuant to the 45-day written comment period, there will be no additional public hearing on the proposed code.

2. The City Council, as code reviewing body for the City of San Carlos, has determined that the attached Exhibit A accurately sets forth those positions which should be designated and the categories of financial interests which should be made reportable for each position.
* * * * *
I, City Clerk Crystal Mui, hereby certify that the foregoing Resolution was duly and regularly passed and adopted by the City Council of the City of San Carlos at a scheduled meeting thereof held on the 13th day of October 2026, by the following vote:
________________________________
CITY CLERK of the City of San Carlos
APPROVED:
___________________________
MAYOR of the City of San Carlos
Exhibit A: Designated Officers and Employees
AYES, COUNCILMEMBERS:

NOES, COUNCILMEMBERS:

ABSENT, COUNCILMEMBERS:

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EXHIBIT A

DESIGNATED OFFICERS AND EMPLOYEES

DESIGNATED POSITION

ADMINISTRATION

DISCLOSURE CATEGORIES
Assistant City Manager 1
City Council 1
City Manager 1
City Treasurer 1
Senior Management Analyst 3

CITY ATTORNEY
City Attorney 1

CITY CLERK
City Clerk/Community Relations Director 1

ADMINISTRATIVE SERVICES DEPARTMENT
Administrative Services Director 1
Financial Services Manager 1
Human Resources Manager 1
Information Technology Manager 1
Senior Accountant 2
Senior Systems Analyst 3
Senior Management Analyst 3

COMMUNITY DEVELOPMENT DEPARTMENT
Assistant Building Official 1
Assistant Planner 2
Assistant Community Development Director 1
Associate Planner 2
Building Inspector 2
Building Official 1
Code Enforcement Officer 2
Community Development Director 1
Economic Development & Housing Manager 1
Economic Development Coordinator 3
Planning Manager 1
Principal Planner 1
Senior Building Inspector 2
Senior Management Analyst 3
Senior Planner 2

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FIRE
Deputy Fire Chief 1
Fire Chief 1
Fire Prevention Officer 1
POLICE
Police Captain (Assigned to Police Chief for San Carlos) 1

PARKS AND RECREATION DEPARTMENT
Parks and Recreation Director 1
Recreation Manager 2
Recreation Supervisor 3

PUBLIC WORKS
Assistant Public Works Director 1
Assistant Public Works Superintendent 2
Associate Engineer 1
City Engineer 1
Public Works Director 1
Public Works Inspector 2
Public Works Superintendent 2
Principal Engineer 1
Senior Engineer 1
Senior Traffic Engineer 1

COMMISSIONS
Planning and Transportation Commissioners 1
Economic Development Advisory Commissioners 1

SPECIFIED CONSULTANTS/NEW POSITIONS
Consultants/new positions shall be included in the list of designated officials and employees and shall disclose pursuant to the broadest disclosure category in the Code subject to the following limitation:

The City Manager, or their designee, may determine in writing that a particular consultant or new position, although a "designated position," is hired to perform a range of duties that is limited in scope and thus is not required to fully comply with the disclosure requirements in this section. Such written determination shall include a description of the consultant's or new position's duties and, based upon that description, a statement of the extent of disclosure requirements. The City Manager's determination is a public record and shall be retained for public inspection in the same manner and location as this Conflict of Interest Code. (Government Code Section 81008.)
Nothing herein excuses any consultant from any other provision of this Conflict of Interest Code, specifically those dealing with disqualification.

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DISCLOSURE CATEGORIES
The disclosure categories listed below identify the types of economic investments that the designated position must disclose for the category to which he or she is assigned. Such economic interests are reportable if they are either located in or doing business in the jurisdiction, are planning to do business in the jurisdiction, or have done business during the previous two years in the jurisdiction of the City.

1. FULL DISCLOSURE
Persons in this category must disclose all investments and business positions in business entities, sources of income including gifts, loans and travel payments, and interests in real property located in the City. Applicable Form 700 Schedules: A through E

2. DEPARTMENT-RELATED INCOME, REAL PROPERTY
Persons in this category must disclose all investments and business positions in business entities and sources of income including gifts, loans and travel payments, and all interests in real property, if the source is of a type which provides, manufactures, or supplies goods, materials, equipment, machinery or services, including training or consulting services, of the type utilized by or subject to the review or approval of the department in which that person is employed. Applicable Form 700 Schedules: A through E

3. DEPARTMENT-RELATED INCOME
Persons in this category must disclose all investments and business positions in business entities and sources of income, including gifts, loans and travel payments if the source is of a type which provides, manufactures, or supplies, goods, materials, equipment, machinery or services, including training or consulting services, of the type utilized by or subject to the review or approval by the department in which that person is employed.

Applicable Form 700 Schedules: A, C, D, E

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CITY COUNCIL

STAFF REPORT
MEETING DATE: October 13, 2026
ITEM TITLE: Accept the Quarterly Reports from the City's Commissions and Boards.

RECOMMENDATION:

Staff recommend that the City Council accept the quarterly reports from the City's Commissions and Boards.

FISCAL IMPLICATIONS:

There are no fiscal implications, and no additional funding is needed.

BACKGROUND:

Every quarter, the City Council receives a report from each commission and board. These reports provide updates on the activities and initiatives undertaken during the preceding period.

Additionally, each report includes a detailed member attendance record, ensuring accountability regarding participation in meetings and decision-making processes. These updates help the City Council stay informed about the work of its advisory bodies and support effective governance.

ANALYSIS:

Attached are the fiscal year 2026-27 first quarter reports from the following commissions and boards for the period of July through September 2026:

- Economic Development Advisory Commission
- Museum of San Carlos History
- Parks, Recreation and Culture Commission
- Planning and Transportation Commission
- Youth Advisory Council

Consistent attendance at commission meetings is essential to maintaining a quorum, which is necessary for conducting official business, as well as ensuring steady communication and staying informed on current discussions. Pursuant to the Commissioners’ Handbook, three unexcused absences within a fiscal year (July – June) will result in the commissioner’s seat being declared vacant. For commissions that meet less than once a month, two unexcused absences will result in vacancy. Staff have alerted all members with two absences—or one absence for commissions meeting less than monthly—that any additional unexcused absence within the fiscal year will result in removal.

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ALTERNATIVES:

The alternatives available to the City Council include:

1. Accept the Quarterly Reports from City Commissions and Boards; or

2. Do not accept the Quarterly Reports from City Commissions and Boards; or

3. Provide staff with alternative direction.

Respectfully submitted by:

Samantha Copsey, Deputy City Clerk; and
Crystal Mui, City Clerk
Approved for submission by:
____________________________
Kathy Kleinbaum, City Manager
ATTACHMENT(S):

1. Economic Development Advisory FY2027 Q1 Report

2. Museum FY2027 Q1 Report

3. Parks, Recreation and Culture FY2027 Q1 Report

4. Planning and Transportation FY2027 Q1 Report

5. Youth Advisory FY2027 Q1 Report

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CITY OF SAN CARLOS

ECONOMIC DEVELOPMENT ADVISORY COMMISSION (EDAC)
QUARTERLY REPORT, JULY-SEPTEMBER 2026
Commissioners
Rajesh Krishnan
Madhura Kumar
Anthony Kamm, Heather Liu, Sailesh Mehra, Karen Molinari Vince Gritsch (Alternate)
Meetings Summary
EDAC held one regular meeting this quarter, on August 25, 2026.

The commission received a presentation from Principal Planner Rucha Dande on the work plan for updating the Formula Business Ordinance and held its annual election of the Chair and Vice Chair positions. The commission also noted the resignation of Commissioner Kelly Hickey this quarter.

The meeting also included a review of the business visitation program, with updates on recent visits and the upcoming BOSS Meetup, along with staff updates on plans for a small business listening session and the final Small Business Spotlight cohort, including the launch of the program's first Instagram reel.

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Meeting Date Sailesh Mehra Anthony Kamm Madhura Kumar Kelly Hickey* Heather Liu Rajesh Krishnan Karen Molinari Vince Gritsch
(Alternate)
8/25/2026 U P P E P P P E
Total Unexcused Absences
1st Quarter 1 - U 0 0 N/A 0 0 0 0
Total Unexcused Absences
This Fiscal Year 1 - U 0 0 N/A 0 0 0 0
P = Present
U = Unexcused Absence
E = Excused Absence
QA = Mtg canceled for lack of quorum, Commissioner wasn't able to attend QP = Mtg canceled for lack of quorum, Commissioner would have been able to attend C = Mtg Canceled for any reason other than lack of quorum City of San Carlos
Economic Development Advisory Commission Attendance Log Consistent attendance at commission meetings is essential to maintaining a quorum, which is necessary for conducting official business, as well as ensuring steady communication and staying informed on current discussions. Members are expected to attend all scheduled meetings and should make every effort to do so. Pursuant to the Commissioners' Handbook, for Commissions that meet less than once a month, two (2) unexcused absences within a fiscal year (July-June) will result in the commissioner's seat being declared vacant. *Kelly Hickey resigned from the Commission on 8.25.26

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1 Museum of San Carlos History
1st Quarter Report to the San Carlos City Council
July 1, 2026 – September 30, 2026
This report covers the time period from July 1, 2026 - September 30, 2026.

The Museum Board had 2 regularly scheduled meetings during this time period. The July & September meetings took place as scheduled. The meetings were held via Zoom and were attended by a majority of Board members.

The 1st quarter was a busy one, creating and improving displays.

Attendance
• Two City representatives were present at the July 15 meeting; • One City representative was present at the September 8 meeting; • The Villagers, the Museum docent group, held an in-person meeting at the Museum on July 8 and September 9. Several Museum Board members attended that meeting as well.

Activities & More
• The Museum was open to the public every Saturday during this period from 1 to 4pm. • We had several visitors this month, many attending the first time for special events that included a talk on music and on Hidden Gas Stations.
• The museum held an Ice Cream social from 1:00pm - 4:00pm on September 12, 2026. • The new War Dogs exhibit has been installed.
• The new Miss San Carlos exhibit was installed. The display case and video are set up. • The exhibit team completed a complete refresh of the Rex Walheim exhibit. Rex was born and raised in San Carlos and was on the last space shuttle flight. The exhibit walls were painted, faded newspaper articles were restored and enlarged, and the official NASA video from the "Last Flight," donated by Rex Walheim, was set up for viewing on a screen next to the exhibit.

The next report will be submitted at the end of December Respectfully Submitted by,
Cori Menezes Carpenter
MSCH Secretary
9/28/26

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October 13, 2026 Packet Pg. 21
Meeting Date Russ Bertetta Andy Klein* Alexandra Seeber 7/15/2025 P E P9/8/2026 P E
Total Unexcused Absences
1st Quarter 000
Total Unexcused Absences
This Fiscal Year 000
*Andy Klein resigned from the Museum Board on 7.21.2026P = PresentU = Unexcused AbsenceE = Excused AbsenceQA = Mtg canceled for lack of quorum, Commissioner wasn't able to attendQP = Mtg canceled for lack of quorum, Commissioner would have been able to attendC = Mtg Canceled for any reason other than lack of quorum City of San Carlos
Museum of San Carlos History Attendance Report
Consistent attendance at commission meetings is essential to maintaining a quorum, which is necessary for conducting official business, as well as ensuring steady communication and staying informed on current discussions. Members are expected to attend all scheduled meetings and should make every effort to do so. Pursuant to the Commissioners' Handbook, for Commissions that meet less than once a month, two (2) unexcused absences within a fiscal year (July-June) will result in the commissioner's seat being declared vacant.

October 13, 2026 Packet Pg. 22
Parks, Recreation & Culture Commission
First Quarter for FY 2027
July - September 2026
The Parks, Recreation & Culture Commission met once during the first quarter, FY 2027, on August 5, 2026. The meeting was held in-person at the San Carlos Library Community Rooms.

August 5
• Commissioners received a presentation on updates to the field use policy and agreements with sports organizations that reflect the current processes that are in place. • Commissioners received an overview of the updates to the field use fees that reduce player fees by 50% for recreation organizations, about 25% for club organizations and additional changes recommended by staff.
• Commissioners also received updates on Parks & Recreation programs and services from Tyler Muela, Recreation Manager.

Please see attached PR&C Commission Attendance Log.

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October 13, 2026 Packet Pg. 23
Meeting Date Bob Bollier Elaine Kistenmacher Julie Lubetkin Alexandra Seeber Mark Stogner Alexis McFarlane
(Alternate)
8/5/2026 PPPPEP
Total Unexcused Absences
1st Quarter 000000
Total Unexcused Absences
This Fiscal Year 000000
P = PresentU = Unexcused AbsenceE = ExcusedQA = Mtg canceled for lack of quorum, Commissioner wasn't able to attendQP = Mtg cancelled for lack of quorum, Commissioner would have been able to attendC = Mtg Canceled for any reason other than lack of quorum City of San Carlos
Parks, Recreation and Culture Commission Attendance Log Consistent attendance at commission meetings is essential to maintaining a quorum, which is necessary for conducting official business, as well as ensuring steady communication and staying informed on current discussions. Members are expected to attend all scheduled meetings and should make every effort to do so. Pursuant to the Commissioners' Handbook, for Commissions that meet less than once a month, two (2) unexcused absences within a fiscal year (July-June) will result in the commissioner's seat being declared vacant.

October 13, 2026 Packet Pg. 24
Planning and Transportation Commission
FY 2027 Q1 Quarterly Report
July 1, 2026 – September 30, 2026
Summary of Accomplishments
The Planning and Transportation Commission (PTC) held two meetings in the first quarter of FY 2027 and addressed the following items:

August 17, 2026:

1. 1100 Laurel Street - Request for a Conditional Use Permit to Operate a Veterinary Clinic. APN: 051-343-130 - Approved

2. Consideration of a Resolution Recommending the City Council Introduce Proposed Amendments to San Carlos Municipal Code Sections 18.05.020 (MixedUse Districts Land Use Regulations), 18.06.020 (Commercial Districts Land Use Regulations), 18.07.020 Industrial Districts Land Use Regulations and Creation of Section 18.23 (Standards for Specific Uses and Activities) to include a new section for Tobacco Retail Sales. - Approved
September 21, 2026:

1. 916 Center Street - Request for a Design Review for a new two-story commercial building. APN: 046-205-210 - Approved.

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October 13, 2026 Packet Pg. 25
Meeting Date Twisha Anand Summer Bundy Kristen Clements Frank Kenniasty Jorge Tapias 7/6/2026 - C7/20/2026 - C8/3/2026 - C8/17/2026 P P E P P9/8/20269/21/2026 P P P P E Total Unexcused Absences 1st
Quarter 00 0 0 0
Total Unexcused Absences
This Fiscal Year 00 0 0 0
P = PresentU = Unexcused AbsenceE = Excused AbsenceQA = Mtg canceled for lack of quorum, Commissioner wasn't able to attend QP = Mtg canceled for lack of quorum, Commissioner would have been able to attendC = Mtg Canceled for any reason other than lack of quorum City of San Carlos
Planning and Transportation Commission Attendance Log
Consistent attendance at commission meetings is essential to maintaining a quorum, which is necessary for conducting official business, as well asensuring steady communication and staying informed on current discussions. Members are expected to attend all scheduled meetings and shouldmake every effort to do so. Pursuant to the Commissioners' Handbook, three (3) unexcused absences within a fiscal year (July – June) will result inthe commissioner’s seat being declared vacant.

October 13, 2026 Packet Pg. 26
YOUTH ADVISORY COUNCIL (YAC): QUARTERLY REPORT
July 2026 – September 2026
July 2026:
• Summer break. No meeting was held.

August 2026:
• The San Carlos Youth Advisory Council (YAC) resumed monthly meetings and finalized subcommittees for the 2026-2027 school year.
• YAC elected a new Chair, Vice-Chair, Public Relations, and Secretary.

September 2026:
• YAC established their work plan for the 2026-2027 school year. YAC agreed on five main objectives for the 2026-2027 school year: 1) Increase educational opportunities related to sustainability while hosting events that reduce waste in the community; 2) host engaging recreational and intergenerational programs; 3) increase community engagement through collaborating with local organizations; 4) improve marketing and increasing public attendance at YAC events; 5) increase mental wellness related educational opportunities for both middle schoolers and high schoolers.
• On September 18, YAC hosted and operated the YC Decades Dance coat and bag check for the over 200 6 – 8 grade participants in attendance.
• YAC hosted the first San Carlos Speaker Series on September 25 featuring five high school speakers. Throughout the event, each speaker shared their ideas, passions, and creativity in a 15-minute academic talk on topics such as muscle recovery, how bread has shaped history, microplastics, understanding human emotions, and the sport of arm wrestling. After the event, attendees debriefed the presentations over light snacks and refreshments. • On September 28, YAC kicked off the intergenerational program, “Generation Buddies”, in partnership with the San Carlos Adult Community Center (ACC). This month at Generation Buddies, youth and adults gathered at the ACC and took part in a 300-piece puzzle competition, built marshmallow towers, shared stories with each other, and enjoyed dinner while making new connections.

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October 13, 2026 Packet Pg. 27
Meeting Date
Maya
Kacholiya
Anusha
Iyengar
Karan
Sangani
Eva
Greenbaum
Sanvi
Srivastava
Nitya
Modi
Nikhil
Nunna
Avi
Cancilla
Keira
Nayberg
Vir
Rao
Johan
Sijp
Dori Lin
(Alternate 1)
Zuri Kadiwar
(Alternate 2)
7/8/2026 - C (Summer Break)_ C C C C C C CC C C C C C
8/12/2026 - C (Summer Break C C C C C C CC C C C C C8/26/2026 P P U P P P PP P P P P P9/9/2026 P P P P P P P P P P P P P Total Unexcused Absences
1st Quarter 00 1 - U 0 0 0 00 0 0 0 0 0
Total Unexcused Absences
This Fiscal Year 00 1 - U 0 0 0 00 0 0 0 0 0
P = PresentU = Unexcused AbsenceE = Excused AbsenceQA = Mtg canceled for lack of quorum, Commissioner wasn't able to attendQP = Mtg canceled for lack of quorum, Commissioner would have been able to attendC = Mtg Canceled for any reason other than lack of quorumConsistent attendance at commission meetings is essential to maintaining a quorum, which is necessary for conducting official business, as well as ensuring steady communciation and staying informed on current discussions. Members are expected to attend all scheduled meetings and should make every effort to do so. Pursuant to the Commissioner's Handbook, three (3) unexcused absences within a fiscal year (July - June) will result in the commissoner's seat being declared vacant.

City of San Carlos
Youth Advisory Council Attendance Log
October 13, 2026 Packet Pg. 28

CITY COUNCIL

STAFF REPORT
MEETING DATE: October 13, 2026
ITEM TITLE: Authorize the City Manager to Sign a Letter Prepared by Staff in Response to the 2025-2026 San Mateo County Civil Grand Jury Report Titled "Is our Flock of ALPR Cameras Properly Tended?" RECOMMENDATION:

Staff recommend that the City Council authorize the City Manager to sign a letter prepared by staff in response to the 2025-2026 San Mateo County Civil Grand Jury report titled “Is our Flock of ALPR Cameras Properly Tended?”.

FISCAL IMPLICATIONS:

There are no fiscal implications, and no additional funding is needed.

BACKGROUND:

On August 3, 2026, the 2025-2026 San Mateo County Civil Grand Jury (“Grand Jury”) issued a report titled “Is Our Flock of Automated License Plate Readers (ALPR) Cameras Properly Tended?” (“Report”), enclosed as Attachment 4. Per the letter received from the Superior Court (Attachment 5), the City of San Carlos is required to submit comments on the findings and recommendations within 90 days, or no later than November 2, 2026.

The City contracts with the San Mateo County Sheriff’s Office (“Sheriff’s Office”) for police services. Accordingly, the Flock Group Inc. contract and implementation policies used by the Sheriff’s Office also apply throughout the City of San Carlos. As a result, the responses to the findings and recommendations prepared by the Sheriff’s Office apply to San Carlos as well.

The City has reviewed the Sheriff’s Office’s responses to the findings and recommendations and agrees with the responses, with one modification to the response to Recommendation 6. The City’s cover letter (Attachment 1), together with the Sheriff’s Office’s response letter (Attachment 2) and updated ALPR policy (Attachment 3), constitute the City’s formal response to the Report.

ANALYSIS:

The Grand Jury made six (6) findings and six (6) recommendations in the Report and requested that the City of San Carlos respond only to Findings 3, 5, 6, 7, 8, and 9 and Recommendations 3, 5, 6, 7, 8, and 9. Attachment 1 to this staff report is a cover letter prepared by staff to respond to the Grand Jury’s Report and includes the following proposed responses:

Grand Jury Finding 3: The ALPR operator shared ALPR information with private university security entities but did not establish that the receiving entity was a "public agency" as defined in

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October 13, 2026 Packet Pg. 29
Civil Code section 1798.90.55(b), or that the sharing was otherwise permitted by law within the meaning of Civil Code section 1798.90.55(b).

Grand Jury Recommendation 3: The ALPR operator currently identified as sharing ALPR data with private university security entities should obtain and retain a written legal and factual determination that the recipient is a "public agency" under Civil Code section 1798.90.5(f), or that the sharing is otherwise permitted by law; if no lawful basis exists, the operator should terminate the sharing relationship.

As of July 2026, no private universities have had access to Sheriff’s Office ALPR data. Further, the Sheriff’s Office will not develop sharing relationships with any private university security entity unless it obtains written legal and factual determinations that the security entity qualifies as a public agency pursuant to Civil Code section 1798.90.5(f), or that sharing is permitted by law.

City of San Carlos’ Response: The City of San Carlos agrees with this finding and recommendation and implementation is being handled by the San Mateo County Sheriff’s Office.

Grand Jury Finding 5: The audit reports produced by the ALPR operator were insufficient to substantiate compliance with applicable California law and the operator's published ALPR policy.

Grand Jury Recommendation 5: The audit reports produced by the ALPR operator should substantiate compliance with applicable California law and the operator's published ALPR policy.

Sheriff’s Office’s Response: The San Mateo County Sheriff's Office agrees with this finding and recommendation. The recommendation has been implemented in the following manner:
the Sheriff's Office audit reports have been reformatted to reflect compliance with applicable California law and its updated, published ALPR policy. The updated policy of the Sheriff's Office is attached to this document.

City of San Carlos’ Response: The City of San Carlos agrees with this finding and recommendation and implementation is being handled by the San Mateo County Sheriff’s Office.

Grand Jury Finding 6: The ALPR operator's Flock Safety contract does not include provisions specifically requiring compliance with applicable California ALPR laws.

Grand Jury Recommendation 6: Upon contract renewal, the ALPR operator should incorporate contractual language requiring vendor compliance with applicable California law and prohibiting vendors from disclosing ALPR data to unauthorized third parties. Operators should consider provisions similar to those contained in the Town of Colma contract with Flock.

Sheriff’s Office’s Response: The San Mateo County Sheriff’s Office agrees with this finding and recommendation. This recommendation will be implemented in the following manner: the contract between Flock Group Inc. and the Sheriff's Office is in the process of being updated to include the recommended language requiring vendor compliance with applicable California law and to prohibit the vendor from disclosing ALPR data to unauthorized third parties. The update

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is expected to be finalized before the end of this year. Additionally, any future contracts will ensure that the same recommended contractual language is included.

City of San Carlos’ Response: The City of San Carlos agrees with this finding and recommendation. This recommendation will be implemented in the following manner: upon renewal of the City of San Carlos' contract with Flock Group Inc., the City will incorporate the recommended language requiring vendor compliance with applicable California law and prohibiting vendors from disclosing ALPR data to unauthorized third parties. Additionally, any future contracts will ensure that the same recommended contractual language is included.

Grand Jury Finding 7: The operator's ALPR policy described a process requiring written requests and executed agreements for ALPR data-sharing relationships; however, the records produced did not substantiate that this process was followed or that the required agreements were obtained.

Grand Jury Recommendation 7: The ALPR operator should update its ALPR policy to accurately reflect the process used to approve ALPR data-sharing relationships.

Sheriff’s Office’s Response: The San Mateo County Sheriff’s Office agrees with this finding and recommendation. The recommendation has been implemented in the following manner:
the Sheriff’s Office ALPR policy has been updated to accurately reflect the process used to approve ALPR data-sharing relationships. The updated policy of the Sheriff's Office is attached to this document.

City of San Carlos’ Response: The City of San Carlos agrees with this finding and recommendation and implementation is being handled by the San Mateo County Sheriff’s Office.

Grand Jury Finding 8: The operator's ALPR policy did not establish criteria governing the approval of in-state ALPR data-sharing requests or the termination of existing network-sharing relationships.

Grand Jury Recommendation 8: The ALPR operator should include in their ALPR policies written criteria governing the approval, denial, periodic review, and termination of in-state ALPR networksharing relationships.

Sheriff’s Office’s Response: The San Mateo County Sheriff's Office agrees with this finding and recommendation. The recommendation has been implemented in the following manner:
the Sheriff’s Office ALPR policy has been updated to include written criteria governing the approval, denial, periodic review, and termination of in-state ALPR network-sharing relationships. The updated policy of the Sheriff's Office is attached to this document.

City of San Carlos’ Response: The City of San Carlos agrees with this finding and recommendation and implementation is being handled by the San Mateo County Sheriff’s Office.

Grand Jury Finding 9: The retention period specified in the operator's ALPR policy does not match the retention period as reported by the Flock transparency portal or Flock contract.

Grand Jury Recommendation 9: The ALPR operator should update their ALPR policy or Flock contract terms, as necessary, so that the stated retention rule accurately reflects operations.

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Sheriff’s Office’s Response: The San Mateo County Sheriff's Office agrees with this finding and recommendation. This recommendation has been implemented in the following manner:
the Sheriff's Office ALPR policy has been updated. The conflicting verbiage, stating ALPR data was retained for I-year, has been removed. Now, Sheriff’s Office policy and the Flock Transparency Portal are aligned with the retention period of 30 days, per the current contract between Flock Group Inc. and the Sheriff’s Office. Some municipalities, where the Sheriff’s Office provides services (such as Woodside), hold separate contracts with Flock Group Inc. which may cause their retention periods to differ from the Sheriff’s Office. Language was included in the updated Sheriff’s Office policy to address these potential differences in retention periods. The updated policy of the Sheriff’s Office is attached to this document.

City of San Carlos’ Response: The City of San Carlos agrees with this finding and recommendation and implementation is being handled by the San Mateo County Sheriff’s Office.

ALTERNATIVES:

The alternatives available to the City Council include:

1. Authorize the City Manager to sign the letter prepared by staff in response to the 2025- 2026 San Mateo County Civil Grand Jury Report titled "Is our Flock of ALPR Cameras Properly Tended?"; or

2. Provide staff with alternative direction.

Respectfully submitted by:

Mike Tabak, Police Captain
Approved for submission by:
____________________________
Kathy Kleinbaum, City Manager
ATTACHMENT(S):

1. Proposed Cover Letter in Response to Grand Jury Report

2. Proposed Letter Prepared by the Sheriff’s Office in Response to Grand Jury Report

3. Updated Sheriff’s Office Policy 420 – Automated License Plate Readers (ALPRs)

4. Grand Jury Report

5. SMC Superior Court Letter 8.3.26

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1 October 13, 2026
Hon. Rachel Holt
Judge of the Superior Court
c/o Jenarda Dubois
Hall of Justice
400 County Center; 8th Floor
Redwood City, CA 94063-1655
To the Honorable Rachel Holt:

Please accept this letter, its contents, and attachments as the City of San Carlos’ formal response to the San Mateo County Civil Grand Jury Report titled “Is Our Flock of ALPR Cameras Properly Tended?” issued on August 3, 2026.

The report noted six (6) findings and six (6) recommendations requiring action or response from the City of San Carlos (“City”). Because the City contracts with the San Mateo County Sheriff’s Office (“Sheriff’s Office”) for police services, the Sheriff’s Office and the City have prepared responses to the findings and recommendations. The Sheriff’s Office’s responses are incorporated into this letter and are also provided in the attached Sheriff’s Office response letter. The City affirms the Sheriff’s Office’s responses to the findings and recommendations, except for Recommendation 6, for which the City provides a separate response specific to the City’s contract with Flock Group Inc.

This response was approved by the San Carlos City Council at its regular public meeting of October 13, 2026.

Grand Jury Finding 3: The ALPR operator shared ALPR information with private university security entities but did not establish that the receiving entity was a "public agency" as defined in Civil Code section 1798.90.55(b), or that the sharing was otherwise permitted by law within the meaning of Civil Code section 1798.90.55(b).

Sheriff’s Office’s Response: The San Mateo County Sheriff’s Office agrees with this finding and recommendation. This recommendation has been implemented in the following manner: the Sheriff’s Office terminated sharing relationships with all private university security entities. As of July 2026, no private universities have had access to Sheriff’s Office ALPR data. Further, the Sheriff’s Office will not develop sharing relationships with any private university security entity unless it obtains written legal and factual determinations that the security entity qualifies as a public agency pursuant to Civil Code section 1798.90.5(f), or that sharing is permitted by law.

City of San Carlos’ Response: The City of San Carlos agrees with this finding and recommendation and

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2 implementation is being handled by the San Mateo County Sheriff’s Office.

Grand Jury Finding 5: The audit reports produced by the ALPR operator were insufficient to substantiate compliance with applicable California law and the operator's published ALPR policy.

Grand Jury Recommendation 5: The audit reports produced by the ALPR operator should substantiate compliance with applicable California law and the operator's published ALPR policy.

Sheriff’s Office’s Response: The San Mateo County Sheriff's Office agrees with this finding and recommendation. The recommendation has been implemented in the following manner: the Sheriff's Office audit reports have been reformatted to reflect compliance with applicable California law and its updated, published ALPR policy. The updated policy of the Sheriff's Office is attached to this document.

City of San Carlos’ Response: The City of San Carlos agrees with this finding and recommendation and implementation is being handled by the San Mateo County Sheriff’s Office.

Grand Jury Finding 6: The ALPR operator's Flock Safety contract does not include provisions specifically requiring compliance with applicable California ALPR laws.

Grand Jury Recommendation 7: The ALPR operator should update its ALPR policy to accurately reflect the process used to approve ALPR data-sharing relationships.

Sheriff’s Office’s Response: The San Mateo County Sheriff’s Office agrees with this finding and recommendation. The recommendation has been implemented in the following manner: the Sheriff’s

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3 Office ALPR policy has been updated to accurately reflect the process used to approve ALPR datasharing relationships. The updated policy of the Sheriff's Office is attached to this document.

City of San Carlos’ Response: The City of San Carlos agrees with this finding and recommendation and implementation is being handled by the San Mateo County Sheriff’s Office.

Grand Jury Finding 8: The operator's ALPR policy did not establish criteria governing the approval of instate ALPR data-sharing requests or the termination of existing network-sharing relationships.

Sheriff’s Office’s Response: The San Mateo County Sheriff's Office agrees with this finding and recommendation. The recommendation has been implemented in the following manner: the Sheriff’s Office ALPR policy has been updated to include written criteria governing the approval, denial, periodic review, and termination of in-state ALPR network-sharing relationships. The updated policy of the Sheriff's Office is attached to this document.

City of San Carlos’ Response: The City of San Carlos agrees with this finding and recommendation and implementation is being handled by the San Mateo County Sheriff’s Office.

Grand Jury Finding 9: The retention period specified in the operator's ALPR policy does not match the retention period as reported by the Flock transparency portal or Flock contract.

Grand Jury Recommendation 9: The ALPR operator should update their ALPR policy or Flock contract terms, as necessary, so that the stated retention rule accurately reflects operations.

Sheriff’s Office’s Response: The San Mateo County Sheriff's Office agrees with this finding and recommendation. This recommendation has been implemented in the following manner: the Sheriff's Office ALPR policy has been updated. The conflicting verbiage, stating ALPR data was retained for I-year, has been removed. Now, Sheriff’s Office policy and the Flock Transparency Portal are aligned with the retention period of 30 days, per the current contract between Flock Group Inc. and the Sheriff’s Office.

Some municipalities, where the Sheriff’s Office provides services (such as Woodside), hold separate contracts with Flock Group Inc. which may cause their retention periods to differ from the Sheriff’s Office. Language was included in the updated Sheriff’s Office policy to address these potential differences in retention periods. The updated policy of the Sheriff’s Office is attached to this document.

City of San Carlos’ Response: The City of San Carlos agrees with this finding and recommendation and implementation is being handled by the San Mateo County Sheriff’s Office.

The City of San Carlos appreciates the Civil Grand Jury's findings and recommendations.

Sincerely,
Kathy Kleinbaum
City of San Carlos City Manager

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Policy
420
San Mateo County Sheriff's Office
Policy Manual
Copyright Lexipol, LLC 2026/10/02, All Rights Reserved.

Published with permission by San Mateo County Sheriff's Office
Automated License Plate Readers (ALPRs) - 1
Automated License Plate Readers (ALPRs)
420.1 PURPOSE AND SCOPE
The purpose of this policy is to provide guidance for the capture, storage and use of digital data obtained through the use of Automated License Plate Reader (ALPR) technology. 420.1.1 DEFINITIONS
Automated License Plate Reader (ALPR): A device that uses cameras and computer technology to compare digital images of license plates to existing law enforcement inquiries and/or investigations lists.

Detection: An ALPR read of a license plate within public view, including potential images of the plate and vehicle on which it was displayed, and information regarding the location of the ALPR at the time the data was obtained.

Hit: An alert from the ALPR system that a scanned license plate number may be in the National Crime Information Center (NCIC) or other law enforcement database for a specific reason including, but not limited to, being related to a stolen vehicle, wanted person(s), missing person(s), domestic violence protective order, registered sex offender or terrorist-related activity.

Hotlist: License plate(s) associated with existing law enforcement investigations.

Plate of Interest: A license plate appearing on a hotlist or that has been entered into the ALPR database and is believed to be associated with criminal activity and/or a vehicle/person of interest. 420.2 POLICY
It is the policy of the San Mateo County Sheriff's Office (SMCSO) to utilize ALPR technology only for official and legitimate law enforcement purposes, with the goal being to increase the efficiency and effectiveness of its public safety efforts in a manner that safeguards the legitimate privacy concerns of law abiding citizens. ALPR technology will be utilized to capture and store digital license plate data and images while recognizing the established privacy rights of the public. Consistent with Civil Code 1798.90.55, the Sheriff's Office shall provide the opportunity for public comment at a regularly scheduled meeting of the governing body of any area prior to the installation of any fixed ALPR camera.

Office personnel may use the ALPR system for official use only. Because such data may contain confidential information, it is not open to public review. Any matches received from the ALPR must be verified before enforcement action is taken unless exigent circumstances exist. Data from FLOCK cameras that is not considered intelligence or investigative information will be purged after 30 days.

While the Sheriff's Office maintains a 30-day ALPR data retention period, some towns and/or municipalities where the Sheriff's Office provides law enforcement services may have different ALPR data retention periods. As such, retention periods may vary by location depending on the

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San Mateo County Sheriff's Office
Policy Manual
Automated License Plate Readers (ALPRs)
Copyright Lexipol, LLC 2026/10/02, All Rights Reserved.

Published with permission by San Mateo County Sheriff's Office
Automated License Plate Readers (ALPRs) - 2
contract between the ALPR vendor and those individual towns and/or municipalities. Current retention periods will be accurately reflected on the Sherrif's Office's ALPR transparency portals. 420.3 ADMINISTRATION
The ALPR technology, also known as License Plate Recognition (LPR), allows for the automated detection of license plates. It is used by the San Mateo County Sheriff's Office to convert data associated with vehicle license plates for official law enforcement purposes, including identifying stolen or wanted vehicles, stolen license plates and missing persons. It may also be used to gather information related to active warrants, homeland security, electronic surveillance, suspect interdiction and stolen property recovery.

All installation and maintenance of ALPR equipment, as well as ALPR data retention and access, shall be managed by the Operations Assistant Sheriff or their designee. The Operations Assistant Sheriff will assign members under their command to administer the day-to-day operation of the ALPR equipment and data.
420.3.1 ALPR ADMINISTRATOR
The Support Services Assistant Sheriff shall be responsible for developing guidelines and procedures to comply 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. A description of the job title or other designation of the members and independent contractors who are authorized to use or access the ALPR system or to collect ALPR information.

B. Training requirements for authorized users.

C. A description of how the ALPR system will be monitored to ensure the security of the information and compliance with applicable privacy laws.

D. Procedures for system operators to maintain records of access in compliance with Civil Code § 1798.90.52.

E. The title and name of the current designee in overseeing the ALPR operation.

F. Working with the Custodian of Records on the retention and destruction of ALPR data.

G. Ensuring this policy and related procedures are conspicuously posted on the Sheriff's Office's website.
420.4 OPERATIONS
Use of an ALPR is restricted to the purposes outlined below. Agency members shall not use, or allow others to use the equipment or database records for any unauthorized purpose (Civil Code § 1798.90.51; Civil Code § 1798.90.53).

A. An ALPR shall only be used for official law enforcement business.

B. An ALPR may be used in conjunction with any routine patrol operation or criminal investigation. Reasonable suspicion or probable cause is not required before using an ALPR.

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San Mateo County Sheriff's Office
Policy Manual
Automated License Plate Readers (ALPRs)
Copyright Lexipol, LLC 2026/10/02, All Rights Reserved.

Published with permission by San Mateo County Sheriff's Office
Automated License Plate Readers (ALPRs) - 3
C. While an ALPR may be used to canvass license plates around any crime scene, particular consideration should be given to using ALPR-equipped cars to canvass areas around homicides, shootings and other major incidents. Partial license plates reported during major crimes should be entered into the ALPR system in an attempt to identify suspect vehicles.
(a) No member of this Sheriff's Office shall operate ALPR equipment or access ALPR data without first completing Sheriff's Office-approved training. (b) The following classifications are authorized to be trained in the use of the ALPR system:
i. Duly sworn peace officers.
ii. Professional stasff whose duties require or call for the use of the system or data, for example, Community Service Officers assigned to investigative positions or Crime Analysts.
(c) Training in the use of the system shall consist of:
i. Privacy and civil liberties protections.
ii. Legal authorities, developments and issues involving the use of ALPR data and technology.
iii. Current Office policy regarding appropriate use of ALPR systems. iv. Technical, physical, administrative and procedural measures to protect the security of ALPR data against unauthorized access or use. v. Practical exercises in the use of the ALPR system.

D. No ALPR operator may access Sheriff's Office, state or federal data unless otherwise authorized to do so.

E. If practicable, the deputy should verify an ALPR response through the California Law Enforcement Telecommunications System (CLETS) before taking enforcement action that is based solely on an ALPR alert.
420.5 ROLES AND RESPONSIBILITIES
A. General Use
(a) ALPR systems shall be deployed solely for official law enforcement purposes, including, but not limited to:
i. Locating stolen vehicles, carjacked vehicles, stolen license plates, wanted or missing persons, or vehicles on the Hotlist;
ii. Canvassing areas surrounding recent crimes to capture license plates that may be connected to the crime event.

B. ALPR Administrator
(a) The ALPR Administrator duties and Official Custodian duties are the responsibility of the Operations Assistant Sheriff or designee for the applicable area.

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Policy Manual
Automated License Plate Readers (ALPRs)
Copyright Lexipol, LLC 2026/10/02, All Rights Reserved.

Published with permission by San Mateo County Sheriff's Office
Automated License Plate Readers (ALPRs) - 4
(b) The ALPR Administrator shall ensure all ALPR system equipment is inspected, at a minimum, on a quarterly basis.
(c) The ALPR Administrator shall coordinate all training for use of the ALPR systems and related technologies.

C. The ALPR Administrator shall submit an ALPR quarterly report to the Area Commander of any deployment of ALPR technology:
(a) The report will include at a minimum, total detections and hits generated from the ALPR equipment and a confirmation that there is no data in the system older than is permitted by this policy.

D. The Sheriff's Office will give an annual report to the Governing Bodies on the number of license plates captured in any given time period, number of times the data was accessed by law enforcement, including but not limited to, a report from the law enforcement agency as to how many of the license plates included in the data accessed were Hits on an active wanted list, the number of inquiries made by law enforcement personnel by agency relative to the data, the justification(s) for those inquiries, and information on any data retained beyond retention periods (maximum of 12 months) and the reasons for such retention.

E. The ALPR Administrator, or designee, shall conduct regular audits of user queries as well as update access to the database. This includes eliminating access to persons separated from the organization for any reason.
(a) During these audits, the ALPR Administrator, or designee, will verify that each search was conducted for an authorized law enforcement purpose and included an approved numeric identifier, such as a valid case number, CAD/incident number, or other approved tracking identifier (as described in this policy).

Searches lacking the required documentation shall be referred to the user's supervisor for review and corrective action.

F. The ALPR Administrator, or designee, shall review all requests for ALPR data-sharing relationships. Approval, denial, or termination of any ALPR data-sharing relationship must be made by the ALPR Administrator, or their designee. The ALPR Administrator, or designee, shall also periodically review all current in-state ALPR network-sharing relationships, for approval, denial, or termination.
(a) Criterial for Data Sharing Relationship Approval
i. When considering the approval, denial, or termination of any in-state ALPR network-sharing relationship, the ALPR Administrator, or designee, shall adhere to the requirements of this policy and all applicable laws and ordinances.
ii. The ALPR Administrator, or designee, shall not approve a data sharing relationship with any agency that does not strictly comply with applicable California law regulating the use of ALPR technology and data.

G. ALPR Operators

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Policy Manual
Automated License Plate Readers (ALPRs)
Copyright Lexipol, LLC 2026/10/02, All Rights Reserved.

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(a) Shall ensure the ALPR cameras are properly affixed to the assigned Sheriff's patrol vehicle prior to starting their shift; inspecting units for damage or excessive wear.
(b) Upon discovery of any ALPR equipment that is inoperable or damaged in any way, the Operator shall:
i. Immediately notify the ALPR Administrator in writing. ii. Document the damage/issue on the County Vehicle Damage form and notify the Technology Services Unit (TSU).
(c) Shall start the ALPR system software to activate the system and receive the automatic updated Hotlist at the beginning of each shift. (d) ALPR units installed on marked Sheriff's patrol vehicles shall be activated and used at all times unless the operator of the vehicle has not been trained and certified to use the system.
(e) Staff assigned unmarked Sheriff's vehicles equipped with an ALPR system may use their discretion on removing the external ALPR cameras based on mission needs.
(f) Shall ensure that the ALPR system software, hardware, and GPS are fully operational.
(g) Shall not attempt to repair defective or inoperable ALPR equipment.

H. ALPR Searches
(a) Prior to conducting any search, query, or analytic review in an ALPR system, authorized personnel shall enter an approved numeric identifier, such as a valid agency case number, CAD/incident number, citation number, warrant number, or other Sheriff's Office-approved investigative tracking identifier in the required "Case Number" field.
(b) Outside agency case numbers are acceptable when no Sheriff's Office case number is available. The entry shall also include a specific law enforcement purpose sufficient to identify the reason for the search. i. Examples of acceptable formats for numeric identifier entries include, but are not necessarily limited to: SHXXXX, 26-0XXXX, SH26-0XXXX, SH260000XXXXX, 25SM000XXXXA, SFPD 26-XXXXXX.
ii. Whenever possible, Sheriff's Office case numbers or incident numbers should be used before resorting to the use of court case numbers, warrant numbers, or outside agency case numbers.
iii. Generic or conclusory search reasons, including but not limited to: "investigation," "follow-up," "patrol," "training," "case work," "administrative," or "TBD," shall not be sufficient entries unless accompanied by a valid case, incident, CAD, or other approved tracking number and a specific description of the authorized law enforcement purpose.

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Policy Manual
Automated License Plate Readers (ALPRs)
Copyright Lexipol, LLC 2026/10/02, All Rights Reserved.

Published with permission by San Mateo County Sheriff's Office
Automated License Plate Readers (ALPRs) - 6
iv. Use of false, misleading, generic, placeholder, incomplete, or unrelated case numbers or search reasons is prohibited and may result in suspension of ALPR access, administrative review, discipline, and/or referral for further investigation as appropriate.

1. Examples of prohibited entries in the "Case Number" field include, but are not necessarily limited to: "26," "0000," "1234," "50408," a license plate number, or partial case numbers.
v. The case, CAD/incident, citation, or warrant number shall be valid and entered in its entirety.
vi. In any instance when a search is conducted without the user entering an approved numeric identifier, that user shall then author a memorandum to the Sheriff's Office ALPR Administrator to document the circumstances preventing the entering of an approved numeric identifier.

The memorandum shall also include the applicable case number, or other approved numeric identifier, for the related ALPR search. This memorandum is to be completed as soon as practicable, but no later than the end of the user's shift, unless approved by a supervisor.

I. ALPR Hits
(a) When an alarm is received alerting operators of a positive Hit from the Hotlist database, a digital image of the license plate will be displayed on the mobile data computer screen.
(b) Absent exigent circumstances, or other information to establish probable cause for a detention, ALPR operators shall compare the digital image of the license plate to the Hotlist information to verify the Hit for both the state in which the license plate was issued and characters on the plate. ALPR systems will alert based on the alpha numeric characters displayed for license plates issued and false positives are possible based on license plates with the same numbers from other states. ALPR systems may also misread letters and numbers of similar shapes. This is the primary reason that, absent exigent circumstances, all positive Hits must be confirmed prior to taking law enforcement action. (c) Absent exigent circumstances, or other information to establish probable cause for a detention, ALPR operators shall confirm the ALPR information by radio or mobile data computer to immediately confirm the Hit prior to taking enforcement or any other type of action.
420.6 ACCOUNTABILITY
All data will be closely safeguarded and protected by both procedural and technological means.

The San Mateo County Sheriff's Office 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 downloaded to the mobile workstation and in storage shall be accessible only through a login/password-protected system capable of documenting all access of information by name, date and time (Civil Code § 1798.90.52).

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Policy Manual
Automated License Plate Readers (ALPRs)
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Published with permission by San Mateo County Sheriff's Office
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B. Members approved to access ALPR data under these guidelines are permitted to access the data for legitimate law enforcement purposes only, such as when the data relate to a specific criminal investigation or Sheriff's Office-related civil or administrative action.

C. ALPR system audits should be conducted on a regular basis.

D. For security or data breaches, see the Records Release and Maintenance Policy. 420.7 PROHIBITED USE
A. ALPR usage is prohibited from invading the privacy of individuals or looking into private area or areas where a reasonable expectation of privacy exists, nor shall they be used to harass, intimidate or discriminate against any individual or group, nor for any purpose not specifically authorized by this policy.

B. Unauthorized access, possession or release of data is a violation of policy and various federal and state criminal statutes. Any employee who accesses, possesses or releases data from the ALPR database without authorization or in violation of this policy and such additional policies established by this Office, may face discipline up to and including termination, criminal prosecution and/or civil liability.

C. The Sheriff's Office does not permit the sharing of ALPR data gathered by the Office or its contractors/subcontractors/municipalities for purpose of federal immigration enforcement, pursuant to the California Values Act (Government Code § 7282.5; Government Code § 7284.2 et seq) – these federal immigration agencies include Immigrations and Customs Enforcement (ICE) and Customs and Border Patrol (CPB).

D. The Sheriff's Office will also consider the California Reproductive Privacy Act (Health and Safety Code § 123460 - § 123469) before approving the sharing of ALPR data for the purpose of investigating any person seeking to exercise their reproductive health care rights within California. The Sheriff's Office does not permit the sharing of ALPR data gathered by the Office or its contractors/subcontractors for the purpose of prosecuting, investigating or initiating any legal proceeding against any person for the exercise of reproductive health care rights as defined by California law.

E. The Sheriff's Office will not share ALPR data with federal or out-of-state agencies in compliance with Civil Code §§1798.90.55(b) and 1798.90.5(f). (a) "Side-sharing," where an ALPR user conducts a network query on behalf of an organization that is not authorized to access the data directly, is strictly prohibited.

F. ALPR technology shall not be used for the purpose of monitoring, tracking, identifying, or investigating individuals or groups based solely on the exercise of rights protected by the First Amendment of the United States or California Constitution, including but not limited to lawful speech, association, assembly, or participation in protests, demonstrations, or other expressive activities.
420.8 REVISIONS
• Adopted: January 13, 2017

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Policy Manual
Automated License Plate Readers (ALPRs)
Copyright Lexipol, LLC 2026/10/02, All Rights Reserved.

Published with permission by San Mateo County Sheriff's Office
Automated License Plate Readers (ALPRs) - 8
• Revised: February 20, 2024
• Revised: February 3, 2026
• Revised: March 16, 2026
• Revised: August 31, 2026
• Revised: September 30, 2026

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Is Our Flock of ALPR Cameras
Properly Tended?
San Mateo County Civil Grand Jury
2025-2026
Release Date: August 3, 2026

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ISSUE | SUMMARY | BACKGROUND | METHODOLOGY | DISCUSSION | FINDINGS RECOMMENDATIONS | REQUEST FOR RESPONSES | RESPONSE REQUIREMENTS | BIBLIOGRAPHY | APPENDIX
ISSUE
Over the past year, Automated License Plate Readers (ALPRs) have come under increasing public scrutiny. This report examines whether ALPR operators in San Mateo County (SMC) are in full compliance with applicable California law and whether their practices align with their adopted ALPR policies.

SUMMARY
Automated License Plate Readers have become widely deployed in SMC, with more than 500 cameras now in operation by law enforcement agencies (LEAs) within the County. The rapid increase in ALPR deployment has been accompanied by California legislation governing ALPR use, and also by increased media coverage of alleged violations. Over the past year, SMC LEAs have made notable operational improvements, particularly with respect to out-of-state data sharing. Most changes were driven by stronger default compliance made by Flock Safety (Flock), now the dominant ALPR platform among the SMC operators reviewed. But SMC ALPR operators continue to have many of the same operational deficiencies identified by a 2019 California State Audit that investigated four operators elsewhere in California. Many of the required policy documents are deficient or need significant revision to accurately reflect current operations, and audit materials produced were inconsistent in scope and rigor. Although the materials reviewed did not identify current sharing by SMC operators with out-of-state entities, most operators did not document criteria, process, or controls governing in-state sharing in a manner sufficient to demonstrate compliance with law. This report presents findings and recommendations to promote transparent operation of ALPR systems consistent with public safety, privacy, and applicable law.

BACKGROUND
Automated License Plate Readers
Automated License Plate Readers (ALPRs) are camera-based systems that automatically capture and analyze license plates on passing vehicles. Cameras are typically located at fixed roadside locations along high-traffic corridors, major intersections, city entry/exit routes, areas with high crime rates, and transportation infrastructure (bridges, tunnels, freeways). These systems combine high-speed cameras, infrared illumination, and optical character recognition software to convert license plate images into searchable digital data. Law enforcement agencies use ALPR systems to locate stolen vehicles, identify vehicles connected to criminal investigations, generate investigative leads, and assist in locating missing persons. When connected through regional or national networks, ALPR systems allow investigators to reconstruct vehicle movements across jurisdictions.

Digital imaging, optical character recognition, and large-scale data storage allow ALPR systems to process large numbers of license plates quickly and automatically. Modern systems can read thousands of plates per hour and store the results in databases that investigators can search later.

When a motor vehicle is detected by an ALPR as it passes through the camera's field of view, a digital record is generated recording the vehicle's license plate number, an image of the plate, a

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contextual image of the vehicle (make, model, color, etc.), the date and time of the scan, the location of the camera, and the identification number of the camera device. Once the image is captured, the digital record is immediately transmitted to a cloud-based database that compares the scanned license plate and other vehicle data against law enforcement watch lists, often referred to as “hot lists,” that may include information on vehicles that have been reported stolen, those associated with criminal investigations, outstanding warrants, or connected to missing persons or Amber Alerts.

When a match occurs, the system can send an alert to officers or dispatch centers in real time.

ALPR cameras are usually deployed as part of a network such that when the same vehicle is detected by multiple cameras, investigators can analyze those detections to determine travel routes and timelines. By default, only data captured by cameras within that local jurisdiction are available.

LEAs typically elect to contribute their data to regional databases or multi-jurisdictional systems that allow sharing across multiple cities, counties, or states. The ability to share data among multiple jurisdictions is more effective in assisting law enforcement in their investigations as suspects rarely limit their travel within a single jurisdiction.

As of March 30, 2026, more than 582 ALPR cameras were deployed across SMC. These cameras are operated by municipal police departments within their respective jurisdictions and by the San Mateo County Sheriff’s Office (SMCSO) in unincorporated areas and in jurisdictions where the Sheriff provides contracted law enforcement services. The only police department in SMC with no ALPR cameras is Broadmoor.

Operator Cameras as of
3/30/2026
Comments
Atherton 53 Earliest in SMC, 2020.

Belmont 10
Brisbane 16
Burlingame 18
Colma 11
Daly City 44
East Palo Alto 25
Foster City 20
Half Moon Bay 14 Separate Flock contract, operated by
SMCSO.

Hillsborough 22
Menlo Park 32
Pacifica 10
Redwood City 25
San Bruno 54
San Mateo 66

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Operator Cameras as of
3/30/2026
Comments
San Mateo County Sheriff's
Office
109 Includes unincorporated SMC (except
Broadmoor), Portola Valley, San Carlos
and Millbrae.

South San Francisco 37
Woodside 26 Separate Flock contract, operated by
SMCSO
Key Issue
ALPRs and the sharing of image data across jurisdictional lines have created controversy with respect to issues of privacy. While not the focus of this report, some civil liberties groups, including the American Civil Liberties Union (ACLU), argue that vehicle tracking could affect freedom of association if it reveals attendance at protests, political meetings, or religious gatherings (First Amendment).

Others, including the Electronic Frontier Foundation (EFF) question whether large-scale tracking of vehicle locations over time could constitute a search under constitutional law (Fourth Amendment).

While the focus of this report is not to investigate the constitutional issues surrounding ALPRs, data sharing among law enforcement agencies has become a significant public concern and has, in some communities, resulted in the suspension or termination of ALPR programs. Although no such actions have occurred in SMC, several Bay Area jurisdictions—including Mountain View, Los Altos Hills, Santa Clara County, and Santa Cruz—have discontinued their use of ALPR systems.

This report evaluates, based on records obtained during the investigation, whether SMC LEAs satisfy California law governing the use of ALPR systems and the sharing of ALPR data. Civil Code section 1798.90.51 requires APLR operators to implement and publicly post a usage and privacy policy. This report also evaluates whether the policies produced accurately describe actual operations.

Legislative Framework
California has enacted legislation governing the use of ALPR systems, with a focus on transparency, accountability, and limitations on data sharing. The primary statutory framework was enacted by Senate Bill 34 (SB 34) (Stats. 2015, Ch. 532), codified at Civil Code sections 1798.90.5 through 1798.90.55.

Effective January 1, 2016, SB 34 imposes requirements governing the collection, storage, access, and sharing of ALPR data. SB 34 applies to both operators of ALPR systems and entities that access ALPR data. Among other requirements, ALPR operators must adopt written usage policies, maintain detailed audit logs, implement reasonable security measures, and provide an opportunity for public comment prior to implementing an ALPR program. The California Department of Justice has issued guidance on SB 34 in Information Bulletin No. 2023-DLE-06.

In addition to SB 34, Senate Bill 54 (SB 54) (Stats. 2017, Ch. 495), known as the California Values Act (Gov. Code § 7284 et seq.) restricts the use of state and local law enforcement resources for

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federal immigration enforcement purposes. SB 54 limits the sharing of certain information with federal immigration authorities and reinforces the principle that local law enforcement data systems, including ALPR databases, must not be used in a manner inconsistent with California law. The California Department of Justice has issued guidance clarifying these restrictions in Information Bulletin No. 2025-DLE-08.

In 2025, the California Legislature passed Senate Bill 274, which would have imposed additional restrictions and oversight. The bill proposed limiting retention periods for non-matching records and expanding state-level review of ALPR use. However, SB 274 was vetoed by Governor Gavin Newsom, who concluded that SB 274 did “not strike the delicate balance between protecting individual privacy and ensuring public safety,... particularly with respect to cold cases.” Collectively, these statutes establish a legal framework that emphasizes transparency, accountability, and restricted data sharing, while placing primary responsibility for compliance on individual law enforcement agencies.

Data Sharing and Side-Sharing
The effectiveness of ALPR systems depends in large part on the ability of LEAs to share data across jurisdictions. Within most ALPR platforms, each agency organizes its cameras into one or more networks that govern both system configuration and data sharing. Agencies may control which other agencies can discover their networks and whether access requests are automatically approved or require explicit authorization. Once access is granted, authorized users from another agency may query shared ALPR data without further approval.

While this model enhances investigative capability—particularly in cases involving vehicles that travel across jurisdictional boundaries—it also places responsibility on each agency to ensure that data sharing practices comply with California law. Civil Code section 1798.90.55(b) provides that a public agency shall not sell, share, or transfer ALPR information, except to another public agency, and only as otherwise permitted by law. The SMCCGJ found that data sharing practices vary widely among agencies, with some limiting access to nearby jurisdictions and others permitting broad sharing within the state. The decentralized nature of these sharing controls creates a structural risk:
compliance with California law depends not on system-enforced restrictions, but on how individual agencies configure and manage their networks. As a result, even where written policies are compliant, system configurations may permit data sharing practices that are inconsistent with statutory requirements. In general, as the size of a network increases and more law enforcement agencies are granted access, the risk of misuse correspondingly increases.

A related concern is the practice commonly referred to as “side-sharing.” For purposes of this report, “side-sharing” refers to the practice in which a California ALPR operator conducts a network query on behalf of an organization that is not authorized to access the data directly—typically an out-ofstate or federal agency—and then provides the results outside of the ALPR system. In such cases, audit records reflect that the query was initiated and used by a California agency, when in fact the request originated from, and the results were delivered to, an external entity.

Because the ALPR audit logs reviewed by the SMCCGJ record only the identity of the querying agency and do not capture the ultimate recipient of the data, side-sharing is inherently difficult to detect. Activity that appears compliant on its face may, in fact, circumvent the restrictions imposed by California law, including limitations on sharing ALPR data with entities outside the state.

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Side-sharing may involve attempts to access ALPR data outside of established sharing arrangements, including by law enforcement personnel who do not have authorized access. For example, a federal immigration agency may seek to obtain ALPR data from a California jurisdiction in a manner inconsistent with the restrictions imposed by SB 54. Such access could be facilitated by directly contacting personnel within a California LEA and requesting that they conduct an ALPR query on behalf of the external agency.

This issue has been the subject of media reporting and public concern, although verification in specific instances is challenging due to the limitations of available audit data. Media coverage of public statements by certain law enforcement officials has further highlighted the potential risk.

The SMCCGJ found that existing controls to prevent or detect improper data sharing, including sidesharing, are limited. While the ALPR platform provides audit logs, role-based access controls, and, more recently, anomaly detection tools, these features rely on agency-level oversight and do not provide a comprehensive or system-enforced safeguard. There is no centralized mechanism to prevent a user from conducting a query on behalf of an unauthorized entity or to ensure that query results are used solely for authorized purposes.

As a result, compliance with California law in this area depends largely on the policies, training, and oversight practices of individual agencies. In the absence of stronger technical controls or more robust audit capabilities, the risk of unauthorized data access—whether through misconfiguration or side-sharing—remains a significant concern.

Flock Safety
Flock Safety is the largest provider of ALPR systems in the United States and the primary provider of ALPR systems used by LEAs in SMC. The company provides both the physical camera infrastructure and a cloud-based software platform that enables agencies to collect, store, search, and share vehicle detection data. This represents a significant market shift from Vigilant Solutions, who was the most common provider in 2019.

Note that while nearly all ALPR cameras in SMC are provided by Flock, Pacifica also operates 4 Axon mobile cameras that were not investigated by SMCCGJ. Also, ALPR data collected by Flock cameras may also be forwarded to intelligence fusion systems that include other types of surveillance data. Some SMC LEAs use C3.ai, and SMC has recently funded a pilot with Peregrine Systems. These systems are capable of sharing data among agencies and across state boundaries but were not investigated by SMCCGJ and have not received wide media attention.

Flock cameras are typically installed at fixed locations such as major intersections, highways, and entry or exit points to a community. These cameras do not continuously track vehicles; rather, they capture individual “snapshots” or detections as vehicles pass through a camera’s field of view. Each detection includes a license plate number, vehicle characteristics (such as make, color, and body type), and metadata including the date, time, and location of the observation.

This information is transmitted to Flock’s cloud-based platform, where it is indexed and made searchable. Authorized users access the system through a web-based interface, allowing them to query historical detections or monitor real-time alerts. For example, agencies may create “hotlists” of vehicles of interest—such as stolen vehicles or those associated with criminal investigations— which trigger notifications when detected by any connected camera.

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A key feature of the system is its ability to aggregate data across multiple cameras and jurisdictions.

While a single camera provides only a point-in-time observation, multiple detections across different locations can allow investigators to infer travel patterns or identify a vehicle’s movement over time.

All user activity—including searches, alerts, and administrative actions—is recorded in audit logs.

These logs are intended to support oversight and accountability by providing a record of how the system is used. Although Flock hosts the data and provides the technical infrastructure, each customer agency retains control over its own data and is responsible for determining who may access it and under what conditions.

Data Sharing Framework
A defining feature of the Flock platform is its ability to facilitate data sharing among law enforcement agencies. This capability is implemented through a system of configurable “Networks,” which function as both administrative groupings and sharing mechanisms. Each agency organizes its cameras into one or more networks and determines whether those networks are visible to other agencies within the platform. When a network is made visible, other agencies may discover it— typically through a map-based interface—and request access.

These access requests are routed to a designated administrator within the owning agency. Depending on how the system is configured, the administrator may review and approve each request individually, or the system may automatically approve requests based on predefined criteria. Once access is granted, users from the approved agency can query the shared data directly, without needing to request permission for each individual search.

This model allows investigators to search for vehicles across jurisdictional boundaries, which can be particularly useful in cases involving regional travel or coordinated criminal activity. At the same time, it introduces complexity, as each agency must determine which other agencies should be granted access and under what conditions.

Agencies can limit sharing in several ways, including restricting access to specific agencies, geographic regions, or operational groupings. Importantly, sharing permissions are not transitive: if Agency A shares data with Agency B, and Agency B shares data with Agency C, Agency C does not automatically gain access to Agency A’s data.

Private entities, such as commercial businesses or homeowners’ associations, participate in the system differently. Their cameras are not visible within the shared network interface, and they do not independently request access to law enforcement data. Instead, data from private cameras is typically shared directly with local LEAs through arrangements managed with Flock outside the standard user interface.

While this network-based architecture enables collaboration and enhances investigative capabilities, it also places primary responsibility on each agency to manage its sharing relationships in a manner consistent with applicable laws and local policy.

Concerns
Beginning in 2025, a number of media reports and public records analyses brought increased attention to the use of ALPR systems, particularly with respect to how data was being shared among law enforcement agencies. These reports identified instances in which California agencies had configured their systems in a manner that allowed access to ALPR data by out-of-state entities, a practice inconsistent with California law.

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Within SMC, the Menlo Park Police Department acknowledged prior instances in which ALPR data had been shared across state lines. Similar issues were identified in other jurisdictions throughout California, suggesting that these were not isolated occurrences but rather reflected broader challenges in how the systems were configured and used.

In addition to concerns regarding system configuration, analysis of audit data highlighted issues related to how queries were conducted and documented. In some cases, users entered generalized descriptions such as “Investigation,”1 without specifying a particular law enforcement purpose.

While such entries are not necessarily improper, they limit the ability of agencies, auditors, and the public to determine whether queries were conducted for authorized purposes.

Taken together, these findings raised questions not only about compliance with legal requirements, but also about the adequacy of system controls and oversight mechanisms. They also underscored the degree to which proper use of the system depends on both technical configuration and user behavior.

System Controls and Vendor Response
In response to these concerns, Flock implemented a series of changes beginning in 2025, aimed at reducing the likelihood of improper data sharing and improving the ability of agencies to monitor system use. These changes reflect a shift from a system that relied heavily on user discretion to one that incorporates more structured controls and constraints.

One of the most significant changes involved restrictions on data sharing across state lines. Prior to 2025, agencies had broad discretion to configure sharing relationships, including the ability to enable “Nationwide” access or establish direct connections with out-of-state agencies. Although such configurations were inconsistent with California law, they were technically permitted within the system.

To address this issue, Flock implemented a phased set of changes. Nationwide sharing was first disabled by default in February 2025 and then permanently removed in March 2025, eliminating the ability for California agencies to broadly expose their data to agencies outside the state. In June 2025, Flock further restricted sharing by disabling the ability to create new out-of-state sharing relationships.

Importantly, these changes did not automatically terminate existing shared relationships. Instead, Flock undertook a process of customer outreach and education, encouraging agencies to review and modify their configurations. As a result, most agencies voluntarily discontinued such arrangements, although some pre-existing relationships remain subject to ongoing legal proceedings. As of this writing, the City of El Cajon is the only California agency with ALPR network sharing relationships extending outside the state. In October 2025, the California Attorney General filed an action against El Cajon alleging non-compliance with SB 34; the case is currently in litigation.

In addition to changes in sharing controls, Flock introduced enhancements aimed at improving how system use is documented and monitored. Historically, users were able to enter free-form text to 1 Analysis done by the SMCCGJ on all 2025 network queries in California on one SMC LEA’s data found that 13.1% of queries entered only “Investigation” as the “Reason” for performing the query.

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describe the purpose of a query in a “Reason” field. In practice, this resulted in inconsistent and often vague entries2, limiting the effectiveness of audit review.

In December 2025, Flock augmented this approach by requiring users to select an “Offense Type” from a standardized list3based on National Incident-Based Reporting System (NIBRS) codes.

Within California, categories inconsistent with SB 54 are disabled. This change provides a more consistent framework for documenting queries and enables more meaningful analysis of system use.

Many agencies have supplemented this requirement by mandating the entry of a case number, linking each query to a specific investigation. This case number is useful for auditing queries within a department but is ineffective for analysis of network queries as LEAs in California do not share a common case management system.

Flock also expanded its audit and monitoring capabilities. Audit logs continue to record all user activity, but additional tools have been introduced to support review. Activity logs track changes to system configuration, including modifications to sharing settings, while the Transparency Portal allows agencies to publish usage statistics and audit summaries.

In April 2026, Flock introduced “Audit Assistance,” an automated tool that analyzes system activity and identifies patterns that deviate from an agency’s typical usage. These alerts are intended to assist administrators in identifying potential misuse, including unusual query patterns or activity that may warrant further review (side-sharing).

Additional controls have been implemented to restrict system access and reinforce appropriate use.

These include limitations on “guest” users outside the agency’s domain and role-based access controls that allow agencies to tailor system permissions based on user responsibilities. Flock’s terms of service also prohibit use of the system on behalf of unauthorized individuals or agencies.

While these changes represent meaningful improvements, they are primarily designed to support and guide user behavior rather than to enforce compliance directly. As such, their effectiveness depends on how agencies configure and use the system.

Training and Compliance Support
Flock provides training on system operation, legal use, and compliance requirements as part of its onboarding process. Agencies may supplement this training with local policies, procedures, and internal controls tailored to their operational environment. While these resources support compliance, they do not substitute for agency responsibility to ensure that system use is consistent with applicable laws and policies.

Remaining Limitations
Notwithstanding these enhancements, important limitations remain in the system’s ability to prevent or detect improper use.

First, while audit logs provide a record of which agency conducted a query and when it occurred, they do not capture how the resulting information is ultimately used or shared. This means that even 2 The search reason “warrant” could refer to a warrant issued by a California judge for an authorized law enforcement purpose, or alternatively to an administrative warrant issued by a federal agency such as ICE. Numeric strings typically correspond to sections of California penal code, but many LEA’s listed a crime category such as “theft” or “burglary”.

The SMCCGJ found no accepted usage of the “Reason” field across or even within LEAs. 3 A list of these offense codes is provided in Appendix A.

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where a query appears appropriate on its face, there is no direct way to determine whether the results were subsequently provided to an unauthorized party.

Second, the system does not technically prevent a user from conducting a query on behalf of another individual or agency (side-sharing). Although such conduct may violate policy or law, it is not inherently detectable through system controls alone. As a result, certain forms of misuse— particularly those involving indirect access—are difficult to identify through audit data.

Finally, the effectiveness of audit and monitoring tools depend on active review by agency personnel. Identifying potential issues requires not only access to audit data but also the time, expertise, and judgment to interpret that data. This introduces variability in how different agencies monitor system use and respond to potential concerns.

These limitations illustrate that, while system-level controls can reduce risk, they cannot fully eliminate it. Effective oversight requires a combination of technical controls, clear policies, and consistent enforcement.

Conclusion
Flock has implemented a number of substantive changes to its platform in response to concerns regarding data sharing and legal compliance. These changes have improved transparency, standardized key aspects of system use, and provided agencies with additional tools to monitor activity.

At the same time, the system continues to rely heavily on agency-level decisions regarding configuration, access, and oversight. Certain risks—particularly those associated with indirect or unauthorized use—cannot be fully mitigated through system design alone.

As a result, responsibility for ensuring compliance with Civil Code sections 1798.90.5 through 1798.90.55 ultimately rests with each individual law enforcement agency. The effectiveness of the system, therefore, depends not only on the capabilities of the technology but also on how it is implemented and governed at the local level.

METHODOLOGY
To determine whether ALPR operators in SMC comply with applicable California law and whether their practices align with their adopted ALPR policies, the SMCCGJ began by reviewing the content available on the public websites of each LEA in the County. Most LEA websites include information regarding ALPR usage and transparency, often with a link to the agency’s Flock Transparency Portal, which is maintained by Flock on behalf of its customers.

The SMCCGJ issued document requests to all ALPR operators in SMC, seeking ALPR policies, recent audit reports, current Flock contracts, and any supporting documentation demonstrating compliance with California law and agency policy. Findings based on nonproduction reflect the absence of responsive records produced to the SMCCGJ, not a conclusive determination that no responsive record exists.

The SMCCGJ was able to identify an ALPR policy document for every SMC ALPR operator, which guided the examination of compliance with that policy. For some operators we were provided an organization audit report, which lists all ALPR queries initiated within that LEA. The organization audit was visually reviewed in a spreadsheet, which is feasible for what is at most a few hundred rows. Some operators provided a network audit report, which lists all ALPR queries initiated by

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other Flock customers on that operator’s data. As the network audit report can be quite large (upwards of 25,000/month), analysis of this data was carried out by first loading it into a database.4 The SMCCGJ examined network sharing reports from the operators that provided them. This information is also publicly available through Flock Safety’s Transparency Portal. The network sharing reports identify the agencies and entities with which each operator shares ALPR data.

The SMCCGJ conducted interviews with several LEAs in SMC, with representatives of Flock, and with the Northern California Regional Intelligence Center (NCRIC).The SMCCGJ collected media reports related to ALPR implementations in SMC, in the state of California, and nationwide.

DISCUSSION
Public Interest
Issues related to the use of ALPR systems have received significant public attention in both SMC and throughout California. Several communities within the County have debated canceling their ALPR contracts or exploring alternative provider. As of this date, all have decided to continue operations with Flock. An article on ALPR usage published by Palo Alto Online on December 29, 2025, was the publication’s most-downloaded article of the year.

For the general public, it can be difficult to determine the root cause of security breaches reported in the media. Coverage has variously attributed these incidents to product design limitations, accidental or intentional misconfiguration, and inadequate operator training. As discussed earlier in this report, ALPR system functionality has evolved in response to public concerns, with enhancements intended to facilitate compliance with applicable laws.

Sharing Within San Mateo County
This investigation found that the extent of data sharing among SMC ALPR operators varies significantly, with the number of network sharing relationships ranging from three in Woodside to 335 in San Bruno. During the course of this investigation, one SMC operator reduced the scope of their network sharing after evaluating the public safety value of broader data access against local privacy considerations. Some LEAs felt that broad access was valuable in addressing the pattern of crimes committed in their community. Others felt that sharing too broadly would not solve more crimes and could risk losing the support of their local community.

As of December 2025, no SMC operators were found to be sharing ALPR data with entities outside California. The investigation did identify instances in which SMC operators shared ALPR data with private organizations, specifically security agencies serving Stanford University and University of the Pacific. Under Civil Code section 1798.90.55(b), a public agency may share ALPR information only with another “public agency” and only as otherwise permitted by law. The materials produced did not establish that the private university security recipients meet the definition of a “public agency” or that an applicable statutory exception authorizes the sharing. It remains the responsibility of each LEA to determine whether such entities qualify as public agencies under applicable law. If deemed public agencies, these entities would be subject to the same statutory and policy requirements governing ALPR use.
4 The network audit report was delivered in comma-separated value format, was then bulk-loaded into a MySQL database and then queried using the Structured Query Language.

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The table below summarizes these findings.

Operator Network
Shares
2/26/2026
Network
Shares
4/13/2026
Private University
Security Shares
4/13/2026
Apparent Sharing
Guideline
Atherton 315 317 2
Belmont 157 145 2 Adjacent Counties
Brisbane 93 92 1 50-mile radius
Burlingame Not available 357 2
Colma 321 326 2
Daly City Not available Not available not available Flock portal is not enabled.

East Palo Alto 303 308 2
Foster City Not available Not available Not available Flock portal excluded network sharing report.

Half Moon Bay Not available 290 0
Hillsborough 303 318 2
Menlo Park 247 242 1
Pacifica 276 283 2
Redwood City 102 100 1 Bay Area Counties
San Bruno 331 335 2
San Mateo 283 280 0
San Mateo County
Sheriff's Office
299 300 2 Reduced in February to
adjacent Counties.

South San Francisco 15 15 0 San Mateo County
Woodside 3 3 0 Adjacent towns
Public Commentary
Under Civil Code section 1798.90.55(a), a public agency that operates an ALPR system must provide the opportunity for public comment. The SMCCGJ did not identify any instances in which ALPR cameras were deployed without the required public notice and discussion.

ALPR Policies
California law requires each ALPR operator to adopt a written ALPR policy and to post that policy in a conspicuous manner (Civ. Code, §§ 1798.90.53(a)–(b); 1798.90.51 (a)–(b)). The California Department of Justice provides a model ALPR policy template, which agencies may adopt or

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modify. Some departments also utilize policy templates developed by Lexipol, a provider of standardized law enforcement policy materials.

The following section evaluates each SMC law enforcement agency’s ALPR policy, including whether it is conspicuously posted, and assesses whether the agency’s actual operations are consistent with its stated policy.

Summary Matrix of ALPR Policy and Operational Findings
Policy Posting and Currency. Most LEAs and police departments provided an ALPR policy in response to the SMCCGJ document request. The SMCGJ reviewed each policy for alignment with the policy templates and guidance provided by the State of California and Lexipol. The SMCCGJ also reviewed each department’s public website to determine whether the policy was conspicuously posted in accordance with California DOJ guidance 2023-DLE-06, and whether the publicly posted version matched the version provided in response to the document request.

Audit Practices. The SMCCGJ requested copies of recent audit reports from each LEA. Where an audit frequency was specified in an agency’s ALPR Policy, the SMCCGJ reviewed the materials provided to determine whether audits appeared to have been conducted at the stated intervals. The SMCCGJ also examined the contents and scope of each audit report.

For purposes of this investigation, a “strong” audit is one that substantiates compliance with both applicable California law and each material element of the LEA’s stated ALPR Policy. California law requires a policy to describe monitoring and “a process for periodic system audits,” but does not prescribe a uniform audit report format or methodology. The labels “strong,” “partial,” and “weak” are assessment terms used in this report and are not statutory classifications.

In the absence of meaningful audit controls, the public has limited assurance that an agency’s stated policies are being consistently implemented in practice. By contrast, a “weak” audit examines only selected legal or policy elements and does not comprehensively evaluate operational compliance.

Finally, the SMCCGJ reviewed whether audit reports were made available to the public or presented to the relevant city, town, or county governing body.

Data Retention. Civil Code section 1798.90.51(b)(2)(D) requires each ALPR policy to specify a data retention period after which ALPR data will be deleted unless it is associated with an active investigation or otherwise retained pursuant to law. The SMCCGJ compared the retention period stated in each agency’s ALPR policy with the retention period displayed on Flock’s Transparency Portal and, where available, the retention provisions contained in the agency’s Flock contract.

Matching retention periods were classified as “consistent,” while differing retention periods were classified as “inconsistent.” We did not examine in detail the process by which Flock deletes data after the stated retention period, as this topic has been addressed by third-party audits.

Data Sharing Process. Each policy must describe criteria and a process for sharing ALPR data. We examined this statement to ensure that it prohibits the sale of ALPR data, out-of-state sharing, sharing to private parties, and usage for other than valid law enforcement purposes. We examined any written guidelines and processes for receiving and approving requests for sharing data, and for any documentary evidence supporting the implementation of that process. Most policies included the sharing process description and documented from templates, but our interviews and document requests did not find an LEA who followed the process described in this “Template.” Several LEAs described the sharing process provided by the Flock platform, which is what we heard described

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during interviews as the adopted process. The LEAs with outdated policies described an outdated sharing process mediated by NCRIC. No LEA’s policy described guidelines for ALPR data sharing within California, though several outlined coherent criteria for what sharing requests to approve.

Contract Terms. The SMCCGJ reviewed the 14 Flock contracts provided in response to its document requests. One contract included an addendum with California compliance provisions (“CA terms”) requiring Flock to adhere to California law governing the protection, access, and disclosure of ALPR data maintained on behalf of California LEA customers, consistent with recommendations previously issued by the California State Auditor.

The absence of express contractual compliance terms does not itself establish a violation of California law, which applies regardless of contract language. In this report, the presence or absence of such terms is evaluated as an additional contractual compliance control.

The table below summarizes the SMCGJ’s assessment of ALPR policy compliance and operational alignment among LEAs in SMC.

Agency Policy Posting /
Currency
Audit Practices Data
Retention
Data
Sharing
Process
Contract
Terms
Atherton Not conspicuous;
current, but with
multiple versions
Strong;
published in
Council
Minutes
Inconsistent Template No CA
terms
Belmont Conspicuous;
current
Strong; not
published
Consistent Flock No CA
terms
Brisbane Not conspicuous;
current
Audit reports
not provided
Consistent Template No CA
terms
Burlingame Not conspicuous;
current
Audit reports
not provided
Consistent Template Contract
not
provided
Colma Not conspicuous;
current
Strong; not
published
Inconsistent Template CA terms
included in
addendum
Daly City Conspicuous,
outdated (NCRIC
references)
Strong, regular
audit; not
published
Inconsistent Outdated No CA
terms
East Palo Alto Conspicuous;
current
Partial; publicly
posted
Consistent Not
described
No CA
terms

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Agency Policy Posting /
Currency
Audit Practices Data
Retention
Data
Sharing
Process
Contract
Terms
Foster City Conspicuous;
current, but broken
link to policy
Audit reports
not provided.

Inconsistent Template No CA
terms
Hillsborough Not conspicuous;
Outdated (NCRIC
references)
Audit reports
not provided.

Consistent Outdated No CA
terms
Menlo Park Not conspicuous;
current
Weak;
published in
City Council
minutes.

Consistent Template No CA
terms
Pacifica Conspicuous;
current
Brief, but
strong; not
published
Consistent Flock Contract
not
provided
Redwood City Conspicuous,
outdated (NCRIC
references)
Strong; not
published
Inconsistent Outdated No CA
terms
San Bruno Conspicuous;
current
Partial; not
published
Consistent Flock No CA
terms
San Mateo Conspicuous;
current
Weak; not
published
Consistent Template No CA
terms
SMC Sheriff's
Office
Conspicuous;
current
Partial;
published in
BOS minutes.

No stated
retention
Template No CA
terms
South San
Francisco
Conspicuous;
current
Partial; not
published.

Consistent Template No CA
terms
Woodside Conspicuous (via
SMC SO) and
current
Strong;
published in
Town Council
minutes
Consistent Template Contract
not
provided.

As shown above, while several agencies demonstrate strong alignment between policy and operational practices, others exhibit deficiencies in audit procedures, inconsistencies in stated data retention practices, and incomplete or inaccurate documentation of data-sharing processes and decisions. These findings highlight the absence of standardized ALPR governance and oversight practices across SMC.

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FINDINGS
This section summarizes findings based on evidence produced or otherwise reviewed by the SMCCGJ. The accompanying table identifies the findings assigned to the governing body of each LEA based on the evidence described in this report.

F1. The ALPR operator’s ALPR policy was not posted in a manner that appears consistent with the California Attorney General’s guidance on “conspicuous” posting.

F2. The ALPR operator’s ALPR Policy appears to be outdated because it describes ALPR operations as mediated by NCRIC, a practice the investigation found was discontinued several years ago.

F3. The ALPR operator shared ALPR information with private university security entities but did not establish that the receiving entity was a “public agency” as defined in Civil Code section 1798.90.55(b), or that the sharing was otherwise permitted by law within the meaning of Civil Code section 1798.90.55(b).

F4. The ALPR operator did not produce records demonstrating that audits required by its ALPR policy had been conducted.

F5. The audit reports produced by the ALPR operator were insufficient to substantiate compliance with applicable California law and the operator’s published ALPR policy.

F6. The ALPR operator’s Flock Safety contract does not include provisions specifically requiring compliance with applicable California ALPR laws.

F7. The operator’s ALPR policy described a process requiring written requests and executed agreements for ALPR data-sharing relationships; however, the records produced did not substantiate that this process was followed or that the required agreements were obtained.

F8. The operator’s ALPR policy did not establish criteria governing the approval of in-state ALPR data-sharing requests or the termination of existing network-sharing relationships.

F9. The retention period specified in the operator’s ALPR Policy does not match the retention period as reported by the Flock transparency portal or Flock contract.

RECOMMENDATIONS
While the recommendations below are generally applicable to all LEAs in SMC, some recommendations have already been implemented by some LEAs. The accompanying table identifies the recommendations directed to the governing body of each LEA reviewed by the SMCCGJ.

R1. The ALPR operator should conspicuously post the current version of their ALPR Policy as required by Civil Code sections 1798.90.51(a)–(b).

R2. The ALPR operator with outdated ALPR policies should revise those policies to accurately reflect current operational practices.

R3. The ALPR operator currently identified as sharing ALPR data with private university security entities should obtain and retain a written legal and factual determination that the recipient is a “public agency” under Civil Code section 1798.90.5(f), or that the sharing is otherwise permitted by law; if no lawful basis exists, the operator should terminate the sharing relationship.

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R4. The ALPR operator should prepare audit reports in accordance with the frequency stated in the operator’s published ALPR policy.

R5. The audit reports produced by the ALPR operator should substantiate compliance with applicable California law and the operator’s published ALPR policy.

R6. Upon contract renewal, the ALPR operator should incorporate contractual language requiring vendor compliance with applicable California law and prohibiting vendors from disclosing ALPR data to unauthorized third parties. Operators should consider provisions similar to those contained in the Town of Colma contract with Flock.

R7. The ALPR operator should update its ALPR policy to accurately reflect the process used to approve ALPR data-sharing relationships.

R8. The ALPR operator should include in their ALPR policies written criteria governing the approval, denial, periodic review, and termination of in-state ALPR network-sharing relationships.

R9. The ALPR operator should update their ALPR policy or Flock contract terms, as necessary, so that the stated retention rule accurately reflects operations.

REQUEST FOR RESPONSES
Pursuant to Penal Code 933.05, the Civil Grand Jury requests responses from the following governing bodies:

Respondent Findings Recommendations
Atherton Town Council F1, F3, F6, F7, F8, F9 R1, R3, R6, R7, R8, R9 Belmont City Council F3, F6, F8 R3, R6, R8
Brisbane City Council F1, F3, F4, F5, F6, F7, F8 R1, R3, R4, R5, R6, R7, R8 Burlingame City Council F1, F3, F4, F5, F6, F7, F8 R1, R3, R4, R5, R6, R7, R8 Colma City Council F1, F3, F5, F7, F8, F9 R1, R3, R5, R7, R8, R9 Daly City City Council F3, F6, F7, F8, F9 R3, R6, R7, R8, R9 East Palo Alto City Council F3, F5, F6, F7, F8 R3, R5, R6, R7, R8 Foster City City Council F3, F4, F5, F6, F7, F8, F9 R3, R4, R5, R6, R7, R8, R9 Half Moon Bay Town Council F3, F5, F6, F7, F8, F9 R3, R5, R6, R7, R8, R9 Hillsborough Town Council F1, F2, F3, F4, F5, F6, F7, F8 R1, R2, R3, R4, R5, R6, R7, R8 Menlo Park City Council F1, F3, F5, F6, F7, F8 R1, R3, R5, R6, R7, R8 Millbrae City Council F3, F5, F6, F7, F8, F9 R3, R5, R6, R7, R8, R9 Pacifica City Council F3, F5, F6, F8 R3, R5, R6, R8
Portola Valley Town Council F3, F5, F6, F7, F8, F9 R3, R5, R6, R7, R8, R9 City Council of Redwood City F2, F3, F5, F6, F7, F8, F9 R2, R3, R5, R6, R7, R8, R9 San Bruno City Council F4, F5, F6, F7, F8 R4, R5, R6, R7, R8 San Carlos City Council F3, F5, F6, F7, F8, F9 R3, R5, R6, R7, R8, R9

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Respondent Findings Recommendations
Ken Binder, San Mateo County
Sheriff
F3, F5, F6, F7, F8, F9 R3, R5, R6, R7, R8, R9
San Mateo City Council F4, F5, F6, F7, F8 R4, R5, R6, R7, R8 South SF City Council F5, F6, F7, F8 R5, R6, R7, R8
Woodside Town Council F5, F6, F7, F8 R5, R6, R7, R8

RESPONSE REQUIREMENTS
California Penal Code Section 933.05 provides as follows (emphasis added):
(a) For purposes of subdivision (b) of Section 933, as to each grand jury finding, the responding person or entity shall report one of the following:
(1) The respondent agrees with the finding.
(2) The respondent disagrees wholly or partially with the finding, in which case the response shall specify the portion of the finding that is disputed and shall include an explanation of the reasons therefor.
(b) For purposes of subdivision (b) of Section 933, as to each grand jury recommendation, the responding person or entity shall report one of the following actions:
(1) The recommendation has been implemented, with a summary regarding the implemented action.
(2) The recommendation has not yet been implemented, but will be implemented in the future, with a timeframe for implementation.
(3) The recommendation requires further analysis, with an explanation and the scope and parameters of an analysis or study, and a timeframe for the matter to be prepared for discussion by the officer or head of the agency or department being investigated or reviewed, including the governing body of the public agency when applicable. This timeframe shall not exceed six months from the date of publication of the grand jury report.
(4) The recommendation will not be implemented because it is not warranted or is not reasonable with an explanation therefor.

Under Penal Code section 933(c), the governing body of a public agency must respond within 90 days after the grand jury submits its final report, and an elected county officer or agency head for which the grand jury has responsibility under Penal Code section 914.1 must respond within 60 days regarding matters under that officer’s or agency head’s control.

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BIBLIOGRAPHY
Automated License Plate Readers, Report 2019-118, California State Auditor, February 2020.

California Automated License Plate Reader Data, 2023-DLE-06, California Department of Justice.

National Crime Information Center Administration of Warrants, 2025-DLE-08, California Department of Justice, April 7, 2025.

A Delicate Balance: Privacy vs. Protection, Report of the San Mateo County Civil Grand Jury, 2016–2017.

FOOTNOTES
1 Analysis done by SMCCGJ on all 2025 network queries in California on one SMC LEA’s data found that 13.1% of queries entered only “Investigation” as the Reason for performing the query. 2 The search reason “warrant” could refer to a warrant issued by a California judge for an authorized law enforcement purpose, or alternatively to an administrative warrant issued by a federal agency such as ICE. 3 A list of these offense codes is provided in Appendix A. 4 The network audit report was delivered in comma-separated value (CSV) format, bulk-loaded into a MySQL database and analyzed using the Structured Query Language (SQL).
5 https://www.paloaltoonline.com/police/2025/11/05/east-palo-alto-leaders-push-back-on-license-plate-readers-amid-privacyconcerns/ 6 https://www.coastsidenews.com/news/half-moon-bay-to-revisit-license-plate-reader-program-and-ice-policies/ 7 https://www.almanacnews.com/news/2025/12/29/the-years-biggest-stories/

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Appendix A - Flock Safety Offense Types

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Superior Court of California, County of San Mateo
Hall of Justice and Records
400 County Center
Redwood City, CA 94063-1655

JENIFFER ALCANTARA

INTERIM COURT EXECUTIVE OFFICER

CLERK & JURY COMMISSIONER
(650) 261-5066
www.sanmateocourt.org
VIA E-MAIL: [email protected]
August 3, 2026
Re: San Mateo County Civil Grand Jury Report – “ Is Our Flock of ALPR Cameras Properly Tended?” Dear Kathy Kleinbaum:

The 2025-2026 Civil Grand Jury has publicly released a report on August 3, 2026 which contains findings and recommendations pertaining to your agency. Your agency must submit comments, within 90 days, to the Honorable Rachel Holt. Your agency’s response is due no later than November 2, 2026. Please note that the response should indicate that it was approved by your governing body at a public meeting.

For all findings, your responding agency shall indicate one of the following:

1. The respondent agrees with the finding.

2. The respondent disagrees wholly or partially with the finding, in which case the response shall specify the portion of the finding that is disputed and shall include an explanation of the reasons, therefor.

Additionally, as to the Civil Grand Jury recommendations, your responding agency must report one of the following actions by responding in one of the specified manners indicated below:

1. The recommendation has been implemented, with a summary regarding the implemented action.

2. The recommendation has not yet been implemented, but will be implemented in the future, with a time frame for implementation.

3. The recommendation requires further analysis, with an explanation and the scope and parameters of an analysis or study, and a time frame for the matter to be prepared for discussion by the officer or director of the agency or department being investigated or reviewed, including the governing body of the public agency when applicable. This time frame shall not exceed six months from the date of publication of the Grand Jury report.

4. The recommendation will not be implemented because it is not warranted or reasonable, with an explanation, therefor.

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2 Please submit your responses in all of the following ways:

1. Responses to be placed on file with the Clerk of the Court by the Court Executive Office. • Prepare original on your agency’s letterhead, indicate the date of the public meeting that your governing body approved the response address and mail to:

Hon. Rachel Holt
Judge of the Superior Court
c/o Jenarda Dubois
Hall of Justice
400 County Center; 8
th Floor
Redwood City, CA 94063-1655.

2. Responses to be placed at the Grand Jury website.
• Copy response and send by e-mail to: [email protected]. (Insert agency name if it is not indicated at the top of your response.)

3. Responses to be placed with the clerk of your agency. • File a copy of the response directly with the clerk of your agency. Do not send this copy to the Court.

For up to 45 days after the end of the term, the foreperson and the foreperson’s designees are available to clarify the recommendations of the report. To reach the foreperson, please email [email protected].

If you wish to receive a hardcopy of this report, kindly email your request to [email protected] and one will be mailed to you accordingly.

If you have any questions regarding these procedures, please do not hesitate to contact David Silberman, County Attorney at [email protected].

Cordially,
Jeniffer Alcantara
Interim Court Executive Officer
Enclosure
cc: Hon. Rachel Holt
Aaron Blum

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CITY COUNCIL

STAFF REPORT
MEETING DATE: October 13, 2026
ITEM TITLE: Authorize Cancellation of the December 28, 2026 City Council Meeting.

RECOMMENDATION:

Staff recommend that the City Council authorize the cancellation of its regular City Council meeting scheduled for December 28, 2026.

FISCAL IMPLICATIONS:

There are no fiscal implications, and no additional funding is needed. The City is billed at a flat monthly rate for broadcasting City Council meetings, so canceling the December 28, 2026 meeting would not yield any cost savings.

BACKGROUND:

Traditionally, the City Council cancels its second meeting in December due to high vacation use and inability to interact with other public agencies. In addition, City facilities, including City Hall, the Adult Community Center, and the Youth Center, will be closed, and most City services and activities will be suspended from December 24, 2026 through January 1, 2027. Emergency services (police, fire, storm, sewer, and road repair) will continue during this furlough period.

ALTERNATIVES:

The alternatives available to the City Council include:

1. Authorize the cancellation of the December 28, 2026 City Council regular meeting; or

2. Do not authorize the cancellation of the December 28, 2026 City Council regular meeting.

Respectfully submitted by:

Crystal Mui, City Clerk
Approved for submission by:
____________________________
Kathy Kleinbaum, City Manager

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CITY COUNCIL

STAFF REPORT
MEETING DATE: October 13, 2026
ITEM TITLE: Adopt Ordinance 1639 Amending San Carlos Municipal Code Title 18, Sections 18.05.020 – Mixed-Use Districts Land Use Regulations,

18.06.020 – Commercial Districts Land Use Regulations, 18.07.020 – Industrial Districts Land Use Regulations, and 18.23 – Standards for Specific Uses and Activities, for a Tobacco Retailer Permit Requirement.

RECOMMENDATION:

Adopt Ordinance 1639 approving amendments to the San Carlos Municipal Code Sections

18.05.020 (Mixed-Use Districts Land Use Regulations), 18.06.020 (Commercial Districts Land Use Regulations), 18.07.020 Industrial Districts Land Use Regulations, and Section 18.23 (Standards for Specific Uses and Activities) to include a new section for Tobacco Retail Sales.

FISCAL IMPLICATIONS:

There are no fiscal implications, and no additional funding is needed.

BACKGROUND:

San Carlos Municipal Code Section 8.07.110 currently requires that no tobacco retailer or other person shall sell or offer for sale any tobacco product without a current and valid tobacco retailer permit from San Mateo County for each location where such activities are conducted.

The proposed updates involve adding this requirement to the Zoning Title, specifically to the land use tables for Mixed-Use Districts, Commercial Districts, and Industrial Districts, and establishing the requirement to obtain a permit within a new Section 18.23.320 governing Standards for Specific Uses and Activities.

On August 17, 2026, the Planning and Transportation Commission approved Resolution PTC2026-10 (Attachment 2) recommending that the City Council consider introducing this ordinance. Subsequently on September 28, 2026 the City Council voted to introduce this ordinance, with the additional requirement that references to Section 18.23.320 apply to all retail land use categories.

ANALYSIS:

While Chapter 8.07.110 currently regulates the permitting process for tobacco retailers, the Zoning Ordinance does not explicitly reference these requirements within its land use regulations, and adding a reference would improve clarity for tobacco retail businesses. These proposed changes are outlined in Exhibit A to Attachment 1.

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Impact of Proposed Amendments
The amendments serve to align the Zoning Code with existing language in the San Carlos Municipal Code. These changes ensure that any new or existing tobacco retail business is clearly informed of the necessity of the San Mateo County Tobacco Retailer Permit as defined in SCMC

8.07.110. They also provide clarity for staff and business owners regarding the prerequisites for operating a tobacco retail establishment within the City.

ENVIRONMENTAL DETERMINATION:

This project has been determined to be exempt from the provisions of the California Environmental Quality Act (CEQA) Guidelines Section 15061(b)(3), the general exemption for projects with no potential for a significant effect in the environment. As a text amendment, it can be seen with certainty that there is no possibility that the amendments will have a significant effect on the environment.

ALTERNATIVES:

The alternatives available to the City Council include:

1. Adopt Ordinance 1639 Amending Title 18 of the San Carlos Municipal Code; or

2. Do not adopt Ordinance 1639; or

3. Provide staff with alternative direction.

Respectfully submitted by:

Andrea Mardesich, Assistant Community Development Director; and Al Savay, Community Development Director
Approved for submission by:
____________________________
Kathy Kleinbaum, City Manager
ATTACHMENT(S):

1. Ordinance 1639 with Exhibit A - Proposed Municipal Code Changes (with redlines)

2. PTC Resolution PTC2026-10

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ORDINANCE NO. 1639

AN ORDINANCE OF THE CITY OF SAN CARLOS AMENDING SAN CARLOS MUNICIPAL CODE TITLE 18, SECTIONS 18.05.020 - MIXED-USE DISTRICTS LAND USE REGULATIONS, 18.06.020 - COMMERCIAL DISTRICTS LAND USE REGULATIONS, 18.07.020 - INDUSTRIAL DISTRICTS LAND USE REGULATIONS, AND 18.23 - STANDARDS FOR SPECIFIC USES AND ACTIVITIES, FOR A TOBACCO RETAILER PERMIT REQUIREMENT.

SECTION 1: The City Council of the City of San Carlos does hereby ordain as follows:

WHEREAS, San Carlos Municipal Code Section 8.07.110 requires that no tobacco retailer or other person shall sell or offer for sale any tobacco product without a current and valid tobacco retailer permit from San Mateo County for each location where such activities are conducted; and WHEREAS, it is recommended to update the Zoning Code (Title 18) to reflect this existing requirement and ensure consistency across the Municipal Code; and WHEREAS, the proposed amendments would add a cross-reference to the County permit requirements of Section 8.07.110 in the land use tables of Sections 18.05.020 (Mixed-Use Districts Land Use Regulations), 18.06.020 (Commercial Districts Land Use Regulations), 18.07.020 Industrial Districts Land Use Regulations, and add a new section for Tobacco Retail Sales in Chapter

18.23 (Standards for Specific Uses and Activities); and WHEREAS, pursuant to San Carlos Municipal Code Chapter 18.35.050 and California Government Code Section 65090 and 65091, a Public Hearing Notice for the Planning and Transportation Commission was Published on August 6, 2026 for the draft San Carlos Municipal Code Zoning Amendments in the newspaper, and distributed to interested parties; and these changes and render a recommendation to the City Council; and WHEREAS, the Planning and Transportation Commission conducted a public hearing to hear and consider all comments of all persons interested in or concerned with the proposed amendments of the City of San Carlos Municipal Code on August 17, 2026 in consideration of a recommendation to the City Council regarding adoption of an Ordinance; and WHEREAS, the proposed amendments to the San Carlos Municipal Code as mentioned above are exempt from the provisions of the California Environmental Quality Act (CEQA) Guidelines Section 15061(b)(3), the general exemption for projects with no potential for a significant effect on the environment. As a text amendment, it can be seen with certainty that there is no possibility that the amendments will have a significant effect on the environment.

WHEREAS, pursuant to San Carlos Municipal Code Chapter 18.35.050 and California Government Code Section 65090 and 65091, a Public Hearing Notice for the City Council hearing was Published on September 17, 2026 for the draft San Carlos Municipal Code Zoning Amendments in the newspaper, and distributed to interested parties; and WHEREAS, the City Council has received a recommendation from the Planning and Transportation Commission Resolution PTC2026 – 10 as a result of a Public Hearing held at the Planning and Transportation Commission Meeting August 17, 2026 and has considered the recommendation of the Planning and Transportation Commission for regulations in the San Carlos Municipal Code including Planning and Transportation Commission findings for amendments to the Title 18 and the reasons for the recommendations, the relationship of the proposed ordinance or amendments to the Zoning Ordinance (Title 18), and 2030 General Plan.

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WHEREAS, the City Council finds the Ordinance update process evaluated the existing ordinance and explored options for changes based on evidence and best practices in other communities and industry experts; and
SECTION 2: The City Council makes the following findings:

A. The proposed ordinance amendments are consistent with the General Plan.

The General Plan includes the following goal:
• Goal LU-5: Support and maintain land uses that contribute to a vibrant and resilient local economy and support the fiscal well-being of the City.

Basis for Finding: This ordinance amendment contributes to the goal of supporting and maintaining land uses that contribute to the local economy by ensuring that tobacco retail businesses are operating in accordance with the guidelines of the County and the City.

B. The ordinance amendment is consistent with the purpose of the zoning title to promote the growth of the City in an orderly manner and to promote and protect the public health, safety, peace, comfort and general welfare.

Basis for Finding: The proposed ordinance amendments promote orderly operations of businesses and protect public health by making clear the requirements necessary to operate a tobacco retail business within relevant sections of the Zoning Code, ensuring that tobacco retailers adhere to the health and safety standards established by the County and the City.

SECTION 3: Replacement and Amendment of Code. San Carlos Municipal Code Sections

18.05.020 (Mixed-Use Districts Land Use Regulations), 18.06.020 (Commercial Districts Land Use Regulations), 18.07.020 Industrial Districts Land Use Regulations is hereby replaced and Section

18.23.230 (Standards for Specific Uses and Activities) is hereby added with the language as provided in Exhibit A.

SECTION 4: California Environmental Quality Act Determination. The City Council hereby finds that this Ordinance is exempt from the provisions of the California Environmental Quality Act (CEQA) Guidelines Section 15061(b)(3), the general exemption for projects with no potential for a significant effect in the environment. As a text amendment, it can be seen with certainty that there is no possibility that the amendments will have a significant effect on the environment.

SECTION 5: Severability. That the City Council hereby declares that it would have passed this Ordinance sentence by sentence, paragraph by paragraph, and section by section, and does hereby declare that any provisions of this Ordinance are severable and, if for any reason any sentence, paragraph or section of this Ordinance shall be held invalid, such decision shall not affect the validity of the remaining parts of this Ordinance.

SECTION 6: Publication and Effective Date. This Ordinance shall be published and posted according to law and shall take effect and be in force from and after 30 days after its passage and adoption.
* * * *
I, City Clerk Crystal Mui, hereby certify that the foregoing Ordinance was introduced on the 28th day of September, 2026 and passed and adopted as an Ordinance of the City of San Carlos at a regular meeting thereof held on the 13th day of October, 2026 by the following vote:

AYES, COUNCILMEMBERS:

NOES, COUNCILMEMBERS:

ABSENT, COUNCILMEMBERS:

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________________________________
CITY CLERK of the City of San Carlos
APPROVED:
____________________________
MAYOR of the City of San Carlos
Exhibit A – Proposed Changes (with redlines)

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EXHIBIT A – Proposed Changes

18.05.020 Land Use Regulations.

Table 18.05.020 prescribes the land use regulations for mixed-use districts. Parcels located within an adopted Specific Plan area shall comply with the land use regulations as specified within the Specific Plan. The regulations for each district are established by letter designations as follows:
“P” designates permitted uses.
“M” designates use classifications that are permitted after review and approval of a minor use permit by the Zoning Administrator.
“C” designates use classifications that are permitted after review and approval of a conditional use permit by the Planning and Transportation Commission.
“(#)” numbers in parentheses refer to specific limitations listed at the end of the table. “-” designates uses that are not permitted.

Use classifications are defined in Chapter 18.40, Use Classifications. In cases where a specific land use or activity is not defined, the Director shall assign the land use or activity to a classification that is substantially similar in character. Use classifications and subclassifications not listed in the table or not found to be substantially similar to the uses below are prohibited. The table also notes additional use regulations that apply to various uses. Section numbers in the right-hand column refer to other sections of this title.

TABLE 18.05.020: LAND USE REGULATIONS—MIXED-USE DISTRICTS Use
Classification
s
MUDC100
MU-D100MU-D120
MUSC120MUNB120
MUSB-100MUSB-120MU-N40MU-N50MU-N120Additional
Regulations
Residential Uses
Residential
Housing
Types
See subclassifications below
Multi-Unit
Residential
P(1
)
P(1) P(2) P P(2) P P(2) P(3) P(2) P(2)
Accessory
Dwelling Unit
P P P P P P P P P P Only if it includes a
proposed or existing
dwelling
Junior
Accessory
Dwelling Unit
- - - - - - - - - -
Elderly and
Long-Term
Care
- - - C - - - - - -
Family Child
Care
See subclassifications below
Small P P P P P P P P P P

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Large P P P P P P P P P P See
Section 18.23.090,
Day care centers
and large family
child care homes
Residential
Care
Facilities
See subclassifications below
General - M(1) M(1) M - - - - - - See
Section 18.23.200,
Residential care
facilities
Limited P P P P P P P P P P
Senior - M(1) M(1) M - - - - - - See
Section 18.23.200,
Residential care
facilities
Single Room
Occupancy
C(1
)
C(1) C(1) C C(1) C(1) C(1) C(3,1
4)
C C See
Section 18.23.220,
Single room
occupancy hotels
Transitional
Housing
P P P P P P P P P P See
Section 18.23.250,
Transitional and
supportive housing
Supportive
Housing
P P P P P P P P P P See
Section 18.23.250,
Transitional and
supportive housing
Public and Semi-Public Uses
Colleges and
Trade
Schools,
Public or
Private
- - - - P P P - - -
Community
Assembly,
Less Than
3,500 Square
Feet
- P P P P P P M M M
Community
Assembly,
3,500 Square
Feet or More
- C C C M M M - - -
See
Section 18.23.080,
Community
assembly facilities
Community
Garden

P P P P P P P P P P
Cultural
Institutions
C(4
)

P P C M M M M M M
Day Care
Centers
- P P P P P P P P P See
Section 18.23.090,
Day care

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Emergency
Shelter
- - - - P P P - - - See
Section 18.23.110,
Emergency shelters
Government
Offices
- P P P P P P P P P
Hospitals and
Clinics
- P P - P P P - - -
Instructional
Services
M P P - P P P P P P See
Section 18.23.260,
Formula business
uses
Park and
Recreation
Facilities,
Public

P P P P P P P P P P
Public Safety
Facilities
- C C - C C C C C C
Schools,
Public or
Private
- - - - C C C C C C
Social
Service
Facilities
- - - - C C C C C C
Commercial Uses
Animal Care,
Sales and
Services
See subclassifications below
Grooming
and Pet
Stores
- P P - P P P P(5) P(5) P(5)
Veterinary
Services
- C(5) C(5) C(5) C(5) C(5) C(5) C(5) C(5) C(5)
Artists’
Studios
M P P - P P P P(5) P(5) P(5)
Automobile/
Vehicle Sales
and Services
See subclassifications below
Automobile
Rentals
- - - - C(6) C(6) C(6) - - -
Automobile/
Vehicle Sales
and Leasing
P(6
,7)
P(6,
7)
P(6,
7)
P(6,7
)
P(6,7) P(6,7) P(6,
7)
- - -
Automobile/
Vehicle
Washing
- - - - C(6) C(6) C(6) - - -
Service
Station
- - - - C(6) C(6) C(6) - - -
See
Section 18.23.050,
Automobile/vehicle
sales and services,
and
Section 18.23.260,
Formula business
uses

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Banks and
Financial
Institutions
P(8
)
P P M P P P M(9) M(9) M(9) See
Section 18.23.260,
Formula business
uses
Business
Services
- P(9) P(9) P(9) P(9) P(9) P(9) P(9) P(9) P(9)
Commercial
Entertainmen
t and
Recreation
See subclassifications below
Cinema/Thea
ters
C(1
7)
C(17
)
C(17
)
- C(17) C(17) C(17) - - - See
Section 18.23.260,
Formula business
uses
Small-Scale - C(17
)
C(17
)
- C(17) C(17) C(17) - - -
Large-Scale - C(17
)
C(17
)
- C(19) - - - - -
Eating and
Drinking
Establishmen
ts
See subclassifications below
Bars/Night
Clubs/Loung
es
C(1
7)
C(17
)
C(17
)
- C(17) C(17) C(17) - - -
Full Service P(1
7)
P(17
)
P(17
)
P P(17) P(17) P(17) C(10,
17)
C(10,
17)
C(10,
17)
See
Section 18.23.140,
Outdoor dining, and
Section 18.23.260,
Formula business
uses
Convenience P(1
8)
P(18
)
P(18
)
P P(18) P(18) P(18) C(10
)
C(10
)
C(10) See
Section 18.23.260,
Formula business
uses
Food
Preparation
P P P P P P P P P P See
Section 18.23.260,
Formula business
uses
Funeral
Parlors and
Mortuaries
- C C C C C C - - -
Lodging See subclassifications below
Bed and
Breakfast
P P P P P P P P P P See
Section 18.23.070,
Bed and breakfast
lodging, and
Section 18.23.260,
Formula business
uses

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Hotels and
Motels
P(1
1,
17)
P(17
)
P(17
)
M P(17) P(17) P(17) M(14
, 17)
M(17
)
M(17) See
Section 18.23.260,
Formula business
uses
Nurseries
and Garden
Centers
P(9
,
20)
P(9,
20)
P(9,
20)
- P(9,
20)
P(9,
20)
P(9,
20)
P(9,
20)
P(9,
20)
P(9,
20)
See
Section 18.23.260,
Formula business
uses
Offices See subclassifications below
Business and
Professional
P(1
2)
P P P P P P P P P See
Section 18.23.260,
Formula business
uses
Medical and
Dental
P(1
2)
P P P P P P P(9) P(9) P(9) See
Section 18.23.260,
Formula business
uses
Walk-In
Clientele
P P P P P P P P P P See
Section 18.23.260,
Formula business
uses
Personal
Services
See subclassifications below
General
Personal
Services
(13
)

P P P P P P P P P
Tattoo or
Body
Modification
Parlor
- - - - M M M - - -
See
Section 18.23.170,
Personal services,
and
Section 18.23.260,
Formula business
uses
Retail Sales See subclassifications below
Cannabis
Dispensary
- - - - - - - - - -
Convenience
Markets
P(1
8)
P(18
)
P(18
)
P P(18) P P P(15) P P See
Section 18.23.260,
Formula business
uses, and Section

18.23.320, Retail
Establishments
selling Tobacco
Products
Food and
Beverage
Sales
P(1
8)
P(18
)
P(18
)
P P(18) P P P(16) P(16) P(16) See
Section 18.23.260,
Formula business
uses and Section

18.23.320, Retail
Establishments
selling Tobacco
Products

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General
Retail
P P P P P P P P P P See
Section 18.23.260,
Formula business
uses, and Section

18.23.320, Retail
Establishments
selling Tobacco
Products
Price Point
Retail
- - - - M M M - - - See Section

18.23.320, Retail
Establishments
selling Tobacco
Products
Second-Hand
Store
- - - - P P P P P P See Section

18.23.320, Retail
Establishments
selling Tobacco
Products
Retail
Establishmen
ts Selling
Ammunition
or Firearms
- - - - - - - - - -
Industrial Uses
Recycling
Facility,
Reverse
Vending
Machine
- - - P P P P P - - See
Section 18.23.190,
Recycling facilities
Transportation, Communication, and Utilities Uses
Communicati
on Facilities
See subclassifications below
Antenna and
Transmission
Towers
See Chapter 18.24, Wireless Telecommunications Facilities Facilities
within
Buildings
- P P P P P P P P P
Transportatio
n Passenger
Terminals
- - - - - - - - - -
Utilities,
Minor

P P P P P P P P P P
Other Applicable Types
Accessory
Uses and
Structures
See Section 18.23.030, Accessory uses, and Section 18.15.020, Accessory buildings and structures

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Home
Occupations
P P P P P P P P P P See
Section 18.23.120,
Home occupations
Drive-In and
DriveThrough
Facilities
Prohibited in MU districts; see Section 18.23.100, Drive-in and drive-through facilities Nonconformi
ng Use
Chapter 18.19, Nonconforming Uses, Structures, and Lots Temporary
Use
Chapter 18.31, Temporary Use Permits
Specific Limitations:

1. Not allowed on the ground floor along Laurel Street and San Carlos Avenue frontages. Parcels located within an adopted Specific Plan area shall comply with the requirements of the Specific Plan.

2. Residential-only development is subject to active ground floor use requirement, pursuant to Section 18.05.030(H). Parcels located within an adopted Specific Plan area shall comply with the requirements of the Specific Plan.

3. Not allowed on the ground floor along Old County Road.

4. Not allowed on Laurel Street or San Carlos Avenue. Parcels located within an adopted Specific Plan area shall comply with the requirements of the Specific Plan.

5. Provided that such use shall be completely enclosed in a building of soundproof construction.

6. For properties without frontage along El Camino Real, only retail sales consistent with the definition of “general retail” and five thousand (5,000) square feet or less.

7. Must be within an enclosed structure.

8. Limited to establishments with a gross floor area of two thousand five hundred (2,500) square feet or less. Limited to the ground floor of a building located on an interior lot a minimum of five hundred (500) feet from any other financial institution.

9. Limited to establishments with a gross floor area of five thousand (5,000) square feet or less.

10. Permitted after review and approval of a minor use permit by the Zoning Administrator if less than twelve (12) chairs.

11. Limited to upper stories unless at least fifty percent (50%) of ground floor street frontage is occupied by food service use.

12. Limited to upper stories.

13. Permitted if existing. Additions to existing facilities and establishment of new facilities are subject to Section 18.23.170, Personal services.

14. Not allowed along East San Carlos Avenue.

15. Limited to neighborhood groceries with less than one thousand five hundred (1,500) square feet of sales area when located along East San Carlos Avenue.

16. The sale of alcoholic beverages is prohibited.

17. Not permitted on sites where the shopfront of such nonresidential use faces onto R zoning districts.

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18 Minor use permit required for sites adjacent to R districts.

19. On the east side of El Camino Real only; in all other areas this use is not permitted.

20. Uses that require a commercial cannabis business permit are not permitted.

18.06.020 Land Use Regulations.

Table 18.06.020 prescribes the land use regulations for commercial districts. The regulations for each district are established by letter designations as follows:
“P” designates permitted uses.
“M” designates use classifications that are permitted after review and approval of a minor use permit by the Zoning Administrator.
“C” designates use classifications that are permitted after review and approval of a conditional use permit by the Planning and Transportation Commission.
“(#)” numbers in parentheses refer to specific limitations listed at the end of the table. “-” designates uses that are not permitted.

TABLE 18.06.020: LAND USE REGULATIONS—COMMERCIAL DISTRICTS Use Classification NR GCI LC Additional Regulations
Public and Semi-Public Uses
Colleges and Trade Schools, Public or
Private
- C(3) -
Government Offices - C(3) -
Instructional Services P M(3) -
Public Safety Facilities - M(3) -
Commercial Uses
Automobile/Vehicle Sales and Services See subclassifications below Automobile/Vehicle Sales and Leasing - P C
Automobile/Vehicle Washing - C -
Service Station (1) P -
See Section 18.23.050,
Automobile/vehicle sales and services
Banks and Financial Institutions - P C
Business Services P P P(4)
Commercial Entertainment and
Recreation
See subclassifications below
Cinema/Theaters - P C

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Large-Scale - C C
Small-Scale - P P(4)
Eating and Drinking Establishments See subclassifications below Full Service M P P(4)
Convenience P P C
See Section 18.23.140, Outdoor dining
Food Preparation P P P(4)
Lodging See subclassifications below
Hotels and Motels C C M
Maintenance and Repair Services - P P(4)
Nurseries and Garden Centers - P M(6) See Section 18.23.270, Commercial cannabis businesses
Offices See subclassifications below
Business and Professional P P P(4)
Medical and Dental - P M
Walk-In Clientele P P P(4)
Personal Services See subclassifications below
General Personal Services P P P(4) See Section 18.23.170, Personal services
Retail Sales See subclassifications below
Building Materials and Services - P M See Section 18.23.320, Retail Establishments selling Tobacco
Products
Cannabis Dispensary - - -
Convenience Markets P P M See Section 18.23.320, Retail Establishments selling Tobacco
Products
Food and Beverage Sales P P M See Section 18.23.320, Retail Establishments selling Tobacco
Products
General Retail P P P(4) See Section 18.23.320, Retail
Establishments selling Tobacco
Products
Large-Format Retail - C C See Section 18.23.130, Large-format retail and Section 18.23.320, Retail
Establishments selling Tobacco
Products
Price Point Retail - P M See Section 18.23.320, Retail
Establishments selling Tobacco
Products
Second-Hand Store - P M See Section 18.23.320, Retail
Establishments selling Tobacco
Products

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Retail Establishments Selling
Ammunition or Firearms
C C C See Section 18.23.290, Retail
establishments selling ammunition or
firearms and Section 18.23.320, Retail
Establishments selling Tobacco
Products
Industrial Uses
Construction and Material Yards - C C See Section 18.23.160, Outdoor storage
Custom Manufacturing - P M
Industry, General - M M(6) See Section 18.23.270, Commercial cannabis businesses
Industry, Limited - P M
Recycling Facility See subclassifications below
Reverse Vending Machine - C(3) -
Recycling Collection Facility - C(3) -
See Section 18.23.190, Recycling
facilities
Research and Development - P M(6) See Section 18.23.270, Commercial cannabis businesses
Research and Development Activities
Requiring BSL-1 and BSL-2 Containment
P P P
Research and Development Activities
Requiring BSL-3 Containment
- - -
Research and Development Activities
Requiring BSL-4 Containment
- - -
Salvage and Wrecking - C(2) - See Section 18.23.160, Outdoor storage
Warehousing and Storage See subclassifications below
Indoor Warehousing and Storage - C(5) P(4)(5)
Outdoor Storage - C - See Section 18.23.160, Outdoor
storage
Wholesaling and Distribution - P M(6) See Section 18.23.270, Commercial cannabis businesses
Cannabis Microbusiness - P - See Section 18.23.270, Commercial cannabis businesses
Transportation, Communication, and Utilities Uses
Communication Facilities See subclassifications below
Antenna and Transmission Towers See Chapter 18.24, Wireless Telecommunications Facilities Facilities Within Buildings P P M
Freight/Truck Terminals and
Warehouses
- P(3) -
Light Fleet-Based Services - P(3) C
Utilities, Major - C(3) -

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Utilities, Minor P P(3) -
Other Applicable Types
Accessory Uses and Structures See Sections 18.23.030, Accessory uses, and 18.15.020, Accessory buildings and structures
Nonconforming Use Chapter 18.19, Nonconforming Uses, Structures, and Lots Temporary Use Chapter 18.31, Temporary Use Permits
Specific Limitations:

1. Permitted if existing. New service stations are not allowed.

2. Shall be conducted entirely within an enclosed building.

3. Not allowed between Industrial Road and Highway 101 and Skyway Road fronting Highway 101.

4. Permitted by right in existing buildings only; additions or enlargements, tear downs and rebuilds may be considered subject to conditional use permit approval by the Planning and Transportation Commission.

5. Storage in small individual spaces exclusively and directly accessible to a specific tenant is permitted by right on the condition that such uses occupy no more than five percent (5%) of the total square footage of any single building.

6. Uses that require a commercial cannabis business permit are not permitted.

18.07.020 Land Use Regulations.

Table 18.07.020 prescribes the land use regulations for industrial districts. The regulations for each district are established by letter designations as follows:
“P” designates permitted uses.
“M” designates use classifications that are permitted after review and approval of a minor use permit by the Zoning Administrator.
“C” designates use classifications that are permitted after review and approval of a conditional use permit by the Planning and Transportation Commission.
“(#)” numbers in parentheses refer to specific limitations listed at the end of the table. “-” designates uses that are not permitted.

TABLE 18.07.020: LAND USE REGULATIONS—INDUSTRIAL DISTRICTS Use Classification IA IL IH IP Additional Regulations
Public and Semi-Public Uses
Colleges and Trade Schools, Public or
Private
C C C(8) -
Government Offices - C C C

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Hospitals and Clinics See subclassification below
Hospitals - - - C
Public Safety Facilities - M M -
Commercial Uses
Adult-Oriented Business C(1) C(1) C(1) - See Section 18.23.040, Adultoriented businesses Animal Care, Sales and Services See subclassifications below Kennels - M - -
Veterinary Services - M - -
Artist’s Studio P P - -
Automobile/Vehicle Sales and
Services
See subclassifications below
Automobile/Vehicle Sales and Leasing - C(3) C(5) C(5)
Automobile/Vehicle Repair, Major P P P C
Automobile/Vehicle Service and
Repair, Minor

P P P -
Automobile/Vehicle Washing - P - -
Large Vehicle and Equipment Sales,
Service and Rental
- P P -
Service Station - P(6) - -
See Section 18.23.050,
Automobile/vehicle sales and
services
Towing and Impound - M M -
Vehicle Storage - M M -
See Section 18.23.160, Outdoor
storage
Business Services P P P P
Commercial Entertainment and
Recreation
See subclassifications below
Large-Scale - C C -
Small-Scale - C C -
Eating and Drinking Establishments See subclassifications below Full Service - - - M(2)
Convenience M(2) M(2) M(2) M(2)
See Section 18.23.140, Outdoor
dining
Food Preparation P P - -
Funeral Parlors and Interment
Services

P - - -
Maintenance and Repair Services P P P -
Nurseries and Garden Centers - M M - See Section 18.23.270, Commercial cannabis businesses
Offices See subclassifications below

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Business and Professional - C C M
Medical and Dental - C - M
Parking, Public or Private - P P - See Chapter 18.20, Parking and Loading
Personal Services See subclassification below
Tattoo or Body Modification Parlor M - - -
Retail Sales See subclassifications below
Building Materials and Services M M M - See Section 18.23.320, Retail Establishments selling Tobacco
Products
Cannabis Dispensary - - - -
Convenience Markets M(2) M(2) M(2) M(2) See Section 18.23.320, Retail Establishments selling Tobacco
Products
Food and Beverage Sales M(2) M(2) M(2) M(2) See Section 18.23.320, Retail Establishments selling Tobacco
Products
General Retail M(4) M(4) M(4) M(4) See Section 18.23.320, Retail Establishments selling Tobacco
Products
Retail Establishments Selling
Ammunition or Firearms
C C C C See Section 18.23.290, Retail
establishments selling ammunition or
firearms and see Section

18.23.320, Retail Establishments
selling Tobacco Products
Industrial Uses
Construction and Material Yards P P P - See Section 18.23.160, Outdoor storage
Custom Manufacturing P P P -
Industry, General P P P - See Section 18.23.270, Commercial cannabis businesses
Industry, Limited P P P P
Recycling Facility See subclassifications below
Reverse Vending Machine P P - -
Recycling Collection Facility - C C -
Recycling Processing Facility - C C -
See Section 18.23.190, Recycling
facilities
Research and Development P P P P See Section 18.23.270, Commercial cannabis businesses
Research and Development Activities
Requiring BSL-1 and BSL-2
Containment

P P P P
Research and Development Activities
Requiring BSL-3 Containment
- - - -

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Research and Development Activities
Requiring BSL-4 Containment
- - - -
Salvage and Wrecking M(3) M M - See Section 18.23.160, Outdoor storage
Warehousing and Storage See subclassifications below
Chemical, Mineral, and Explosives
Storage
- C(7) C(7) -
Indoor Warehousing and Storage P P P -
Outdoor Storage P(9) P P - See Section 18.23.160, Outdoor storage
Wholesaling and Distribution P P P - See Section 18.23.270, Commercial cannabis businesses
Cannabis Microbusiness P P P - See Section 18.23.270, Commercial cannabis businesses
Transportation, Communication, and Utilities Uses
Communication Facilities See subclassifications below
Antenna and Transmission Towers See Chapter 18.24, Wireless Telecommunications Facilities Facilities Within Buildings M M M M
Freight/Truck Terminals and
Warehouses
- C P(10) -
Light Fleet-Based Services P P P -
Utilities, Major C C C C
Utilities, Minor P P P P
Waste Transfer Facility - P P -
Other Applicable Types
Accessory Uses and Structures See Sections 18.23.030, Accessory uses, and 18.15.020, Accessory buildings and structures
Nonconforming Use Chapter 18.19, Nonconforming Uses, Structures, and Lots Temporary Use Chapter 18.31, Temporary Use Permits
Specific Limitations:

1. Permitted only in the area shown on Figure 18.23.040-B: Adult-Oriented Business Area.

2. Permitted only as an ancillary use. The combined floor area of all eating and drinking uses on a site shall not exceed two thousand five hundred (2,500) square feet unless a conditional use permit is approved.

3. Shall be conducted entirely within an enclosed building.

4. Permitted only as an ancillary use, not to occupy more than one thousand (1,000) square feet, unless a conditional use permit is approved.

5. Limited to properties between Industrial Road and Highway 101 and adjacent to Shoreway Road.

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6. Limited to alternative fueling stations such as for electric or hybrid vehicles, hydrogen-powered vehicles, and similar vehicles using alternative fuels.

7. Prohibited within five hundred (500) feet of a residential district.

8. Except between Industrial and Highway 101 and Shoreway and Highway 101.

9. Permitted as an accessory use only.

10. Conditional use permit required if adjacent to an R district.

Chapter 18.23

STANDARDS FOR SPECIFIC USES AND ACTIVITIES

18.23.320 Retail Establishments selling Tobacco Products A. No tobacco retailer or other person shall sell or offer for sale any tobacco product without a current and valid tobacco retailer permit from San Mateo County for each location where such activities are conducted.

B. Tobacco retailers are subject to all applicable Municipal Code requirements in addition to all applicable county, state and federal laws.

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October 13, 2026 Packet Pg. 90
RESOLUTION NO. PTC2026 - 10

A RESOLUTION OF THE PLANNING AND TRANSPORTATION COMMISSION OF THE CITY OF

SAN CARLOS RECOMMENDING CITY COUNCIL ADOPT AN ORDINANCE APPROVING AMENDMENTS TO SAN CARLOS MUNICIPAL CODE SECTIONS 18.05.020 (MIXED-USE DISTRICTS LAND USE REGULATIONS), 18.06.020 (COMMERCIAL DISTRICTS LAND USE REGULATIONS), 18.07.020 INDUSTRIAL DISTRICTS LAND USE REGULATIONS AND SECTION 18.23 (STANDARDS FOR SPECIFIC USES AND ACTIVITIES) OF THE SAN CARLOS MUNICIPAL CODE.

WHEREAS, the proposed amendments would add a cross-reference to the County permit requirements of Section 8.07.110 in the land use tables of Sections 18.05.020 (Mixed-Use Districts Land Use Regulations), 18.06.020 (Commercial Districts Land Use Regulations), 18.07.020 Industrial Districts Land Use Regulations and add a new section for Tobacco Retail Sales in Chapter 18.23 (Standards for Specific Uses and Activities).

WHEREAS, a Public Hearing Notice was published on August 6, 2026 for the draft Zoning Amendments in the newspaper and distributed to interested parties; and WHEREAS, pursuant to Government Code Sections 65853 and 65850 and San Carlos Municipal Code Chapter 18.35, the Planning and Transportation Commission held a public hearing on August 17th, 2026 to consider these changes and render a recommendation to the City Council; and
WHEREAS, the proposed amendments are exempt from the California Environmental Quality Act (CEQA) Guidelines Section 15061(b)(3), as a text amendment that can be seen with certainty to have no potential for a significant effect on the environment.

NOW, THEREFORE BE IT FOUND, DETERMINED, AND RESOLVED by the Planning and Transportation Commission of the City of San Carlos that:

Pursuant to SCMC Section 18.35.080 Criteria for Zoning Amendments, the Planning and Transportation Commission shall not recommend, and the City Council shall not approve a zoning amendment unless the proposed amendment meets the following criteria:
1) Findings:

A. The proposed ordinance amendments are consistent with the General Plan.

The General Plan includes the following goal:
* Goal LU-5: Support and maintain land uses that contribute to a vibrant and resilient local economy and support the fiscal well-being of the City.

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B. The ordinance amendment is consistent with the purpose of the zoning title to promote the growth of the City in an orderly manner and to promote and protect the public health, safety, peace, comfort and general welfare.

A. The Planning and Transportation Commission recommends that the City Council introduce an Ordinance approving amendments as set forth in Exhibit A as amended.

Passed and adopted as Resolution of the Planning and Transportation Commission of the City of San Carlos at a regular meeting thereof on the 17th day of August 2026, by the following vote:

AYES, PLANNING AND TRANSPORTATION COMMISSIONERS:

Kenniasty/ Tapias/ Anand/ Bundy
NOES, PLANNING AND TRANSPORTATION COMMISSIONERS:

None

ABSENT,

PLANNING AND TRANSPORTATION COMMISSIONERS:

Clements
- Gan of the Planning and | )
Transportation Commission of
the City of San Carlos
ATTEST:
naval lad —
Assistant Community Development Director, City of San Carlos

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October 13, 2026 Packet Pg. 92
DRAFT ORDINANCE NO.

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF SAN CARLOS AMENDING TITLE 18, SECTIONS 18.05.020 (MIXED-USE DISTRICTS LAND USE REGULATIONS), 18.06.020 (COMMERCIAL DISTRICTS LAND USE REGULATIONS), 18.07.020 INDUSTRIAL DISTRICTS LAND USE REGULATIONS AND SECTION 18.23 (STANDARDS FOR SPECIFIC USES AND ACTIVITIES) OF THE SAN CARLOS MUNICIPAL CODE.

SECTION 1: The City Council of the City of San Carlos does hereby ordain as follows:

WHEREAS, it is recommended to update the Zoning Code (Title 18) to reflect this existing requirement and ensure consistency across the Municipal Code; and WHEREAS, the proposed amendments would add a cross-reference to the County permit requirements of Section 8.07.110 in the land use tables of Sections 18.05.020 (Mixed-Use Districts Land Use Regulations), 18.06.020 (Commercial Districts Land Use Regulations), 18.07.020 Industrial Districts Land Use Regulations and add a new section for Tobacco Retail Sales in Chapter 18.23 (Standards for Specific Uses and Activities).

WHEREAS, pursuant to San Carlos Municipal Code Chapter 18.35.050 and California Government Code Section 65090 and 650901, a Public Hearing Notice for the Planning and Transportation Commission was Published on August 6, 2026 for the draft San Carlos Municipal Code Zoning Amendments in the newspaper, and distributed to interested parties; and
these changes and render a recommendation to the City Council; and WHEREAS, the Planning and Transportation Commission conducted a public hearing to hear and consider all comments of all persons interested in or concerned with the proposed amendments of the City of San Carlos Municipal Code on August 17, 2026 in consideration of a recommendation to the City Council regarding adoption of an Ordinance; and
WHEREAS, the proposed amendments to the San Carlos Municipal Code as mentioned above are exempt from the provisions of the California Environmental Quality Act (CEQA) Guidelines Section 15061(b)(3), the general exemption for projects with no potential for a significant effect on the environment. As a text amendment, it can be seen with certainty that there is no possibility that the amendments will have a significant effect on the environment.

WHEREAS, pursuant to San Carlos Municipal Code Chapter 18.35.050 and California Government Code Section 65090 and 650901, a Public Hearing Notice for the City Council hearing was Published on for the draft San Carlos Municipal Code Zoning Amendments in the newspaper, and distributed to interested parties; and WHEREAS, City Council has received a recommendation from the Planning and Transportation Commission PTC2026 - as a result of a Public Hearing held at

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the Planning and Transportation Commission Meeting August 17, 2026 and has considered the recommendation of the Planning and Transportation Commission for regulations in the San Carlos Municipal Code including Planning and Transportation Commission findings for amendments to the Title 18 and the reasons for the recommendations, the relationship of the proposed ordinance or amendments to the Zoning Ordinance (Title 18), and 2030 General Plan.

WHEREAS, the City Council finds the Ordinance update process evaluated the existing ordinance and explored options for changes based on evidence and best practices in other communities and industry experts; and
SECTION 3: The City Council makes the following findings:

A. The proposed ordinance amendments are consistent with the General Plan.

The General Plan includes the following goal:
* Goal LU-5: Support and maintain land uses that contribute to a vibrant and resilient local economy and support the fiscal well-being of the City.

SECTION 4: Replacement of Code. San Carlos Municipal Code Sections

18.05.020 (Mixed-Use Districts Land Use Regulations), 18.06.020 (Commercial Districts Land Use Regulations), 18.07.020 Industrial Districts Land Use Regulations and Section

18.23 (Standards for Specific Uses and Activities) is hereby replaced with the language in Exhibit A.

SECTION _5: California Environmental Quality Act Determination. The City Council hereby finds that this Ordinance is exempt from the provisions of the California Environmental Quality Act (CEQA) Guidelines Section 15061(b)(3), the general exemption for projects with no potential for a significant effect in the environment. As a text amendment, it can be seen with certainty that there is no possibility that the amendments will have a significant effect on the environment.

SECTION 6: Severability. If any section, subsection, sentence, clause, phrase, or portion of this Ordinance is for any reason held to be invalid or unconstitutional by the decision of any court of competent jurisdiction, such decision shall not affect the validity of the remaining portions of this Ordinance. The City Council of the City of San Carlos hereby declares that it would have adopted this Ordinance and such section, subsection, clause, phrase, or portion may be declared invalid or unconstitutional.

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SECTION 7: That the City Council hereby declares that it would have passed this Ordinance sentence by sentence, paragraph by paragraph, and section by section, and does hereby declare that any provisions of this Ordinance are severable and, if for any reason any sentence, paragraph or section of this Ordinance shall be held invalid, such decision shall not affect the validity of the remaining parts of this Ordinance.

SECTION 8: This Ordinance shall be published and posted according to law and shall take effect and be in force from and after 30 days after its passage and adoption. |, City Clerk Crystal Mui, hereby certify that the foregoing Ordinance was introduced on this day of September, 2026 and adopted at a regular meeting of the City Council of the City of San Carlos held on the September, 2026 by the following vote:

AYES,
NOES,
COUNCILMEMBERS:

COUNCILMEMBERS:

ABSENT, COUNCILMEMBERS:

CITY CLERK of the City of San
Carlos
APPROVED:

MAYOR of the City of San Carlos 8.g
October 13, 2026 Packet Pg. 95

CITY COUNCIL

STAFF REPORT
MEETING DATE: October 13, 2026
ITEM TITLE: Receive an Update on Winter Storm Season Preparedness.

RECOMMENDATION:

Receive an update on City actions related to winter storm season preparedness for the 2026-27 winter season.

FISCAL IMPLICATIONS:

There are no fiscal implications, and no additional funding is needed The Public Works Department maintenance budget includes allowances for winter storm season preparedness and response. If a major event requires spending beyond the adopted budget, staff will return to the Council to request supplemental appropriations and will pursue reimbursement through mutual aid, state, or federal programs where eligible.

BACKGROUND:

California is preparing for a potentially historic, record strong El Niño season that is expected to bring heightened risks of severe winter storms, coastal flooding, and heavy rainfall through early 2027. Flooding and severe weather are anticipated in San Mateo County, which may be further exacerbated if coupled with king tides. Anticipated king tides windows include November 24 to 26, December 22 to 25, and January 20 to 23.

Governor Gavin Newsom proclaimed a statewide state of emergency on September 21, 2026, to fast-track flood-fighting supplies, mobilize the National Guard, and pre-position critical emergency resources in advance. However, this declaration doesn't bring local funding to assist cities and counties with preparations.

The City is currently working to prepare for this upcoming storm season. This report provides an overview of the City’s preparedness activities, planned community outreach, and coordination with other agencies.

ANALYSIS:

Infrastructure Preparedness Efforts
The Public Works department begins preparing for the winter season every August, with mitigation and safety work lasting throughout the fall and winter months until the rainy season is over. This work includes:

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• Storm Channels and Creeks -- City staff clean debris, trash, and vegetation out of major storm channels and creeks that carry storm water to the Bay and prevent it from collecting on San Carlos streets. The clearing of these waterways prevents blockages and potential flooding.
• Stormwater Pump Stations -- There are five pump stations located in San Carlos and each station contains two pumps. Each pump is pulled, cleaned, tested, and replaced (if necessary) to ensure they are functioning properly. The pumps are housed in wet wells, which store and retain stormwater until it can be transferred into the storm drain systems and waterways. Staff clean the wet wells to remove obstructions and debris and repair any cracks that may lead to leaks.
• Hillside Erosion Control -- Every year, City maintenance crews work with contractors to install erosion control measures on hillsides that are susceptible to mudslides. These measures help protect both homes and roadways.
• Flushing and Cleaning Storm Drain Inlets -- City staff clean and flush more than 250 storm drain inlets to remove dirt, debris, and trash that prevent water flow or cause overflow and flooding.
• Storm Outfalls and Retention Basin Clean-ups -- The City has five large storm outfalls and retention basins built to hold excess storm water, located in the rear of some properties and City parks. These are cleaned every season to help curb flooding. • Storm Swales and Gutters -- Crews clear trash and debris and remove overgrown vegetation in swales and gutters to prevent blockages and the potential flooding of backyards and city parks.
• Storm Equipment and Machines -- All machines and equipment used during the winter season are inspected and preventative maintenance is completed.

Public Works is also in the process of issuing requests for proposals for on-call contracts for emergency services, including:
• Emergency Tree Response
• Emergency Pump Service
• Emergency Combination Flusher Contractor
• Emergency Generator Service
• Emergency Roofing Contractor

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The City plans to have multiple contractors for several of these services because contractors can quickly become unavailable during a significant storm event. In addition, the City is ordering additional Personal Protective Equipment (PPE), reflective signs, lights, hand tools, and other storm response supplies.

In addition to these preparations, City staff is putting together several emergency response trainings to make sure staff at all levels of the organization are up to date on our Emergency Operation Center processes and storm response procedures.

Preventative maintenance does not stop at the beginning of the winter or rainy season. Staff will continue to routinely clean and maintain all storm drain inlets, creeks, swales, and gutters before and after each individual rain event to prevent blockages, flooding, and any impacts to the San Carlos community throughout the winter season.

Community Preparedness Efforts
To help prepare our residents and businesses for this upcoming winter season, the City is working October 13, 2026 Packet Pg. 97
on a number of outreach efforts to make sure the community has the information they need.

A brief summary of communication efforts include:
• Including a storm preparedness article in the Good Living newsletter and preparing a Storm Preparedness postcard to be mailed to all residents in late October/early November.
• Updating the City storm resource page at cityofsancarlos.org/storm. • Updating our general emergency preparedness page at cityofsancarlos.org/emergency. • Re-sharing proactive preparation actions/tips the community can take now before the storms hit.
• Re-sharing City videos on specific topics (go bags, making a plan, etc.). • Monitoring and sharing County resources and updates.
• Renewed push for community members to sign up for SMC Alert (https://www.smcgov.org/dem/smc-alert) and Genasys (https://protect.genasys.com). • Creating new storm/emergency templates for quick social media information dissemination
The City’s sandbag stations are currently open and stocked for the upcoming season. Community members are welcome to fill 10 bags (20 for businesses) at the San Carlos Corporation Yard, located at 1000 Bransten Road, Monday through Friday. In addition, community members are encouraged to prepare for possible power outages by locating flashlights and creating emergency kits.

Coordination with Outside Agencies
The County Department of Emergency Management is hosting a series of events and trainings to coordinate preparations for this upcoming winter. These events include organizing on-going briefings, including updated weather forecasts and providing training and shared resources for crisis communications.

Public Works Engineering is coordinating with neighboring cities and OneShoreline on El Niño preparedness. The plan is to hold a virtual coordination meeting and establish a SharePoint folder in advance, with individual folders for each agency to upload relevant resources such as wet weather preparation checklists, standard operating procedures, flood preparation information, and other materials. Since the County has been designated as the Operational Area Coordinator under the mutual aid agreement, the agencies will also work to update their local agency coordinator names and contact information.

ALTERNATIVES:

The alternatives available to the City Council include:

1. Receive the report on the City’s winter storm season preparedness; or

2. Direct staff to consider additional storm season preparedness measures.

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Respectfully submitted by:

Tracy Scramaglia, Assistant Public Works Director;
Steven Machida, Public Works Director; and
Kathy Kleinbaum, City Manager
Approved for submission by:
____________________________
Kathy Kleinbaum, City Manager

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October 13, 2026 Packet Pg. 99

CITY COUNCIL

STAFF REPORT
MEETING DATE: October 13, 2026
ITEM TITLE: Receive a Presentation on Entertainment Zones and Provide Direction on Whether to Establish an Entertainment Zone in San Carlos.

RECOMMENDATION:

Staff recommend that the City Council receive a presentation on entertainment zones and provide direction on whether to establish an entertainment zone in San Carlos.

FISCAL IMPLICATIONS:

There are no fiscal implications, and no additional funding is necessary.

BACKGROUND:

Consistent with the stated goals of the City’s Prosperity and Economic Development (PED) section of the Downtown Specific Plan, which went into effect on February 25, 2026, “the Downtown core will support both retail and restaurant destinations, strengthen economic vitality, and provide for everyday needs through a welcoming and engaging public realm that supports residents, workers, visitors, and businesses alike.” Specifically, action PED-7 of the Specific Plan recommends that the City explore the feasibility of establishing an entertainment zone in the Downtown area to further the goals of the PED.

In general, entertainment zones (EZs) allow cities and counties to designate public areas where open-container alcohol consumption is permitted during specified hours or events. EZs were enabled by Senate Bill (SB) 969, which took effect January 1, 2025.

According to an April 2026 report by CVL Economics titled California Entertainment Zones:

Statewide Inventory and Insights for Economic Development and Arts and Culture, “California entertainment zones represent a new generation of placemaking policy - a relatively low-cost, high-visibility intervention that municipalities can deploy to support economic revitalization, activate public spaces, and strengthen connections between local businesses, arts organizations, and residents. The economic benefits of entertainment zones will depend largely on the City’s established policies around activation.”
The report also states that 17 cities throughout California have formally adopted entertainment zone ordinances as of March 2026, including Sacramento and San Francisco. Redwood City is the only city in San Mateo County to have adopted an entertainment ordinance (May 11, 2026).

In Santa Clara County, San Jose, Santa Clara, Mountain View, and Palo Alto adopted entertainment ordinances on June 10, 2025, February 17, 2026, April 28, 2026, and May 4, 2026, respectively.

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The purpose of this study session is to explain the legal requirements related to EZs, consider how EZs might be implemented in San Carlos, and seek the Council’s direction on whether it would like to pursue an EZ in San Carlos.

ANALYSIS:

Cities’ Legal Requirements Related to EZs
An EZ can only be established through enactment of a local ordinance. The following conditions must be met:

1. The city must notify local law enforcement and request feedback about:
a. Potential health and safety impacts that might be generated by the entertainment zone and strategies to mitigate those impacts
b. The EZ’s proposed boundaries, days and hours of operation, types of alcoholic beverages permitted, and approved nonglass and nonmetal containers

2. The city must establish a process or procedure by which persons in possession of alcoholic beverages in the EZ may be readily identifiable as being 21 years of age or older (such as the use of wristbands)

3. Upon establishing or modifying the EZ, the city must provide all of the following to California Department of Alcoholic Beverage Control (ABC):
a. A copy of the ordinance establishing or modifying the EZ b. Necessary information to identify the boundaries of the EZ c. The days and hours of operation
d. The types of alcoholic beverages permitted
e. The approved nonglass and nonmetal containers in which alcoholic beverages may be authorized
After an EZ has been established, the city must review the operation of the entertainment zone every two years, and in consultation with local law enforcement agencies, ensure that the EZ is being maintained in a manner that protects the health and safety of the general public. Reports of these reviews must be made available to ABC upon request.

Business’ Legal Requirements Related to EZs
Businesses may be eligible to participate in the sale of alcoholic beverages as part of an EZ if they have an existing permanent business location (i.e., a brick-and-mortar business) within the designated boundaries of the EZ, possess an active ABC license, and have met ABC’s requirement to provide annual notification of their intent to participate in the city’s EZ.

Patrons of eligible participating businesses may leave the business and walk into an EZ with open containers of alcohol if the following conditions are met:

1. Consumption of the type of alcoholic beverage they are consuming must be authorized by the ordinance creating the entertainment zone. For example, if the ordinance only allows beer and wine, and the patron is consuming a cocktail with liquor, they are not permitted in the EZ

2. Open alcohol containers only leave the premises during the hours allowed by the ordinance establishing the entertainment zone. For example, if the restaurant is open until 11:00 p.m., but ordinance’s maximum activation hours are until 10:00 p.m., the business patron may not be in the EZ after 10:00 p.m.

3. Patrons with open containers exit the premises directly into an EZ

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4. The premises expressly prohibit alcoholic beverages acquired outside their premises

5. Glass or metal containers are not used in the EZ
Serving Alcohol in Public and Private Spaces in San Carlos Today According to San Carlos Municipal Code Section 9.10.010, “it is unlawful for any person to drink any beer, wine or other intoxicating beverage on any public sidewalk, alley, street or highway.” Exceptions to this rule are made several times a year to allow for the sale of beer and wine for City-sponsored recreation events such as Art & Wine Faire, Wine Walk, Night of Holiday Lights, and the Summer Concert Series. For these types of events, the City, per an agreement with the San Carlos Parks and Recreation Foundation (“the Foundation”), allows the Foundation, with applicable ABC licensure, to serve alcohol to attendees at City-owned properties. Also, 50% of the net proceeds from the sale of beer and wine during these events are donated back to the City to help offset the cost of the event. The remaining funds are donated to other various park improvement projects and the fee assistance program. On average, the City receives $57,000 per year from these events.

Businesses that wish to serve alcohol on their private premises must also obtain an ABC license.

The type of license depends on the unique offerings, operating conditions, and footprint of each business. As of July 2026, there were 31 businesses along the 600, 700, and 800 blocks of Laurel Street with valid ABC licenses. Many of these are restaurants with license type 41 “on-sale beer & wine – eating place” or license type 47 “on-sale general – eating place” licenses and alcohol must not leave the premises of the business. However, Title 4. Department of Alcoholic Beverage Control Proposed Regulations allows for licensing of permanent non-contiguous areas of restaurants (e.g. a sidewalk separating a parklet from the main licensed area of the restaurant) as long as the non-contiguous area’s distance from the main licensed area does not exceed twenty-five feet.

Considerations for the Council

1.Does the Council support establishing an Entertainment Zone in San Carlos? Establishment of an entertainment zone or zones in San Carlos would be consistent with the City’s adopted Downtown Specific Plan and could help generate additional sales for local businesses during Downtown events. According to the CVL Economics report, “the most successful implementations treat entertainment zones as ongoing platforms for creative placemaking, not simply regulatory carve-outs for outdoor drinking.” The report recommends activating entertainment zones around live music events, art installations, cultural festivals, and other forms of entertainment.

2. What area might the EZ cover?
Redwood City established an EZ within its pedestrian mall at the 2000 block of Broadway and the section of Redwood Creek between Broadway and the Main Street Parking lot. This location was selected because it was closed to vehicular traffic, there is sufficient density of ABC licenses, and clear entrances and exits, all of which make the zone easier to manage.

San Carlos might also consider the 700 Block of Laurel Street for the same reasons Redwood City listed. However, for equity reasons, the Council may want to also consider extending the benefits of an EZ to the 600 and 800 blocks of Laurel, as well as the 1100 and 1200 blocks of San Carlos Avenue, due to the concentration of existing ABC licensees at these locations.

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Mountain View established its EZ along five blocks of Castro Street due to their commercial identities, history of hosting successful special event permits, and pedestrian-friendly environment.

It is important to note that according to feedback from other cities, activating an EZ on a street that is already closed to traffic and populated with outdoor restaurant seating and parklets, doesn’t necessarily create more foot traffic as many patrons are happy enough to sit at the parklet.

3. When should EZs be activated?
Both Mountain View and Redwood City decided to activate their EZs during very specific, Citysponsored events. Mountain View activated its EZ twice with its summer 2026 soccer watch parties. The City Council may want to consider activating an EZ around City-sponsored events in the Downtown. Alternatively, the Council could limit the use of EZs to only events that do not have currently include Parks and Recreation Foundation beer and wines sales such as the Citybranded Life on Laurel events.

Another option would be to designate a consistent day, such as “the first Thursday” or “the first Friday” of every month. However, based on feedback from both Redwood City and Mountain View, EZ activations that are not tied to events are not as engaging or well attended. In other words, staff was advised that if activation is the goal, activation is better achieved through events, rather than relaxing rules around public alcohol consumption.

Next Steps
If the Council directs staff to proceed with an EZ for San Carlos, the next steps would be to (1) draft an ordinance for adoption, (2) convene a multi-departmental team of staff to develop a set of internal operating procedures for activation, (3) develop a set of regulations to share with participating businesses, and (4) conduct business outreach and education.

A multi-departmental team of police, fire, parks and recreation, and economic development, maintenance and operations would need to be established to address a range of issues related to EZ activation such as:

1. Types of signage and physical barriers to be installed around the EZ barriers

2. How will eligible businesses and community partners be notified in advance of each activation?

3. What type of signage are participating businesses required to post?

4. Who will distribute the City-approved event wristbands to demonstrate patron is over 21 years of age, as well as the City-approved cups that ensure outside beverages are not brought into the EZ?

5. How many safety officers and staff should be present to ensure public safety and adherence to the rules?

6. What type of additional trash and recycling is required?

7. How will incidents and violations be addressed?

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The City of Mountain View has a Downtown Entertainment zone Operations Manual that addresses these types of questions. The manual also includes city-specific restrictions such as mobile advertising displays, outdoor sales of merchandise, and temporary structures such as October 13, 2026 Packet Pg. 103
tents. Its Chamber of Commerce and Downtown Business Association support Mountain View’s EZ activation by assisting with event coordination and planning, conducting business outreach and education related to the EZ Operations Manual, and helping communication participation requirements to downtown businesses. The City of Mountain View identifies at least one staff member on-site to serve as a designated liaison with its police department and one other staff member to produce the Operations Manual upon request.

ALTERNATIVES:

The alternatives available to the City Council include:

1. Provide staff with feedback on the information presented and recommend next steps; or

2. Direct staff to further evaluate additional information; or

3. Direct staff to not proceed further.

Respectfully submitted by:

Nil Blackburn, Assistant City Manager
Approved for submission by:
____________________________
Kathy Kleinbaum, City Manager

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San Carlos City CouncilOctober 13, 2026

San Carlos City Council
October 13, 2026