1 David Yakobson
From: Alex Elliott
Sent: Friday, April 10, 2026 8:06 PM
To: councilmtgitems
Subject: 16 Item - Encouraging Responsible AI Use - Hall, Zwick, Torosis Attachments: Disabilities Commission_AI Adhoc letter_Final (1).docx Good evening,
Please post the attached letter as part of the written comment for 16 Item - Encouraging Responsible AI Use - Hall, Zwick, Torosis: Ad hoc committee on Artificial Intelligence Opportunities and Risks:
https://www.santamonica.gov/media/HHS/Commissions/AI%20Adhoc%20letter_2026%200211.pdf Thank you,
Alex Elliott
Chair, Santa Monica Disabilities Commission
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February 11th, 2026
City of Santa Monica
1685 Main Street, Room 209
Santa Monica, CA 90401
RE: Ad hoc committee on Artificial Intelligence Opportunities and Risks Dear Honorable Mayor Caroline Torosis, City Council & City Manager Oliver Chi:
The Disabilities Commission meets monthly to develop recommendations on City policy impacting access to public services from the cradle to the grave. I am reaching out on behalf of the Disabilities Commission to provide recommendations for planning, implementing and governing Artificial Intelligence (AI) technologies for all Santa Monica residents, including people with disabilities.
The Disabilities Commission has been following the progress in AI systems over the past few years to understand what opportunities and risks these systems have for people with disabilities in Santa Monica. AI has the potential to benefit people with disabilities in everyday tasks, navigation, communication, education, employment, health, and independent living. Current uses of AI by people with disabilities include assistive technology such as speech recognition and automated captions that can improve communication and access, smart mobility devices for navigating indoor and outdoor spaces, and AI powered medication reminders, shopping lists, and other tasks to aid independent living.
AI poses many potential risks for people with disabilities in employment, education, healthcare, transportation, benefits determination, information and communication, and the legal system.
Across the country, governments at the local, state, and federal level have been studying recent developments in AI and drafting policies for how these tools should and should not be used in governance. For example, in October Governor Newsom signed several bills addressing new and emerging technology, such as AI. On October 1st, 2025, the California Civil Rights Council implemented regulations to protect against potential employment discrimination because of the use of AI, algorithms, and other automated-decision systems. The newly approved regulations provide increased clarity on how existing antidiscrimination laws apply to the use of AI in employment decisions.
AI and algorithmic technologies create outputs based on inputs, which are derived from datasets (sometimes referred to as “training data”). Oftentimes, training datasets are not an accurate representation of people with disabilities — they may have inaccurate data about disability, undersample or improperly tag information as being related to disability. These factors can all lead to AI tools that can discriminate against disabled people and contribute to negative outcomes. Ensuring that people with disabilities are centered in the creation, deployment, and auditing of these technologies and of the policies that govern them can help to mitigate the risks of these tools.
The Disabilities Commission recommends the City Manager and City Council take the following steps to improve the opportunities and minimize the risks of Artificial Intelligence technologies:
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1. Include the ADA Coordinator in the procurement and implementation of AI technologies.
The ADA coordinator should receive training on the potential risks and benefits of AI and be included in the procurement, implementation, and evaluation of AI.
2. Explore use of AI tools to improve the accessibility of the City's websites, applications, and digital assets
April 24, 2026 marks the compliance date for the new rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments to conform with Web Content Accessibility Guidelines 2.1 Level AA. We recommend City IT staff explore AI technologies to create accessible digital assets and spaces. For example, 1) Use of AI to support development of alternative text (alt-text) for images or captioning on its website. Some residents rely on screen readers to understand the contents of a webpage, but screen readers can typically only understand images with alt-text. 2) Use of AI tools to help to audit and remediate documents with accessibility issues. Many important municipal documents are delivered in PDF format (e.g., the agenda and minutes for City Council meetings). PDF files with accessibility issues can be very expensive and time consuming to remediate compared to other formats such as HTML. AI tools could be used to identify WCAG issues before documents are uploaded to a website’s document library. Explore using AI tools to support efforts to convert high volumes of PDF documents to HTML, as well as the potential use of AI-enhanced captioning, transcription services, and document summaries into plain language. The city needs to take responsibility for providing accessible services even if AI changes how residents access services.
3. Collaborate with the Disabilities Commission and residents with disabilities in the planning, development, implementation, and evaluation of AI Policies AI is evolving and changing rapidly, as the City develops its AI plans, keep in mind that the Disability Commission is always available to advise, collaborate, and answer questions about potential risks and benefits of AI. In other words:
nothing about us without us. The Disabilities Commission invites city staff to our public hearing on July 8th, 2026, to continue the collaboration.
4. Improve access to Information, Communication, and Technology (ICT) (Hardware, Software, Telecommunications networks) for assistive technologies powered by AI
The cost of the hardware, software, and connectivity for assistive technologies powered by AI Technologies remain a barrier for many residents with disabilities.
It is critical to improve efforts to increase access to the devices, software, and broadband needed to access assistive technology features that promote independence. For example, the statewide California Broadband for All efforts to reduce the digital divide and other programs that lower the cost of access.
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5. Disclose the Use of AI; Minimize Bias; Monitor and Assess People with disabilities need to know when and how AI is being used so they can assess whether they may be unintentionally or especially impacted. AI data systems must be trained with diverse datasets that include representation of people with disabilities to minimize bias. The city needs to continuously monitor and assess AI technologies for impacts on people with disabilities.
6. Learn from other environments and share lessons learned For example, CA Department of Technology - Artificial Intelligence Community, U.S. Access Board, Pacific ADA Center, City Connect, and others.
The Commission would like to thank the Council and City staff for always keeping the interests of people with disabilities in mind during planning and execution of City projects and objectives. The Disabilities Commission believes all Santa Monica residents should have full and equal access and a voice in City decision making, which promotes belonging and equity in our community. Thank you for your consideration.
Sincerely,
Santa Monica Disabilities Commission
Alex Elliott, Chair
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1 David Yakobson
From: Shawn Landres <[email protected]>
Sent: Tuesday, April 14, 2026 11:48 AM
To: councilmtgitems
Subject: 16-H
Attachments: Op-Ed- AI already Is in Your Public Comment. Santa Monica Should Have Something .pdf
EXTERNAL
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By: Shawn Landres
Date: April 14, 2026
Image via Freepic.
Shawn Landres PhD, a Senior Fellow at the UCLA Luskin School of Public Affairs, is a secondterm Santa Monica Planning Commissioner and former chair of the Planning and Social Services commissions. The views expressed here are his own.
OPINION
Op/Ed: AI already Is in Your Public Comment.
Santa Monica Should Have Something to Say
About That.
Santa MonicaNEXT
https://santamonicanext.org/2026/04/op-ed-ai-already-is-in-yoment-santa-monica-should-have-something-to-say-about-that/ 4/14/26, 11:45 AM
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Tonight the City Council takes up a proposal from Mayor Torosis and Councilmembers Hall and Zwick to make Santa Monica a national model for responsible AI use in local government. The item would update the City’s AI policy, authorize enterprise AI accounts, embed AI training in the reestablished Santa Monica Institute, and commit the City to protecting workers from displacement.
Clearly there is a pressing need to address how the City uses AI. But AI already is reaching the City: through the public comments, letters, and increasingly the phone lines that shape every decision the Council and its commissions make.
Council ought to consider not only how the City uses AI, but also how AI might be using the City.
Last December, the Planning Commission unanimously took up my call to delay a vote on housing subdivision rules because the public had not had enough time to weigh in. I told residents: “Tell us what you think. We will read your comments and take them seriously, all of them, even if we disagree with them.”
They did. In advance of our March 4 study session, we received more than 250 public comments, many within 24 hours of the meeting. I analyzed the packet with AI, asking which letters departed from organized templates and which adapted the template to the writer’s own concerns.
AI helped me do my job better. The same technology that helped me read 250 comments also could have written them.
In February, the LA Times revealed that a consultant used CiviClick, an AI platform, to generate over 20,000 opposition messages to the South Coast Air Quality Management District, targeting clean air rules expected to prevent 2,500 premature deaths. Three of five purported commenters had no knowledge of the letters. The board voted 7-5 to reject the rules. When residents cannot trust that public comments come from actual people, civic engagement stops connecting communities to decision-makers and starts connecting algorithms to the public record.
The quieter problem may prove harder to fix. A Stanford-led study found that every large language model tested for summarizing public comments scored majority positions higher than https://santamonicanext.org/2026/04/op-ed-ai-already-is-in-yoment-santa-monica-should-have-something-to-say-about-that/ 4/14/26, 11:45 AM
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minority ones. It is one thing for a disabilities commission to use AI to disaggregate sidewalk mobility experiences — that is precision. It is bias when an AI tool, in search of coherence at the expense of accuracy, treats more numerous homeowner comments as more representative than renter comments, or flattens the comments of Spanish-speaking families and workers into a summary that mirrors the majority view.
Five reforms would address how AI reaches City Hall from the outside. First, require any body using AI to summarize public comments to disclose the tools and parameters used to build the summaries; the Little Hoover Commission’s 2024 report calls for this transparency. Second, publish a model anti-bias prompt and agendize it for discussion and approval; the choices in a summarization prompt are policy decisions, and policy decisions belong in open session. Third, mandate disclosure of AI-generated comments, following campaign finance law’s source-tracing approach for out-of-state contributions. Fourth, track AI equity: who participates, through which channels, and whether the process is reaching the residents it was designed to serve. Fifth, design remote public comment to be easy for humans and hard for AI agents. AI-generated callers eventually could attempt live public comment, but California law prohibits requiring commenters to identify themselves. Friction-based measures like rate limiting and live-connection requirements could help, but the state will need to address this tension directly.
Santa Monica can lead here. The Council’s Tuesday item establishes how the City uses AI responsibly within its own walls. A companion set of policies could establish how the City handles AI when it arrives from outside: in the comment packet, on the phone line, in the summary of what our neighbors said. SB 707 compliance itself belongs in that companion framework: after July 1, AI very likely could be translating agendas, captioning meetings, and processing comments on behalf of the City, and residents deserve to know which tools are doing that work and under what rules. Together, the two frameworks would do what neither does alone:
protect the integrity of the conversation between residents and the government that serves them.
Author
https://santamonicanext.org/2026/04/op-ed-ai-already-is-in-yoment-santa-monica-should-have-something-to-say-about-that/ 4/14/26, 11:45 AM
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https://santamonicanext.org/2026/04/op-ed-ai-already-is-in-yoment-santa-monica-should-have-something-to-say-about-that/ 4/14/26, 11:45 AM
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