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eComments - Item 13_Redacted.pdf

South San Francisco City Council
January 26, 2022

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eComments - Item 13_Redacted.pdf
Meeting
January 26, 2022
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South San Francisco City Council
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Text extracted from the city's file for reading and search. Open the original on ci-ssf-ca.legistar1.com. That file is the official record.

Agenda Item

13. 22-59 Report regarding consideration of options for stationary Automatic License Plate Readers (ALPR) cameras at the entrance/exit ramps of Highway 101 and Interstate 380, Interstate 280, and/or intersections between South San Francisco and neighboring cities, and potential adoption of a resolution to select an option. (Maryjo Nuñez, Lead for America Fellow, City Manager's Office) Legislation Text Attachment 1: Letter from Chamber of Commerce Attachment 2 SMC Cities with ALPR Cameras Attachment 3 GIS Map 1 for ALPR Attachment 4 ALPR Cameras for 380, 101, and 280 Attachment 5 All Intersections Map Attachment 6 ALPR Resolution Presentation (for 1.26.22) 4 Public Comments
Guest User at January 26, 2022 at 2:21pm PST
Oppose
My name is Sara Matlin. I am a volunteer co-chair of the local ACLU-North Peninsula Chapter, along with Beth von Emster, who also submitted public comment I am writing to oppose the purchase of Automated License Plate Readers (ALPRs). ALPRs present numerous constitutional and ethical concerns.

They are a threat to safety and civil rights and do not make our communities safer The ACLU-NP is an all-volunteer group of community members that seeks to protect and advance the civil liberties of all residents, employees, and students in San Mateo County We represent more than 4,000 people in San Mateo County, many of them in South San Francisco. Thank you to Mike Futrell, who let us know yesterday that this item would be on the City Council agenda today I wish we had known sooner, in order to gather and share additional information and concerns from affected community members
ALPR systems are frequently and disproportionately used against marginalized people, leading to real-life harm and unnecessary police encounters The use of ALPR systems to harm marginalized communities including immigrants, Black Americans, and American Muslims – is well documented. As with other surveillance technologies, police often deploy license plate readers disproportionately in poor areas, regardless of crime rates. [https://www.eff.org/deeplinks/2015/01/what-we-learned-oakland-raw-alpr-data] ICE has been shown to exploit ALPR systems and databases to locate and deport immigrants https://www.aclunc.org/blog/documents-reveal-ice-using-driver-location-data-local-police-deportations].

The California State Auditor’s 2020 report reveals that lax ALPR use allows law enforcement to “misuse ALPR images to stalk an individual or observe vehicles at particular locations and events, such as … political rallies ” [https //www auditor ca gov/reports/2019 118/index html] An Associated Press investigation found that police officers misused ALPRs to spy on romantic partners, business associates, neighbors, and journalists
[https://apnews.com/article/699236946e3140659fff8a2362e16f43] ALPR systems collect and store location information about all drivers whose cars pass through their cameras’ fields of view. This information, after being matched to dates, times, and locations, can be compiled into databases that reveal sensitive information about where our community members work, live, associate, and visit. Breaches and ransomware are a regular occurrence, and the misuse of surveillance data is not uncommon
South San Francisco’s liability exposure would be enormous if it adopted additional ALPR systems San Francisco’s experience should serve as a cautionary tale: ALPR misuse led to the detention of a Black woman at gunpoint, leading to an expensive civil rights lawsuit against the city [https://www.aclunc.org/blog/san-francisco-paying-price-surveillance-without-safeguards] In addition, a study in Vallejo found that 35 percent of “hits” from mobile ALPRs and 37 percent of all “hits” from fixed readers were misreads — an unacceptable high rate of error.

ALPR doesn’t make communities safer The ACLU urges cities to consider policies and the allocation of resources to non-policing programs that actually improve the safety and health of our communities. Please consider the serious concerns and recommendations noted in the ACLU of Northern California’s Making Smart Decisions About Surveillance. [https://www.aclunc.org/publications/making-smart-decisions-aboutsurveillance guide community transparency accountability] Please consider the rights of South San Francisco and San Mateo County community members and refrain from expanding South San Francisco’s system of automated license plate readers Thank you,
Sara Matlin
ACLU-North Peninsula Chapter, Volunteer
@gmail com
Guest User at January 26, 2022 at 12 52pm PST
Oppose
@gmail com
Guest User at January 26, 2022 at 12 09pm PST
Oppose
There needs to be regular community meetings in EACH neighborhood throughout SSF about decisions being made that impact all SSF residents and communities. Option 3 is an overkill of unnecessary cameras and do not see justification for need or spending of this excessive amount of funds, especially when resident needs of all ages are not being met (education, services, childcare, parks, programs, etc.) Guest User at January 26, 2022 at 7:16am PST
Oppose
I am the co-chair of the North Peninsula Chapter of the ACLU of Northern California. I oppose the purchase and use of automated license plate readers (ALPRs) in South San Francisco.

A decision regarding vehicle-monitoring cameras imposes significant legal, ethical, financial, communal costs and would further infringe on the rights of San Mateo County residents. Much more community involvement and input should be sought before taking such high risk steps Public access to private data. Whether their cameras are attached to police cars or street lights, ALPR systems collect and store location information about drivers whose cars pass through their cameras’ fields of view. This information, after being matched to dates, times, and locations, can be compiled into databases that reveal sensitive information about where our community members work, live, associate, and visit. Breaches and ransomware are a regular occurrence, and the misuse of surveillance data is not uncommon
ALPR systems are frequently and disproportionately used against marginalized people, leading to real-life harm and unnecessary police encounters The use of ALPR systems to harm marginalized communities including immigrants, Black Americans, and American Muslims – is well documented. For example, ICE has been shown to exploit ALPR systems and databases to locate and deport immigrants As with other surveillance technologies, police often deploy license plate readers disproportionately in poor areas, regardless of crime rates
Public input into policy to protect privacy, civil liberties, and security. California law requires an opportunity for public comment; a written, publicly available use policy that is “consistent with respect for an individual’s privacy and civil liberties;” and reasonable security safeguards for any use of automated license plate readers South San Francisco’s ALPR policy is an exact copy of the Northern California Regional Intelligence Center’s policy, and your policy was most recently modified in 2017. This means that the policy was not drafted to include local input and concerns, and it was not revised recently In fact, since South San Francisco is already using ALPRs, it’s likely that policy was created without sufficient opportunity for community input
Cost and Liability. South San Francisco’s liability exposure would be enormous if it adopted additional ALPR systems San Francisco’s experience should serve as a cautionary tale ALPR misuse led to the detention of a Black woman at gunpoint, leading to an expensive civil rights lawsuit against the city. In addition, a study in Vallejo found that 35 percent of “hits” from mobile ALPRs and 37 percent of all “hits” from fixed readers were misreads — an unacceptable high rate of error.

ALPR doesn’t make communities safer I urge you to instead consider policies and the allocation of resources to non-policing programs that actually improve the safety and health of our communities.

Please refrain from expanding South San Francisco’s system of automated license plate readers Sincerely,
Beth von Emster, Co chair, North Peninsula Chapter of ACLU of Northern California

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