4 If, after the date of this Purchase Agreement and until the End Date if the Official Statement is timely filed on EMMA, any event shall occur or circumstance shall exist of which the City has knowledge that would cause the Official Statement to contain any untrue statement of a material fact or to omit to state a material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading, the City shall notify the Underwriter (and for the purpose of this Section provide the Underwriter with such information as it may from time to time reasonably request), and, if in the opinion of the City or the Underwriter such event or circumstance requires the preparation and publication of a supplement or amendment to the Official Statement, the City will prepare such a supplement or amendment, at the City’s expense, so that the Official Statement as then supplemented or amended, will not contain an untrue statement of a material fact or omit to state a material fact that is required to be stated therein or necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading and furnish to the Underwriter a reasonable number of copies of such supplement or amendment. The Underwriter shall promptly notify the City in writing of the end of the Underwriting Period, provided that in the absence of written notice by the Underwriter to the City before the Closing Date, the end of the Underwriting Period is the Closing Date.
4. At 8:30 a.m., Pacific Time, on [Closing Date], or at such other time or date as shall be agreed upon by the Underwriter and the City (such time and date being herein referred to as the “Closing Date”), the City shall deliver, or cause to be delivered, to the Trustee the Bonds in definitive form, registered in the name of Cede & Co., as the nominee of The Depository Trust Company, New York, New York (“DTC”) (so that the Bonds may be authenticated by the Trustee and credited to the account that is specified by the Underwriter under DTC’s FAST procedures).
On or before such Closing Date, the City shall deliver, at the offices of Anzel Galvan LLP (“Bond Counsel”) in San Francisco, California, or at such other place as is mutually agreed upon by the Underwriter and the City, the other documents that are described in this Purchase Agreement. On the date of the Closing, the Underwriter shall pay the purchase price of the Bonds as set forth in Section 1 of this Purchase Agreement in immediately available funds to the order of the Trustee.
The delivery and payment described above are referred to herein as the “Closing”).
5. (a) The Underwriter agrees to assist the City in establishing the issue price of the Bonds and shall execute and deliver to the City at Closing an “issue price” or similar certificate for the Bonds, together with the supporting pricing wires or equivalent communications, substantially in the form attached hereto as Exhibit B, with such modifications as may be appropriate or necessary, in the reasonable judgment of the Underwriter, the City and Bond Counsel, to accurately reflect, as applicable, the sales price or prices or the initial offering price or prices to the public of the Bonds.
(b) Except as otherwise set forth in Exhibit A attached hereto, with respect to the Bonds, the City will treat the first price at which 10% of each maturity of the Bonds (the “10% test”) is sold to the public as the issue price of that maturity. At or promptly after the execution of this Purchase Agreement, the Underwriter shall report to the City the price or prices at which it has sold to the public each maturity of Bonds. With respect to the Bonds, if at that time the 10% test has not been satisfied as to any maturity of the Bonds, the Underwriter agrees to promptly report to the City the prices at which it sells the unsold Bonds of that maturity to the public. With respect to the Bonds, that reporting obligation shall continue, whether or not the Closing Date has occurred, until either (i) the Underwriter has sold all Bonds of that maturity or (ii) the 10% test has
5 been satisfied as to the Bonds of that maturity, provided that, the Underwriter’s reporting obligation after the Closing Date may be at reasonable periodic intervals or otherwise upon request of the City or Bond Counsel. For purposes of this Section, if Bonds mature on the same date but have different interest rates, each separate CUSIP number within that maturity will be treated as a separate maturity of the Bonds.
(c) The Underwriter confirms that it has offered the Bonds to the public on or before the date of this Purchase Agreement at the offering price or prices (the “initial offering price”), or at the corresponding yield or yields, set forth in Exhibit A attached hereto. Exhibit A also sets forth, as of the date of this Purchase Agreement, the maturities, if any, of the Bonds for which the Underwriter represents that (i) the 10% test has been satisfied (assuming orders are confirmed by the close of the business day immediately following the date of this Purchase Agreement) and (ii) the 10% test has not been satisfied and for which the City and the Underwriter agree that the restrictions set forth in the next sentence shall apply, which will allow the City to treat the initial offering price to the public of each such maturity as of the sale date as the issue price of that maturity (the “hold-the-offering-price rule”). So long as the hold-the-offering-price rule remains applicable to any maturity of the Bonds, the Underwriter will neither offer nor sell unsold Bonds of that maturity to any person at a price that is higher than the initial offering price to the public during the period starting on the sale date and ending on the earlier of the following:
(1) the close of the fifth (5th) business day after the sale date; or (2) the date on which the Underwriter has sold at least 10% of that maturity of the Bonds to the public at a price that is no higher than the initial offering price to the public.
The Underwriter will advise the City promptly after the close of the fifth (5th) business day after the sale date whether it has sold 10% of that maturity of the Bonds to the public at a price that is no higher than the initial offering price to the public. (d) The Underwriter confirms that:
(i) any selling group agreement and any third-party distribution agreement relating to the initial sale of the Bonds to the public, together with the related pricing wires, contains or will contain language obligating each dealer who is a member of the selling group and each brokerdealer that is a party to such third-party distribution agreement, as applicable:
(A)(i) to report the prices at which it sells to the public the unsold Bonds of each maturity of a series allocated to it, whether or not the Closing Date has occurred, until either all Bonds of that maturity allocated to it have been sold or it is notified by the Underwriter that the 10% test has been satisfied as to the Bonds of that maturity, provided that, the reporting obligation after the Closing Date may be at reasonable periodic intervals or otherwise upon request of the Underwriter and (ii) to comply with the hold-the-offering-price rule, if applicable, if and for so long as directed by the Underwriter,
(B) to promptly notify the Underwriter of any sales of Bonds that, to its knowledge, are made to a purchaser who is a related party to an underwriter participating in the initial sale of the Bonds to the public (each such term being used as defined below), and
6 (C) to acknowledge that, unless otherwise advised by the dealer or brokerdealer, the Underwriter shall assume that each order submitted by the dealer or broker-dealer is a sale to the public.
(ii) any selling group agreement relating to the initial sale of the Bonds to the public, together with the related pricing wires, contains or will contain language obligating each dealer that is a party to a third-party distribution agreement to be employed in connection with the initial sale of the Bonds to the public to require each broker-dealer that is a party to such third-party distribution agreement to (A) report the prices at which it sells to the public the unsold Bonds of each maturity allocated to it, whether or not the Closing Date has occurred, until either all Bonds of that maturity of a series allocated to it have been sold or it is notified by the Underwriter or the dealer that the 10% test has been satisfied as to the Bonds of that maturity, provided that, the reporting obligation after the Closing Date may be at reasonable periodic intervals or otherwise upon request of the Underwriter or the dealer, and (B) comply with the hold-the-offering-price rule, if applicable, if and for so long as directed by the Underwriter or the dealer and as set forth in the related pricing wires.
(e) The City acknowledges that, in making the representation set forth in this section, the Underwriter will rely on (i) in the event a selling group has been created in connection with the initial sale of the Bonds to the public, the agreement of each dealer who is a member of the selling group to comply with the requirements for establishing issue price of the Bonds, including, but not limited to, its agreement to comply with the hold-the-offering-price rule, if applicable to the Bonds, as set forth in a selling group agreement and the related pricing wires, and (ii) in the event that a third-party distribution agreement was employed in connection with the initial sale of the Bonds to the public, the agreement of each broker-dealer that is a party to such agreement to comply with the requirements for establishing issue price of the Bonds, including, but not limited to, its agreement to comply with the hold-the-offering-price rule, if applicable to the Bonds, as set forth in the third-party distribution agreement and the related pricing wires. The City further acknowledges that the Underwriter shall not be liable for the failure of any dealer who is a member of a selling group, or of any broker-dealer that is a party to a third-party distribution agreement, to comply with its corresponding agreement to comply with the requirements for establishing the issue price of the Bonds, including, but not limited to, its agreement to comply with the hold-the-offering-price rule, if applicable to the Bonds. (f) The Underwriter acknowledges that sales of any Bonds to any person that is a related party to an underwriter participating in the initial sale of the Bonds to the public (each such term being used as defined below) shall not constitute sales to the public for purposes of this section. Further, for purposes of this section:
(1) “public” means any person other than an underwriter or a related party;
(2) “underwriter” means (A) any person that agrees pursuant to a written contract with the City (or with the lead underwriter to form an underwriting syndicate) to participate in the initial sale of the Bonds to the public and (B) any person that agrees pursuant to a written contract directly or indirectly with a person described in clause (A) to participate in the initial sale of the Bonds to the public (including a member
7 of a selling group or a party to a third-party distribution agreement participating in the initial sale of the Bonds to the public);
(3) a purchaser of any of the Bonds is a “related party” to an underwriter if the underwriter and the purchaser are subject, directly or indirectly, to (A) more than 50% common ownership of the voting power or the total value of their stock, if both entities are corporations (including direct ownership by one corporation of another), (B) more than 50% common ownership of their capital interests or profits interests, if both entities are partnerships (including direct ownership by one partnership of another), or (C) more than 50% common ownership of the value of the outstanding stock of the corporation or the capital interests or profit interests of the partnership, as applicable, if one entity is a corporation and the other entity is a partnership (including direct ownership of the applicable stock or interests by one entity of the other); and (4) “sale date” means the date of execution of this Purchase Agreement by all parties hereto.
6. The Underwriter represents to and agrees with the City that, as of the date hereof and as of the Closing Date:
(i) The Underwriter is duly authorized to execute this Purchase Agreement and to take any action under this Purchase Agreement required to be taken by it; (ii) The Underwriter is in compliance with MSRB Rule G-37 with respect to the City, and is not prohibited thereby from acting as the underwriter with respect to securities of the City; and
(iii) The Underwriter has, and has had, no financial advisory relationship, as that term is defined in California Government Code Section 53590 (c) or MSRB Rule G-23, with the City with respect to the Bonds, and no investment firm controlling, controlled by or under common control with the Underwriter has or has had any such financial advisory relationship.
7. The City represents, warrants and covenants to the Underwriter that:
(a) The City is a charter city and a municipal corporation duly organized and existing under its charter and the Constitution and the laws of the State of California, and has all necessary power and authority to enter into and perform its duties under the Indenture, the Continuing Disclosure Certificate, and this Purchase Agreement (collectively, the “City Documents”) and, when executed and delivered by the respective parties thereto, the City Documents will constitute the legal, valid and binding obligations of the City in accordance with their respective terms, except as the enforcement thereof may be limited by bankruptcy, insolvency or other laws affecting the enforcement of creditors’ rights generally and by the application of equitable principles if sought and by the limitations on legal remedies imposed on actions against public agencies in the State of California.
(b) Neither the execution and delivery of the City Documents, or the approval and execution of the Official Statement, and compliance with the provisions on the City’s part
8 contained therein, nor the consummation of any other of the transactions herein and therein contemplated, nor the fulfillment of the terms hereof and thereof, in any material way conflicts with or constitutes a breach of or default under nor contravenes any law, administrative regulation, judgment, decree, loan agreement, indenture, bond, note, resolution, agreement or other instrument to which the City is a party or is otherwise subject, nor does any such execution, delivery, adoption or compliance result in the creation or imposition of any security interest or encumbrance of any nature whatsoever upon any of the properties or assets of the City under the terms of any such law, administrative regulation, judgment, decree, loan agreement, indenture, bond, note, resolution, agreement or other instrument, except as provided by the City Documents. (c) Except as may be required under blue sky or other securities laws of any state, there is no consent, approval, authorization or other order of, or filing with, or certification by, any regulatory authority having jurisdiction over the City required for the execution and delivery of the Bonds or the consummation by the City of the other transactions contemplated by the Official Statement and this Purchase Agreement.
(d) To the best of the knowledge of the City, and except as disclosed in the Official Statement, there is, and on the Closing there will be, no action, suit, proceeding or investigation at law or in equity before or by any court or governmental agency or body pending or threatened against the City to restrain or enjoin the delivery of any of the Bonds, or the payments to be made pursuant to the Indenture, or in any way contesting or affecting the validity of the City Documents or the authority of the City to approve this Purchase Agreement, or enter into the City Documents, or in any way questioning or challenging the tax status of the Bonds. (e) As of its date and as of the date hereof, the information relating to the City, the Bonds and the Wastewater System contained in the Preliminary Official Statement is true and correct in all material respects and such information does not contain any untrue or misleading statement of a material fact or omit to state any material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading (except that no representation is made with respect to information relating to DTC, DTC’s book-entry system, information regarding the Insurer, the Policy and the Reserve Policy, or any information therein provided by or pertaining to the Underwriter). As of the date thereof and at all times subsequent thereto up to and including the End Date, such information relating to the City, the Bonds and the Wastewater System contained in the Official Statement will be complete and will not contain any untrue or misleading statement of a material fact or omit to state any material fact (unless an event occurs of the nature described in Section 7(j) below) necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading. (f) The City agrees to cooperate with the Underwriter in endeavoring to qualify the Bonds for offering and sale under the securities or blue sky laws of such jurisdictions of the United States as the Underwriter may request; provided, however, that the City will not be required to execute a special or general consent to service of process in any jurisdiction in which it is not now so subject or to qualify to do business in any jurisdiction where it is not so qualified. The Underwriter shall be responsible for all costs relating to such determination and qualification of the Bonds under blue sky or similar laws.
9 (g) By official action of the City prior to or concurrently with the execution hereof, the City has duly approved the distribution of the Official Statement, and has duly authorized and approved the execution and delivery of, and the performance by the City of the obligations on its part contained in the City Documents and the consummation by it of all other transactions contemplated by the Official Statement and this Purchase Agreement. (h) The City is not in breach of or default under any applicable law or administrative regulation of the State of California or the United States or any applicable judgment or decree or any loan agreement, indenture, bond, note, resolution, agreement or other instrument to which the City is a party or is otherwise subject, which breach or default would have a material adverse effect on the pledge of Net Revenues under the Indenture or the City’s performance under the City Documents, and no event has occurred and is continuing which, with the passage of time or the giving of notice, or both, would constitute such a default or event of default under any such instrument.
(i) To the best knowledge of the City, the City is not in default, nor has been in default in the last ten years, as to the payment of principal or interest with respect to an obligation issued by the City or successor of the City or with respect to an obligation guaranteed by the City as guarantor or successor of a guarantor.
(j) If between the date of this Purchase Agreement and the End Date an event occurs, of which the City has knowledge, which might or would cause the information relating to the City, the Wastewater System or the City’s functions, duties and responsibilities contained in the Official Statement, as then supplemented or amended, to contain an untrue statement of a material fact or to omit to state a material fact required to be stated therein or necessary to make such information therein, in the light of the circumstances under which it was presented, not misleading, the City will notify the Underwriter, and if, in the opinion of the Underwriter, such event requires the preparation and publication of a supplement or amendment to the Official Statement, the City will cooperate with the Underwriter in the preparation of an amendment or supplement to the Official Statement in accordance with the last paragraph of Section 3, provided all expenses thereby incurred will be paid for by the City. (k) If the information relating to the Wastewater System, the City, its functions, duties and responsibilities contained in the Official Statement is amended or supplemented pursuant to the immediately preceding subsection, at the time of each supplement or amendment thereto and (unless subsequently again supplemented or amended pursuant to such subsection) at all times subsequent thereto up to and including the date of the Closing, the portions of the Official Statement so supplemented or amended (including any financial and statistical data contained therein) will not contain any untrue statement of a material fact or omit to state a material fact required to be stated therein or necessary to make such information therein, in the light of the circumstances under which it was presented, not misleading. (l) No consent, approval, authorization or other action by a governmental or regulatory agency that has not been obtained is or will be required of the City for the delivery and sale of the Bonds or the consummation of the other transactions contemplated by this Purchase Agreement and the Official Statement, except for such licenses, certificates, approvals, variances or permits which may be necessary for the construction or operation of the Wastewater System
10 which the City has applied for (or will apply for in the ordinary course of business) and expects to receive, and except as may be required under the state securities or blue sky laws in connection with the sale of the Bonds by the Underwriter.
(m) Substantially all the proceeds from the sale of the Bonds (after deducting the expenses of issuance and sale of the Bonds) will be used to finance the costs of capital improvements to the Wastewater System, and the City will not take or omit to take any action which action or omission will in any way cause the proceeds from the sale of the Bonds to be applied in a manner contrary to that provided in the Indenture, as amended from time to time. (n) The City will deliver all opinions, certificates, letters and other instruments and documents reasonably required by the Underwriter and this Purchase Agreement. (o) Any certificate of the City delivered to the Underwriter shall be deemed a representation and warranty by the City to the Underwriter as to the statements made therein. (p) Other than as described in the Preliminary Official Statement and the Official Statement, as of the time of acceptance hereof and as of the Closing, the City does not and will not have outstanding any indebtedness which is secured by a lien on Net Revenues superior to or on a parity with the lien established by the Indenture. (q) Between the date of this Purchase Agreement and the Closing Date, the City will not, without the prior written consent of the Underwriter, and except as disclosed in the Official Statement, offer or issue any bonds, notes or other obligations for borrowed money, or incur any material liabilities, direct or contingent payable from Net Revenues. (r) The City is not presently and as a result of the execution of the City Documents and the sale of the Bonds will not be in violation of any debt limitation, appropriation limitation or any other provision of the California Constitution or statutes or any additional debt or similar provision of any bond, note, contract or other evidence of indebtedness to which the City is a party or to which the City is bound.
(s) The financial statements of, and other financial information regarding the City and the Wastewater System in the Official Statement fairly present the financial position and results of the operations of the City and the Wastewater System as of the dates and for the periods therein set forth and the audited financial statements have been prepared in accordance with Generally Accepted Accounting Principles.
(t) The City has not, in the last five years, failed to comply in any material respect in its obligations under any continuing disclosure undertaking entered into pursuant to Rule 15c2-12 except as disclosed in the Preliminary Official Statement and the Official Statement. The City will undertake, pursuant to the Continuing Disclosure Certificate to provide annual reports and notices of certain events in accordance with the requirements of Rule 15c2-12.
8. The Underwriter has entered into this Purchase Agreement in reliance upon the representations, warranties and agreements of the City contained herein, and the opinions of Bond Counsel, Counsel to the Trustee and the City Attorney required hereby. The Underwriter’s
11 obligations under this Purchase Agreement are and shall be subject to the following further conditions:
(a) At the time of Closing, the City Documents shall be in full force and effect as valid and binding agreements between or among the various parties thereto and the Official Statement shall not have been amended, modified or supplemented except in accordance with this Purchase Agreement, and there shall be in full force and effect such resolutions as, in the opinion of Bond Counsel, shall be necessary in connection with the transactions contemplated hereby. (b) At or prior to the Closing, the Underwriter shall receive the following documents, in each case satisfactory in form and substance to the Underwriter:
(1) The approving opinion of Bond Counsel, dated the Closing Date, addressed to the City, the Trustee and the Underwriter (or reliance letter to the Trustee and the Underwriter), in substantially the form attached as APPENDIX C to the Official Statement;
(2) A supplemental opinion of Bond Counsel dated the Closing Date, addressed to the Underwriter, in form and substance to the effect that:
(a) The statements contained in the Official Statement on the cover and under the captions “INTRODUCTION,” “THE 2026 BONDS,” “SECURITY AND SOURCES OF PAYMENT FOR THE 2026 BONDS,” “TAX MATTERS” and APPENDIX B and APPENDIX C, insofar as such statements purport to describe certain provisions of the Bonds, the Indenture, and the opinion of Bond Counsel regarding the exclusion of interest on the Bonds from gross income for federal income tax purposes and the exemption of such interest from State of California personal income taxes, present a fair and accurate summary of the provisions thereof;
(b) The Bonds are exempt from registration pursuant to the Securities Act of 1933, as amended, and the Indenture is exempt from qualification as an indenture pursuant to the Trust Indenture Act of 1939, as amended; and (c) The Purchase Agreement has been duly authorized, executed and delivered by the City, and, assuming due authorization, execution and delivery by the other party thereto, the Purchase Agreement constitutes the legal, valid and binding agreement of the City enforceable against the City in accordance with its terms, except as the enforcement thereof may be limited by bankruptcy, insolvency, reorganization, arrangement, fraudulent conveyance, moratorium or other laws affecting the enforcement of creditors’ rights to the application of equitable principles, to the possible unavailability of specific performance or injunctive relief, to the exercise of judicial discretion in appropriate cases and to the limitations on legal remedies against public agencies in the State of California, and except no opinion need be expressed as to the enforceability of any indemnification, contribution, penalty, choice of law, choice of forum or waiver (including, without limitation,
12 waiver of jury trial or consent to nonjury trial) provisions contained in the Purchase Agreement.
(3) The letter of Anzel Galvan LLP, San Francisco, California, Disclosure Counsel, dated the Closing Date and addressed to the City and the Underwriter, to the effect that, based upon their participation in conferences in the course of preparation of the Official Statement, and in reliance on such conferences and on the certificates, opinions and other documents as may be mentioned in such opinion, and without passing on and without assuming any responsibility for the accuracy, completeness and fairness of the statements in the Official Statement, and having made no independent investigation or verification thereof, no information has come to the attention of the attorneys in the firm representing the City as Disclosure Counsel which caused them to believe that (a) the Preliminary Official Statement as of its date or as of the date of the Purchase Agreement, contained any untrue statement of a material fact or omitted to state a material fact required to be stated therein or necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading (except that such letter need express no view with respect to: (i) the expressions of opinion, the assumptions, the projections, estimates and forecasts, the charts, the financial statements or other financial, numerical, economic, demographic or statistical data, assessed valuations, or environmental matters contained in the Preliminary Official Statement; (ii) any information relating to CUSIP numbers; (iii) any information with respect to The Depository Trust Company and its book-entry system; (iv) any information contained in the Appendices to the Preliminary Official Statement; (v) any information incorporated by reference into the Preliminary Official Statement; (vi) any information regarding the Insurer, the Policy and the Reserve Policy; and (vii) any information with respect to the Underwriter or underwriting matters with respect to the Bonds, including but not limited to information under the caption “UNDERWRITING”); provided, however, with respect to the foregoing conclusion, the letter may note that the Preliminary Official Statement contained certain information marked as preliminary, subject to change, and omitted certain information permitted to be omitted by Rule 15c2-12; and (b) the Official Statement as of its date contained, or as of the date of delivery of the Bonds contains, any untrue statement of a material fact, or as of its date omitted, or as of the date of delivery of the Bonds omits, to state a material fact required to be stated therein or necessary to make the statements therein, in light of the circumstances under which they were made, not misleading in any material respect (except that such letter need express no view with respect to: (i) the expressions of opinion, the assumptions, the projections, estimates and forecasts, the charts, the financial statements or other financial, numerical, economic, demographic or statistical data, assessed valuations, or environmental matters contained in the Official Statement; (ii) any information relating to CUSIP numbers; (iii) any information with respect to The Depository Trust Company and its book-entry system; (iv) any information contained in the Appendices to the Official Statement; (v) any information incorporated by reference into the Official Statement; (vi) any information regarding the Insurer, the Policy and the Reserve Policy; and (vii) any information
13 with respect to the Underwriter or underwriting matters with respect to the Bonds, including but not limited to information under the caption “UNDERWRITING”). (4) An opinion of the City Attorney to the City, dated the Closing Date, in form and substance satisfactory to the Underwriter and Bond Counsel, addressed to the Underwriter and the Trustee, to the effect that:
(i) the City is a charter city and a municipal corporation duly created and existing under its charter and the Constitution and in accordance with the laws of the State of California;
(ii) the preparation and distribution of the Official Statement and the City Documents have been duly approved by the City; (iii) the resolution of the City Council approving and authorizing the City’s execution and delivery of the Official Statement and the City Documents has been duly adopted at a meeting of the governing body of the City which was called and held pursuant to law and with all public notice required by law and at which a quorum was present and acting throughout; (iv) except as disclosed in the Preliminary Official Statement and the Official Statement, there is no action, suit, proceeding or investigation at law or in equity before or by any court, public board or body, pending or, to the best knowledge of such counsel, threatened against or affecting the City, which would adversely impact the City’s ability to complete the transactions described in and contemplated by the Official Statement, to restrain or enjoin the payments under, or in any way contesting or affecting the validity of the City Documents, or the transactions described and defined in the Official Statement wherein an unfavorable decision, ruling or finding would adversely affect the validity and enforceability of the City Documents;
(v) the execution and delivery of the City Documents and the approval of the Official Statement, and compliance with the provisions thereof and hereof, under the circumstances contemplated thereby, do not and will not in any material respect conflict with or constitute on the part of the City a breach of or default under any agreement or other instrument to which the City is a party or by which it is bound or any existing law, regulation, court order or consent decree to which the City is subject; (vi) the City Documents and the Official Statement have been duly authorized, executed and delivered by the City, and, assuming due authorization, execution and delivery by the other parties thereto, the City Documents constitute legal, valid and binding agreements of the City enforceable in accordance with their respective terms, except as the enforcement thereof may be limited by bankruptcy, insolvency or other laws affecting the enforcement of creditors’ rights generally and by the
14 application of equitable principles if sought and by the limitations on legal remedies imposed on actions against public agencies in the State of California;
(vii) no authorization, approval, consent, or other order of the State of California or any other governmental authority or agency within the State of California is required for the valid authorization, execution and delivery of the City Documents and the approval of the Official Statement, except such as have been obtained and except such as may be required under state securities or blue sky laws in connection with the purchase and distribution of the Bonds by the Underwriter;
(viii) the charges and fees of the Wastewater System were duly approved and adopted by the City and are valid and enforceable at the current levels levied by the City; and
(ix) nothing has come to the City Attorney’s attention which would lead such attorney to believe that the information relating to the City or the Wastewater System contained in the Official Statement contains an untrue statement or omits to state a material fact necessary to make the statements therein, in light of the circumstances under which they were made, not misleading.
(5) The opinion of counsel to the Trustee, dated the Closing Date in form and substance satisfactory to the Underwriter and Bond Counsel, and addressed to the City and the Underwriter.
(6) An opinion, dated the Closing Date and addressed to the Underwriter, of Kutak Rock LLP, counsel to the Underwriter (“Underwriter’s Counsel”), in such form as may be acceptable to the Underwriter. (7) A certificate or certificates, dated the Closing Date, signed by a duly authorized official of the City satisfactory in form and substance to the Underwriter and Bond Counsel, (a) confirming as of such date the representations and warranties of the City contained in this Purchase Agreement; (b) certifying that the City has complied with in all material respects all agreements, covenants and conditions to be complied with by the City at or prior to the Closing under the City Documents; (c) certifying that to the best of such official’s knowledge, no event affecting the City has occurred since the date of the Official Statement which either makes untrue or incorrect in any material respect as of the Closing the statements or information contained in the Official Statement or is not reflected in the Official Statement but should be reflected therein in order to make the statements and information therein not misleading in any material respect; (d) certifying that no consent is required to be obtained for the inclusion of the City’s audited financial statements, including the accompanying accountant’s letter, for Fiscal Year 2025 in the Official Statement.
15 (8) A certificate, dated the date of the Preliminary Official Statement, signed by a duly authorized official of the City deeming the Preliminary Official Statement “final” for purposes of Rule 15c2-12.
(9) An executed copy of the City Documents.
(10) An executed copy of the Official Statement.
(11) A certified copy of the general resolution of the Trustee authorizing the execution and delivery of certain documents by certain officers of the Trustee, which resolution authorizes the execution and delivery of documents such as the Bonds and the Indenture.
(12) Copies of the resolution adopted by the City Council and certified by the City Clerk, authorizing the execution and delivery of the City Documents and the Official Statement.
(13) Tax certifications by the City in form and substance acceptable to Bond Counsel.
(14) A certificate or certificates, dated the Closing Date, signed by a duly authorized official of the Trustee satisfactory in form and substance to the Underwriter, to the effect that:
(i) The Trustee is duly organized and existing as a national banking association under the laws of the United States of America, having the full corporate power and authority to enter into and perform its duties under the Indenture;
(ii) The Trustee is duly authorized to enter into the Indenture and has duly executed and delivered the Indenture, and assuming due authorization and execution by the other parties thereto, the Indenture is legal, valid and binding upon the Trustee, and enforceable against the Trustee in accordance with its terms;
(iii) The Trustee has duly authenticated the Bonds under the Indenture and delivered the Bonds to or upon the order of the Underwriter; and
(iv) No consent, approval, authorization or other action by any governmental or regulatory authority having jurisdiction over the banking or trust powers of the Trustee that has not been obtained is or will be required for the issuance of the Bonds or the consummation by the Trustee, of its obligations under the Indenture.
(15) Evidence that the Bonds have been rated as set forth in the Official Statement and that such rating(s) continue in effect as of the Closing.
16 (16) Evidence that a federal tax information form 8038-G has been prepared for filing with respect to the Bonds.
(17) A copy of the executed Blanket Letter of Representations by and between the City and The Depository Trust Company, relating to the book-entry system for the Bonds.
(18) A copy of the Notice of Final Sale required to be delivered to the California Debt and Investment Advisory Commission pursuant to Section 8855 of the California Government Code which may be delivered after the issuance of the Bonds.
(19) A parity debt certificate regarding the City’s compliance with the requirements in the SWRCB Agreements in connection with the issuance of the Bonds.
(20) Executed copies of the Policy and the Reserve Policy; (21) An opinion of counsel to the Insurer, in form and substance satisfactory to the City and Underwriter, that the Policy and the Reserve Policy have been duly authorized, executed and delivered by the Insurer and are legally valid and binding against the Insurer;
(22) One or more opinions or certificates of the Insurer as to the accuracy of the information in the Official Statement relating to the Insurer and the Policy; and
(23) Such additional legal opinions, certificates, proceedings, instruments and other documents as Bond Counsel, the Underwriter and Underwriter’s Counsel may reasonably request to evidence compliance with legal requirements, the truth and accuracy, as of the time of Closing, of the representations contained herein and in the Official Statement and the due performance or satisfaction by the Trustee and the City at or prior to such time of all agreements then to be performed and all conditions then to be satisfied. (c) All matters relating to this Purchase Agreement, the Bonds and the sale thereof, the City Documents and the consummation of the transactions contemplated by this Purchase Agreement shall have been approved by the Underwriter, such approval not to be unreasonably withheld.
If the conditions to the Underwriter’s obligations contained in this Purchase Agreement are not satisfied or if the Underwriter’s obligations shall be terminated for any reason permitted by this Purchase Agreement, this Purchase Agreement shall terminate and neither the Underwriter nor the City shall have any further obligation hereunder.
9. The Underwriter shall have the right to terminate this Purchase Agreement, without liability therefor, by written notification to the City if at any time at or prior to the Closing in the Underwriter’s reasonable judgment any of the following events shall occur:
17 (a) The market price or marketability of the Bonds, or the ability of the Underwriter to enforce contracts for the sale of the Bonds, shall be materially adversely affected by any of the following events:
(i) Legislation shall be enacted by or recommended to the Congress for passage by the President of the United States, or the Treasury Department of the United States or the Internal Revenue Service or favorably reported for passage to either House of the Congress by any committee of such House to which such legislation has been referred for consideration, a decision by a court of the United States or of the State or the United States Tax Court shall be rendered, or an order, ruling, regulation (final, temporary or proposed), press release, statement or other form of notice by or on behalf of the Treasury Department of the United States, the Internal Revenue Service or other governmental agency shall be made or proposed, the effect of any or all of which would be to alter, directly or indirectly, federal income taxation upon interest received on obligations of the general character of the Bonds, or the interest on the Bonds as described in the Official Statement, or other action or events shall have transpired which may have the purpose or effect, directly or indirectly, of changing the federal income tax consequences of any of the transactions contemplated herein; or
(ii) There shall have occurred (1) an outbreak or escalation of hostilities or the declaration by the United States of a national emergency or war or (2) any other calamity or crisis in the financial markets of the United States or elsewhere or the escalation of such calamity or crisis; or (iii) Legislation enacted (or resolution passed) by the Congress or an order, decree, or injunction issued by any court of competent jurisdiction, or an order, ruling, regulation (final, temporary, or proposed), press release or other form of notice issued or made by or on behalf of the Securities and Exchange Commission, or any other governmental agency having jurisdiction of the subject matter, to the effect that obligations of the general character of the Bonds are not exempt from registration under or other requirements of the Securities Act of 1933, as amended, or that the Indenture is not exempt from qualification under or other requirements of the Trust Indenture Act of 1939, as amended, or that the issuance, offering, or sale of obligations of the general character of the Bonds, as contemplated hereby or by the Official Statement or otherwise, is or would be in violation of the federal securities law as amended and then in effect; or (iv) A general suspension of trading in securities on the New York Stock Exchange or any other national securities exchange, the establishment of minimum or maximum prices on any such national securities exchange, the establishment of material restrictions (not in force as of the date hereof) upon trading securities generally by any governmental authority or any national securities exchange, or any material increase of
18 restrictions now in force (including, with respect to the extension of credit by, or the charge to the net capital requirements of, the Underwriter); or (v) Except as disclosed in or contemplated by the Official Statement, any material adverse change in the Wastewater System, the Net Revenues or the financial condition of the City that would materially adversely affect the Bonds shall have occurred; or
(vi) Any rating of the Bonds or other obligations of the City payable from Net Revenues of the Wastewater System by a national rating agency shall have been withdrawn or downgraded or placed on credit watch with negative implications; or
(b) A general banking moratorium shall have been established by federal, State of New York or California authorities; or
(c) Any amendment to the federal or California Constitution or action by any federal or California court, legislative body, regulatory body or other authority materially adversely affecting the tax status of the City, its property, income or securities (or interest thereon), or the ability of the City to execute the Indenture or the City to issue the Bonds and pledge the Net Revenues as contemplated by the Indenture and the Official Statement; or (d) Establishment of any new restrictions in securities materially affecting the free market for securities of the same nature as the Bonds (including the imposition of any limitations on interest rates) or the charge to the net capital requirements of the Underwriter established by the New York Stock Exchange, the Securities and Exchange Commission, any other Federal or state agency or the Congress of the United States, or by Executive Order; or (e) Any event occurring, or information becoming known which, in the reasonable judgment of the Underwriter, makes untrue in any material respect any statement or information contained in the Preliminary Official Statement or the Official Statement, or results in the Preliminary Official Statement or the Official Statement containing any untrue statement of a material fact or omitting to state a material fact required to be stated therein or necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading; or
(f) A material disruption in securities settlement, payment or clearance services affecting the Bonds shall have occurred; or
(g) An event described in Section 7(j) hereof shall have occurred which, in the reasonable professional judgment of the Underwriter, requires the preparation and publication of a supplement or amendment to the Official Statement and, the City refuses to permit the Official Statement to be supplemented to supply such statement or information, or the effect of the Official Statement as so supplemented is to materially adversely affect the market price or marketability of the Bonds or the ability of the Underwriter to enforce contracts for the sale of the Bonds; or (h) A decision by a court of the United States shall be rendered, or a stop order, release, regulation or no-action letter by or on behalf of the SEC or any other governmental agency
19 having jurisdiction of the subject matter shall have been issued or made, to the effect that the issuance, offering or sale of the Bonds, including the underlying obligations as contemplated by this Purchase Agreement or by the Official Statement, or any document relating to the issuance, offering or sale of the Bonds, is or would be in violation of any provision of the federal securities laws at the Closing Date, including the Securities Act of 1933, as amended, the Exchange Act of 1934, as amended and the Trust Indenture Act of 1939, as amended.
10. Performance by the City of its obligations under this Purchase Agreement is conditioned upon (i) performance by the Underwriter of its obligations hereunder, and (ii) receipt by the Underwriter of all opinions and certificates to be delivered at Closing by persons and entities other than the City.
11. (a) The Underwriter shall be under no obligation to pay, and the City shall pay or cause to be paid out of the proceeds of the Bonds or from other lawfully available funds of the City, all expenses incident to the performance of the City’s obligations hereunder, including but not limited to: the cost of photocopying and delivering the Bonds to the Underwriter; the cost of preparing, printing (and/or word processing and reproducing), distributing and delivering the City Documents and the cost of printing, distributing and delivering the Preliminary Official Statement and the Official Statement in such reasonable quantities as requested by the Underwriter; and the fees and disbursements of Bond Counsel, Disclosure Counsel, any accountants, financial advisors, engineers, experts or consultants the City has retained in connection with the Bonds and expenses (included in the expense component of the Underwriter’s spread) incurred on behalf of the City officers or employees which are incidental to implementing this Purchase Agreement, including, but not limited to, meals, transportation, and lodging of those officers or employees. (b) Whether or not the Bonds are delivered to the Underwriter as set forth herein, the City shall be under no obligation to pay, and the City shall not pay, any expenses incurred by the Underwriter in connection with its public offering and distribution of the Bonds (except those specifically enumerated in the preceding paragraph of this Section 11), including any advertising expenses and the fees of the California Debt and Investment Advisory Commission, CUSIP services bureau charges, regulatory fees imposed on the Underwriter for new security issues, the cost of preparation of any “blue sky” or legal investment memoranda and the fees and disbursements of Underwriter’s Counsel.
12. Any notice or other communication to be given to the Underwriter may be given by delivering the same to Samuel A. Ramirez & Co., Inc., 12130 Millennium Drive, Suite 300, Los Angeles, California 90094, Attention: Public Finance. Any notice or other communication to be given to the City may be given by delivering the same to City of Watsonville, 250 Main St., Watsonville, California 95076, Attention: City Manager. The approval of the Underwriter when required hereunder or the determination of satisfaction as to any document referred to herein shall be in writing signed by the Underwriter and delivered to you.
13. This Purchase Agreement is made solely for the benefit of the City and the Underwriter (including the successors or assigns thereof) and no other person shall acquire or have any right hereunder or by virtue hereof.
20 14. This Purchase Agreement may be executed by the parties hereto in separate counterparts, each of which such counterparts shall together constitute but one and the same instrument.
15. The representations and warranties of the City set forth in or made pursuant to this Purchase Agreement shall not be deemed to have been discharged, satisfied or otherwise rendered void by reason of the Closing or termination of this Purchase Agreement and regardless of any investigations made by or on behalf of the Underwriter (or statements as to the results of such investigations) concerning such representations and warranties of the City and regardless of delivery of and payment for the Bonds.
16. This Purchase Agreement shall become effective and binding upon the respective parties hereto upon the execution of the acceptance hereof by the City and the Underwriter and shall be valid and enforceable as of the time of such acceptance.
17. This Purchase Agreement shall be governed by the laws of the State of California.
This Purchase Agreement shall not be assigned by either party hereto.
18. This Purchase Agreement supersedes and replaces all prior negotiations, agreements and understandings between the parties hereto in relation to the sale of Bonds by the City and represents the entire agreement of the parties as to the subject matter herein.
19. Any provision of this Purchase Agreement which is prohibited or unenforceable in any jurisdiction shall, as to such jurisdiction, be ineffective to the extent of such prohibition or unenforceability without invalidating the remaining provisions of this Purchase Agreement or affecting the validity or enforceability of such provision in any other jurisdiction. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]
S-1
SAMUEL A. RAMIREZ & CO., INC.
By:
Title:
The foregoing is hereby agreed to and accepted as of the date first above written:
CITY OF WATSONVILLE
By: ________________________________
Authorized Officer
Time of Execution: _____________ California time
[SIGNATURE PAGE OF BOND PURCHASE AGREEMENT – CITY OF
WATSONVILLE WASTEWATER REVENUE BONDS, SERIES 2026]
Formatted: Spanish (Spain)
A-1
EXHIBIT A
$_________
CITY OF WATSONVILLE
WASTEWATER REVENUE BONDS, SERIES 2026
Maturity
(May 1)
Principal
Amount
Interest
Rate Yield Price
10% Test
Satisfied*
10% Test
Not
Satisfied
Subject to
Hold-TheOfferingPrice Rule
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
2041
2042
2043
2044
2045
2046
20__(T)
20__(T)
_________________
(T) Term Bond.
(C) Priced to optional call at [par] on May 1, 20__.
* At the time of execution of this Purchase Agreement and assuming orders are confirmed by the close of the business day immediately following the date of this Purchase Agreement.
B-1
EXHIBIT B
$_________
CITY OF WATSONVILLE
WASTEWATER REVENUE BONDS, SERIES 2026
FORM OF ISSUE PRICE CERTIFICATE
The undersigned, Samuel A. Ramirez & Co., Inc. (“Ramirez”), hereby certifies as set forth below with respect to the sale and issuance of the above-captioned obligations (the “Bonds”).
1. Sale of the General Rule Maturities. As of the date of this certificate, for each Maturity of the General Rule Maturities, the first price at which at least 10% of such Maturity was sold to the Public is the respective price listed in Schedule A.
2. Initial Offering Price of the Hold-the-Offering-Price Maturities. (a) Ramirez offered the Hold-the-Offering-Price Maturities to the Public for purchase at the respective initial offering prices listed in Schedule A (the “Initial Offering Prices”) on or before the Sale Date. A copy of the pricing wire or equivalent communication for the Bonds is attached to this certificate as Schedule B.
(b) As set forth in the Bond Purchase Agreement, dated [BPA Date], by and between Ramirez and the Issuer, Ramirez has agreed in writing that, (i) for each Maturity of the Hold-theOffering-Price Maturities, it would neither offer nor sell any of the Bonds of such Maturity to any person at a price that is higher than the Initial Offering Price for such Maturity during the Holding Period for such Maturity (the “hold-the-offering-price rule”), and (ii) any selling group agreement shall contain the agreement of each dealer who is a member of the selling group, and any retailthird-party distribution agreement shall contain the agreement of each broker-dealer who is a party to the retailthird-party distribution agreement, to comply with the hold-the-offering-price rule. Pursuant to such agreement, no Underwriter (as defined below) has offered or sold any Maturity of the Hold-the-Offering-Price Maturities at a price that is higher than the respective Initial Offering Price for that Maturity of the Bonds during the Holding Period.
3. Defined Terms.
(a) Issuer means the City of Watsonville.
(ab) General Rule Maturities means those Maturities of the Bonds listed in Schedule A hereto as the “General Rule Maturities.”
(bc) Hold-the-Offering-Price Maturities means those Maturities of the Bonds listed in Schedule A hereto as the “Hold-the-Offering-Price Maturities.” (cd) Holding Period means, with respect to a Hold-the-Offering-Price Maturity, the period starting on the Sale Date and ending on the earlier of (i) the close of the fifth business day after the Sale Date, or (ii) the date on which Ramirez has sold at least 10% of such Hold-thePage 466 of 716 B-2
Offering-Price Maturity to the Public at prices that are no higher than the Initial Offering Price for such Hold-the-Offering-Price Maturity.
(d) Issuer means the City of Watsonville.
(e) Maturity means Bonds with the same credit and payment terms. Bonds with different maturity dates, or Bonds with the same maturity date but different stated interest rates, are treated as separate maturities.
(f) Public means any person (including an individual, trust, estate, partnership, association, company, or corporation) other than an Underwriter or a related party to an Underwriter. The term “related party” for purposes of this certificate generally means any two or more persons who have greater than 50 percent common ownership, directly or indirectly. (g) Sale Date means the first day on which there is a binding contract in writing for the sale of a Maturity of the Bonds. The Sale Date of the Bonds is [BPA Date]. (h) Underwriter means (i) any person that agrees pursuant to a written contract with the Issuer (or with the lead underwriter to form an underwriting syndicate) to participate in the initial sale of the Bonds to the Public, and (ii) any person that agrees pursuant to a written contract directly or indirectly with a person described in clause (i) of this paragraph to participate in the initial sale of the Bonds to the Public (including a member of a selling group or a party to a retailthird-party distribution agreement participating in the initial sale of the Bonds to the Public).
The representations set forth in this certificate are limited to factual matters only. Nothing in this certificate represents the interpretation by Ramirez of any laws, including specifically Sections 103 and 148 of the Internal Revenue Code of 1986, as amended, and the Treasury Regulations thereunder. The undersigned understands that the foregoing information will be relied upon by the Issuer with respect to certain of the representations set forth in the attached Tax Certificate and with respect to compliance with the federal income tax rules affecting the Bonds, and by Bond Counsel, in connection with rendering its opinion that the interest on the Bonds is excluded from gross income for federal income tax purposes, the preparation of the Internal Revenue Service Form 8038-G, and other federal income tax advice that it may give to the Issuer from time to time relating to the Bonds. Except as expressly set forth above, the certifications set forth herein may not be relied upon or used by any third party or for any other purpose.
Dated: [Closing Date] SAMUEL A. RAMIREZ & CO., INC., as Underwriter
By:
Authorized Signatory
Schedule
SCHEDULE A
SALE PRICES OF THE GENERAL RULE MATURITIES AND INITIAL OFFERING
PRICES OF THE HOLD-THE-OFFERING-PRICE MATURITIES
[TO BE ATTACHED]
Schedule
SCHEDULE B
PRICING WIRE OR EQUIVALENT COMMUNICATION
City of
Watsonville
Wastewater
Revenue Bonds,
Series 2026
September 22, 2026
Financing Team
Urban Futures, Inc.
Municipal Advisor
Anzel Galvan LLP
Bond Counsel and Disclosure Counsel
Samuel A. Ramirez & Co., Inc
Underwriter
U.S. Bank
Trustee
Plan of Finance: Wastewater Revenue Bonds,
Series 2026
Purpose
• Generate $20 million in proceeds to finance a portion of the costs of the Energy Infrastructure Modernization Program at the City’s Wastewater Treatment Facility and pay Costs of Issuance Fixed Rate Amortization
• 2027-2046 (20 years)
Security
• Net Revenues (Revenues – O&M Costs) of the City’s Wastewater System and on parity with outstanding State Revolving Fund (SRF) Loans
Rate Covenant
• Wastewater rates fixed to be reasonably expected to yield Net Revenues equal to 1.20x Debt Service (including Rate Stabilization Fund transfers)
Additional Bonds Test
• 1.20x Debt Service, including proposed parity obligations and approved and in effect rate increases (excluding Rate Stabilization Fund transfers)
Project
Energy Infrastructure Modernization Program
• Total cost of $20.8 million ($20 million funded from bond proceeds and remainder funded from Wastewater System cash reserves)
• Replace aging cogeneration equipment and upgrade biogas conditioning, aeration and sludgedewatering systems and is expected to generate energy and O&M savings • Financing for the project and projected O&M savings incorporated into the City’s 5-year rate plan
Preliminary Financing Details*
Estimated par or principal amount of
$19.445 million
• Project fund deposit of $20 million
• Assumes bond insurance and debt service
reserve fund (DSRF) surety premiums in and
inclusive of all costs of issuance
Debt Structure
• Level annual debt service of approximately
$1.56 million with final maturity in 2046
• Payment dates of May and November, principal
paid in May
• Current market true interest cost of 4.41%
Not-to-Exceed Parameters in Resolution
• Not-to-exceed parameters of principal ($22.5
million), true interest cost (5.25%), and
Underwriter’s fee (0.75% of par) allow some
room should market conditions shift
Sources and Uses
2026 Bonds
Sources
Par Amount $19,445,000
Net Premium 1,132,321
Total $20,577,321
Uses
Project Fund $20,000,000
Costs of Issuance 577,321
Total $20,577,321
* Preliminary, subject to change Page 474 of 716
City
Council
Action
City Council consider adoption of Resolution to authorize and approve issuance of Wastewater Revenue Bonds,
Series 2026 (not to exceed $22.5 million), approve
financing team, and approve final form of financing
documents
Financing Documents
• Indenture of Trust
• Bond Purchase Agreement
• Preliminary Official
Statement
• Continuing Disclosure
Certificate
Financing
Schedule:
Next Steps
Sept 15 Rating Meeting
Sept 22 Rating Received
Sept 25* Preliminary Official Statement Posted
Oct 6* Bond Sale
Oct 22* Closing (Bond Proceeds Received)
* Preliminary, subject to change Page 476 of 716
1 CITY COUNCIL AGENDA REPORT
MEETING DATE: Tuesday, September 22, 2026
TO: CITY COUNCIL
WRITTEN BY: HOUSING MANAGER LANDAVERRY
RECOMMENDED BY: COMMUNITY DEVELOPMENT DIRECTOR ORBACH
APPROVED BY: TAMARA VIDES, CITY MANAGER
SUBJECT: 2026 AFFORDABLE HOUSING PROGRAM LIMITS
RECOMMENDATION:
Staff recommends the City Council of the City of Watsonville, and the City Council acting as the Successor Housing Agency, adopt a joint resolution establishing the 2026 Maximum Allowable Income Limits, Maximum Allowable Residential Rent Limits, and Maximum Allowable Home Sales Price Limits for the Watsonville Affordable Housing Program, including a 7.00 percent prevailing interest rate for purposes of calculating affordable ownership sales prices.
BACKGROUND:
The City of Watsonville has maintained an Affordable Housing Ordinance for the purpose of increasing the availability of housing that is affordable to Watsonville residents. The original ordinance, adopted in 1991, required developers of housing projects of more than eight units to make at least 25 percent of the units affordable to median-, low-, and very low-income households based on County median household income. Although the objective of increasing affordable housing was desirable, the ordinance was not producing the intended number of affordable units; by the end of 2000, only five affordable units had been supplied that met the intent of the ordinance.
In 1999, the Housing Safety Committee developed recommendations to improve housing conditions and increase housing affordability.
In early 2000, the City Council directed staff to establish a Housing Task Force representing a broad range of interests to evaluate potential improvements to the Affordable Housing Ordinance.
In 2001, following recommendations from the Housing Task Force and the Planning Commission, the City Council adopted a revised Affordable Housing Ordinance. The revised ordinance was intended to
2 better reflect the incomes of Watsonville residents and was codified as Chapter 14-46 of the Watsonville Municipal Code (WMC).
In August 2025, the City Council approved additional amendments to Chapter 14-46 to comply with current State law and to clarify and improve the consistency of various provisions.
The current Ordinance requires 15 to 20 percent of new residential development projects consisting of seven or more units to be affordable to households with very low, low, median, moderate, and above moderate incomes, as applicable, based on Watsonville household median income (WMC Sections 14-
46.030 and 14-46.040). The units regulated by the Ordinance are generally referred to as affordable, inclusionary, and/or deed-restricted units.
Chapter 14-46 establishes requirements for both rental and ownership units and provides formulas for determining maximum allowable income, rent, and sales price limits used in administering the City's Affordable Housing Program (WMC Sections 14-46.030, 14-46.130, 14-46.140, and 14-46.150). The City Council periodically adopts the applicable limits by resolution.
Under WMC Section 14-46.030, "Watsonville Median Household Income" is defined as 70 percent of Santa Cruz County median household income, adjusted for family size. The applicable income data are derived from the annual income limits published by the California Department of Housing and Community Development (HCD) pursuant to Section 6932 of Title 25 of the California Code of Regulations. Because the City's methodology applies a local adjustment to the County figures, the names of the City's income categories do not necessarily correspond directly to State or federal income category names.
The current affordable housing program limits were adopted in June 2024, which was the most recent update to the Santa Cruz County median household income by HCD. At that time, the City Council adopted a prevailing interest rate of 7.5 percent.
DISCUSSION:
HCD released the 2026 Official State Income Limits on June 29, 2026. The release of updated State income data, together with changes in housing-market and mortgage-rate conditions, provides the basis for updating the City's Affordable Housing Program limits. Adoption of updated limits is necessary to ensure that the City's income, rent, and ownership sales-price calculations continue to be administered using the most current information contemplated by Chapter 14-46.
The proposed 2026 schedule establishes the Maximum Allowable Income to Occupy Affordable Units, Maximum Allowable Residential Rent, and Maximum Allowable Home Sales Price for the City's Affordable Housing Program. The proposed schedule is included as Exhibit A to the accompanying resolution.
For affordable ownership units, WMC Section 14-46.150 establishes the methodology used to calculate the maximum allowable sales price. That methodology is outlined in Steps 1-4 below. The calculation is intended to establish a sales price that is affordable to a household within the applicable income
3 category while accounting for household size, the amount of income that may be devoted to housing costs, the prevailing mortgage interest rate, and the assumed loan-to-value ratio.
Step 1 – Determine the annual household income limit.
The applicable income category (Median, Moderate, or Above Moderate) and household size are identified. Household size is generally assigned as one person more than the number of bedrooms in the affordable unit. For example, a three-bedroom unit is assigned a four-person household size, while a studio is assigned a one-person household size. The applicable maximum annual income is then identified from the most recent City-adopted Affordable Housing Program limits.
Step 2 – Determine the monthly household allowance available for a mortgage payment.
Thirty percent (30%) of the annual household income limit is used to establish the annual household allowance. The amount is rounded up to the nearest $50 and divided by 12, with the resulting monthly amount rounded up to the nearest $50.
Step 3 – Determine the maximum mortgage amount.
The maximum mortgage is calculated using a 30-year, fully amortized, fixed-rate mortgage and the prevailing interest rate adopted for the Program.
Step 4 – Determine the maximum allowable sales price.
Assuming the mortgage represents 95 percent of the sale price, the maximum mortgage principal is divided by 0.95 and rounded to the nearest $50. The resulting amount is the maximum allowable sales price for the affordable unit.
The prevailing interest rate is particularly important because the mortgage payment is a key component of the sales-price calculation. As interest rates increase, the maximum sales price that an income-eligible household can support generally decreases. Conversely, lower interest rates generally allow for a higher maximum sales price at the same income level. This is illustrated in Table 1 below.
Table 1: Illustrative impact of interest rates on maximum sales prices for a three-bedroom unit Maximum Price
3-Bedroom Unit
6.75% Interest Rate 7.00% Interest Rate 7.25% Interest Rate Median $389,666 $379,883 $370,486
Moderate $467,600 $455,859 $444,583
Above Moderate $584,500 $569,824 $555,729
4 WMC Section 14-46.030 defines the "Prevailing Interest Rate" as the average 30-year fixed-rate mortgage available on a particular date from lenders located in Santa Cruz County that offer the loan product to Watsonville residents. The Ordinance provides that the prevailing interest rate is initially set by the Community Development Director based on the specified calculation and may be amended by the City Council from time to time.
Staff recommends a prevailing interest rate of 7.00 percent for the 2026 Program. In developing this recommendation, staff considered current 30-year fixed mortgage rates from local lenders, broader housing-finance market information, and the City's First Time Home Buyer Program Guidelines. The local lender rates reviewed for the first week of September 2026 ranged from 6.974 percent to 7.373 percent for 30-year fixed-rate mortgages, assuming a 5 percent down payment and a credit score between 700 and 719, as shown in Table 2 below.
Table 2: Interest rates as of September 4, 2026
LENDER APR
Chase Bank 6.974%
Bay Federal Credit Union 7.094 %
Bank of America 7.331 %
US Bank 7.373
For comparison, Freddie Mac reported a national average 30-year fixed mortgage rate of 6.71 percent as of September 3, 2026, and Bankrate listed the California average at 6.89 percent.
The recommended 7.00 percent rate is intended to provide a reasonable and administratively practical standard for the 2026 Program. It offers a consistent assumption for applying the City's sales-price formula and does not prevent the City Council from revisiting the rate if market conditions change materially.
Existing owners of affordable units are provided protections intended to allow a reasonable return on their investment when maximum resale prices fluctuate. Pursuant to WMC Section 14-46.150(h)(2), the maximum allowable resale price for an existing affordable unit is determined using the method that produces the higher price for the owner: (1) the maximum allowable sales-price formula; or (2) the original sales price plus 50 percent of the increase in the applicable House Price Index since the date of purchase.
The proposed 2026 limits will become effective upon adoption by the City Council and will remain in effect until superseded by subsequent limits adopted by the Council.
CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) DETERMINATION:
The preparation and adoption of the Affordable Housing Program Limits is not a project under the California Environmental Quality Act (CEQA), pursuant to CEQA Guidelines Section 15378(b)(2), because the action does not have the potential to result in either a direct physical change in the environment or
5 a reasonably foreseeable indirect physical change in the environment. Therefore, no further CEQA review is required.
STRATEGIC PLAN:
The proposed resolution is consistent with the City's Strategic Plan Housing goal by supporting sufficient, quality housing opportunities and expanding housing programs for City residents. Establishing current income, rent, and sales-price limits supports the continued administration of affordable and inclusionary housing units under Chapter 14-46.
FINANCIAL IMPACT:
The recommended action will not impact the General Fund. Preparation and administration of the Affordable Housing Program Limits are part of the Community Development Department's budgeted work program and will be completed using existing staff resources.
ALTERNATIVE ACTION:
The City Council may modify the proposed prevailing interest rate, modify other elements of the proposed 2026 limits, or decline to adopt the resolution. If the Council does not adopt new limits, the existing Affordable Housing Program limits will remain in effect.
ATTACHMENTS AND/OR REFERENCES (IF ANY):
None.
Reso No. ______ (CM)
Meeting Date: 092226 SWZ ______ TV ______ CDD ______
1 RESOLUTION NO.__________ (CM)
RESOLUTION NO.__________ (SHA)
A JOINT RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
WATSONVILLE, AND CITY COUNCIL ACTING AS THE SUCCESSOR
HOUSING AGENCY, ADOPTING THE WATSONVILLE AFFORDABLE
HOUSING PROGRAM 2026 INCOME, RENT, AND SALES PRICE LIMITS
FOR THE CITY'S AFFORDABLE HOUSING PROGRAM
WHEREAS, the City Council of the City of Watsonville adopted an Affordable Housing Ordinance in 1991 to increase the availability of housing affordable to Watsonville residents; and
WHEREAS, in 2001, the City Council adopted a revised Affordable Housing Ordinance, codified as Chapter 14-46 of the Watsonville Municipal Code (WMC), to better reflect the incomes of Watsonville residents and to further the goals, policies, and programs of the City's Housing Element; and
WHEREAS, on August 26, 2025, the City Council approved amendments to Chapter 14-46 to comply with current State law and to clarify and improve the consistency of provisions governing the City's Affordable Housing Program; and WHEREAS, Section 14-46.030 of the Watsonville Municipal Code defines "Watsonville Median Household Income" as seventy percent (70%) of Santa Cruz County's median household income, adjusted for family size and rounded up to the nearest fifty dollars ($50); and
WHEREAS, the State Department of Housing and Community Development (HCD) publishes annual county income data pursuant to Section 6932 of Title 25 of the California Code of Regulations, which is used in establishing the City's applicable income limits; and
WHEREAS, Sections 14-46.130, 14-46.140, and 14-46.150 of the Watsonville
Reso No. ______ (CM)
Meeting Date: 092226
2 Municipal Code provide for the periodic establishment of maximum income limits, maximum residential rent levels, and maximum affordable sales prices by resolution of the City Council; and
WHEREAS, HCD released the 2026 Official State Income Limits on June 29, 2026, and the updated income data and current housing-market conditions warrant adoption of updated 2026 Affordable Housing Program limits; and
WHEREAS, Chapter 14-46 of the Watsonville Municipal Code requires the City to establish a prevailing interest rate for purposes of calculating maximum affordable home sales prices, and staff recommends a prevailing interest rate of seven percent (7.00%) for the 2026 Program; and
WHEREAS, the City Council has reviewed the proposed 2026 income, rent, and sales-price limits and finds that adoption of the limits is consistent with the requirements and purposes of Chapter 14-46 of the Watsonville Municipal Code.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY
OF WATSONVILLE, CALIFORNIA, AND CITY COUNCIL ACTING AS THE SUCCESSOR HOUSING AGENCY, AS FOLLOWS:
1. That the City Council of the City of Watsonville, acting as the Successor Housing Agency, hereby adopts the schedule entitled "Watsonville Affordable Housing Program 2026 Income, Rent, and Sales Price Limits," attached hereto and incorporated herein as Exhibit A. The schedule establishes the 2026 Maximum Allowable Income to Occupy Affordable Units, Maximum Allowable Residential Rent, and Maximum Allowable Home Sales Price for the City's Affordable Housing Program.
Reso No. ______ (CM)
Meeting Date: 092226
3 2. That the 2026 schedule adopted by this resolution shall be used to determine applicable income limits, maximum residential rents, and maximum home sales prices for affordable units regulated by the City's Affordable Housing Program.
3. That for purposes of calculating maximum allowable affordable home sales prices under Section 14-46.150 of the Watsonville Municipal Code, the prevailing interest rate is hereby established at seven percent (7.00%) for a 30-year, fully amortized, fixedrate mortgage, until amended or superseded by action of the City Council.
4. That the 2026 Affordable Housing Program limits adopted by this resolution shall become effective upon adoption and shall remain in effect until superseded by subsequent limits adopted by the City Council.
********************************************
Reso No. ______ (CM)
Meeting Date: 092226
4 EXHIBIT A
Watsonville Affordable Housing Program 2026 Income, Rent, and Sales Price Limits
1 2 3 4 5 6 7 8
Very Low $53,800 $61,500 $69,200 $76,850 $83,000 $89,150 $95,300 $101,450 Low $67,250 $76,850 $86,450 $96,050 $103,750 $111,450 $119,150 $126,800 Median $80,700 $92,200 $103,750 $115,250 $124,500 $133,700 $142,950 $152,150 Moderate $100,900 $115,250 $129,700 $144,100 $155,650 $167,150 $178,700 $190,200 Above Moderate $114,300 $130,650 $147,000 $163,300 $176,400 $189,400 $202,500 $215,550 Studio 1 2 3 4
Very Low $840 $960 $1,081 $1,201 $1,297
Low $1,345 $1,537 $1,729 $1,921 $2,075
Median $1,681 $1,921 $2,161 $2,401 $2,594
Moderate $2,594
Studio 1 2 3 4
Median $265,946 $303,878 $341,950 $379,883 $410,340
Moderate $319,135 $364,654 $410,340 $455,859 $492,408
Above Moderate $398,918 $455,818 $512,925 $569,824 $615,509 Prevailing Interest Rate: 7.0 Per Cent
Income Levels % of AMI 1 2 3 4 5 6 7
Very Low 50% 76,150 87,000 97,900 108,750 117,450 126,150 134,850 Low 80% 122,200 139,650 157,100 174,550 188,500 202,500 216,450 Median 100% 96,050 109,750 123,500 137,200 148,200 159,150 170,150 Moderate 120% 115,250 131,700 148,200 164,650 177,800 191,000 204,150 Number of Bedrooms
Income Category
SANTA CRUZ COUNTY INCOME LIMITS FOR 2026
Number of Bedrooms
Income Category
Watsonville Affordable Housing Program
2026 Income, Rent and Sales Price Limits
Income Limits
Resale Price Limits (per Affordability Formula)
Number of Persons in Household
Income Category
Rent Limits
Exhibit A
1 CITY COUNCIL AGENDA REPORT
MEETING DATE: Tuesday, September 22, 2026
TO: CITY COUNCIL
RECOMMENDED BY: POLICE CHIEF SHAB
APPROVED BY: TAMARA VIDES, CITY MANAGER
SUBJECT: DISCUSSION REGARDING THE WATSONVILLE POLICE DEPARTMENT’S
USE OF FLOCK SAFETY CAMERAS
RECOMMENDATION:
Receive a report regarding the Watsonville Police Department’s current use of Flock Safety cameras and provide direction to staff.
BACKGROUND:
The Watsonville Police Department began using Flock Safety cameras in September 2023 with an initial deployment of twenty cameras. In September 2025, the City Council authorized a 24-month lease for a total of thirty-seven cameras. The system was acquired as an investigative resource to help officers and detectives identify vehicles associated with reported crimes, locate stolen vehicles, develop leads, and corroborate information gathered through other investigative methods.
Flock Safety cameras have also generated public discussion regarding privacy, data security, information sharing, retention, and the appropriate limits on law enforcement use. Staff is presenting this item so the City Council and community can receive an overview of the program, ask questions, provide input, and discuss whether any additional direction should be provided.
2 DISCUSSION:
Flock cameras capture limited vehicle information visible from public roadways, including a vehicle image, license plate, date, time, location, and certain vehicle characteristics. The system does not use facial recognition, identify a vehicle's occupants, continuously track a vehicle by GPS, or independently determine that a person has committed a crime.
The system is used to generate alerts when a vehicle is associated with a qualifying law enforcement warrant or detention and to conduct searches related to legitimate criminal investigations. A Flock result could be an investigative lead, but officers must verify the information and develop any additional legal basis required before taking enforcement action.
Since implementation, information from Flock Safety cameras has assisted Watsonville officers and detectives with investigations involving violent crime, sexual assault, fatal hit-and-run collisions, stolen vehicles, wanted persons, weapons offenses, and other reported crimes. The technology has helped identify potential suspect vehicles, recover stolen property, corroborate witness information, establish investigative timelines, and direct limited personnel toward productive leads.
The Department recognizes that the public-safety value of this technology must be balanced with meaningful safeguards. WPD Policy Section 470 governs access and use. Searches must be connected to a legitimate criminal justice purpose and supported by an articulable belief that the search will produce relevant information. Users must document the associated case and reason for the search. Each search is attributed to a named user and permanently logged for review.
Routine Flock data is temporarily retained for thirty days and then deleted unless information has been lawfully preserved as evidence in a specific case. Access is limited to authorized and trained personnel.
The Department conducts recurring audits and reviews to identify improper use or unusual activity.
Reviews conducted to date have not identified misuse by Watsonville personnel. Any misuse would be treated as a serious violation of Department policy and public trust and would be subject to investigation and discipline.
Department policy and California law restrict the sharing or use of Flock Safety camera information for federal immigration enforcement. WPD and Flock have also disabled federal and out-of-state sharing and restricts searches related to immigration enforcement and reproductive health care. These controls are intended to keep Watsonville data focused on lawful local and state criminal justice purposes.
The use of Flock Safety cameras is governed by California law and WPD Policy Section 470, which establishes requirements for authorized access, data security, training, information sharing, retention, and recurring audits. The policy also prohibits the sharing of data gathered by the City or its contractors for federal immigration enforcement, consistent with the California Values Act and other applicable state law.
CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) DETERMINATION:
3 Discussion of the Police Department's use of Flock Safety camera technology and direction to staff is not a project under the California Environmental Quality Act (CEQA) because it is an administrative and policy discussion that will not result in a direct or reasonably foreseeable indirect physical change in the environment. If Council provides direction that results in a future discretionary action, any required CEQA review can be addressed when that action returns for consideration. (CEQA Guidelines, §§15060, subds. (c)(2), (c)(3), 15061, subd. (b)(3).
STRATEGIC PLAN:
Public Safety
FINANCIAL IMPACT:
Approximately $118,300 remains under the existing agreement with Flock, which runs through September 2027.
ALTERNATIVE ACTION:
1. Maintain current lease agreement with Flock with no changes.
2. Revise Department policies regarding use of Flock Safety cameras.
3. Direct staff to serve notice that City will not renew the contract with Flock in September 2027.
4. Direct staff to initiate negotiations with Flock Group, Inc. regarding modifications to Flock contract terms.
5. Direct staff to serve the required 30-day notice to cancel the contract with Flock.
ATTACHMENTS AND/OR REFERENCES (IF ANY):
1. Current Flock Safety agreement
Flock Safety + CA - Watsonville PD
______________
Flock Group Inc.
1170 Howell Mill Rd, Suite 210
Atlanta, GA 30318
______________
MAIN CONTACT:
Caroline Fraher
[email protected]
310-844-3659
Docusign Envelope ID: 04491325-3F4E-4A26-90AD-BF3915448C0D Attachment 1
EXHIBIT A
ORDER FORM
Customer: CA - Watsonville PD Initial Term: 24 Months
Legal Entity Name: CA - Watsonville PD Renewal Term: 24 Months Accounts Payable Email: [email protected] Payment Terms: Net 30 Address: 215 Union St Watsonville, California 95076 Billing Frequency: Annual Retention Period: 30 Days
Hardware and Software Products
Annual recurring amounts over subscription term
Item Cost Quantity Total
Flock Safety Platform $118,300.00
Flock Safety Platform
Flock Safety Platform - Essentials Included 1 Included
Flock Safety Bundles
Dual Solar LPR - Standard Bundle, fka Falcon Included 1 Included Flock Safety LPR Products
Flock Safety LPR, fka Falcon Included 19 Included
Flock Safety LPR, fka Falcon Included 18 Included
Flock Safety FlockOS Add Ons
Flock Safety Advanced Search Included 1 Included
Professional Services and One Time Purchases
Item Cost Quantity Total
One Time Fees
Flock Safety Professional Services
Professional Services - Standard Implementation Fee $650.00 5 $3,250.00 Professional Services - Advanced Implementation
Fee $1,092.85 7 $7,649.95
Professional Services - Existing Infrastructure
Implementation Fee $150.00 6 $900.00
Professional Services - Solar Bundle Implementation
Fee $900.00 1 $900.00
Subtotal Year 1: $130,999.95
Annual Recurring Subtotal: $118,300.00
Discounts: $10,650.05
Estimated Tax: $0.00
Docusign Envelope ID: 04491325-3F4E-4A26-90AD-BF3915448C0D Attachment 1
Contract Total: $249,299.95
Taxes shown above are provided as an estimate. Actual taxes are the responsibility of the Customer. This Agreement will automatically renew for successive renewal terms of the greater of one year or the length set forth on the Order Form (each, a “Renewal Term”) unless either Party gives the other Party notice of non-renewal at least thirty (30) days prior to the end of the then-current term.
The Term for Flock Hardware shall commence upon first installation and validation, except that the Term for any Flock Hardware that requires selfinstallation shall commence upon execution of the Agreement. In the event a Customer purchases more than one type of Flock Hardware, the earliest Term start date shall control. In the event a Customer purchases software only, the Term shall commence upon execution of the Agreement.
Billing Schedule
Billing Schedule Amount (USD)
Year 1
At Contract Signing $130,999.95
Annual Recurring after Year 1 $118,300.00
Contract Total $249,299.95
*Tax not included
Discounts
Discounts Applied Amount (USD)
Flock Safety Platform $0.00
Flock Safety Add-ons $5,000.00
Flock Safety Professional Services $5,650.05
Docusign Envelope ID: 04491325-3F4E-4A26-90AD-BF3915448C0D Attachment 1
Product and Services Description
Flock Safety Platform Items Product Description
Flock Safety LPR, fka Falcon
Law enforcement grade infrastructure-free (solar power + LTE) license plate recognition camera with Vehicle Fingerprint ™ technology (proprietary machine learning software) and real-time alerts for unlimited users.
Flock Safety Advanced Search
Advanced Search is an optional upgrade for Law Enforcement Grade Falcon cameras. Advanced Search includes Convoy Analysis, Multi Geo Search, and Visual Search.
Flock Safety Platform - Essentials
An integrated public safety platform that detects, centralizes and decodes actionable evidence to increase safety, improve efficiency, and connect the community.
Flock Safety LPR, fka Falcon
Law enforcement grade infrastructure-free (solar power + LTE) license plate recognition camera with Vehicle Fingerprint ™ technology (proprietary machine learning software) and real-time alerts for unlimited users.
Dual Solar LPR - Standard Bundle,
fka Falcon Two solar-powered fixed standard-range LPR cameras on the same pole Professional Services - Standard
Implementation Fee
One-time Professional Services engagement. Includes site and safety assessment, camera setup and testing, and shipping and handling in accordance with the Flock Safety Standard Implementation Service Brief.
Professional Services - Advanced
Implementation Fee
One-time Professional Services engagement. Includes site & safety assessment, camera setup & testing, and shipping & handling in accordance with the Flock Safety Advanced Implementation Service Brief.
Professional Services - Existing
Infrastructure Implementation Fee
One-time Professional Services engagement. Includes site and safety assessment of existing vertical infrastructure location, camera setup and testing, and shipping and handling in accordance with the Flock Safety Standard Implementation Service Brief.
Solar LPR, fka Solar Falcon
Standard range license plate recognition camera with Vehicle Fingerprint ™ technology (proprietary machine learning software) and real-time alerts for unlimited users, with LTE
Professional Services - Solar
Bundle Implementation Fee
One-time Professional Services engagement. Includes site and safety assessment, camera setup and testing, and shipping and handling in accordance with the Flock Safety Standard Implementation Service Brief.
FlockOS Features & Description
FlockOS Features Description
Community Network Access
The ability to request direct access to feeds from privately owned Flock Safety LPR cameras located in neighborhoods, schools, and businesses in your community, significantly increasing actionable evidence that clears cases.
Unlimited Users Unlimited users for FlockOS
State Network (License Plate Lookup Only) Allows agencies to look up license plates on all cameras opted into the Flock Safety network within your state.
Nationwide Network (License Plate Lookup Only)
With the vast Flock Safety sharing network, law enforcement agencies no longer have to rely on just their devices alone. Agencies can leverage a nationwide system boasting 10 billion additional plate reads per month to amplify the potential to collect vital evidence in otherwise dead-end investigations.
Law Enforcement Network Access The ability to request direct access to evidence detection devices from Law Enforcement agencies outside of your jurisdiction.
Time & Location Based Search Search full, partial, and temporary plates by time at particular device locations License Plate Lookup Look up specific license plate location history captured on Flock devices Vehicle Fingerprint Search Search footage using Vehicle Fingerprint™ technology. Access vehicle type, make, color, license plate state, missing / covered plates, and other unique features like bumper stickers, decals, and roof racks.
Insights & Analytics Reporting tool to help administrators manage their LPR program with device performance data, user and network audits, plate read reports, hot list alert reports, event logs, and outcome reports.
Real-Time NCIC Alerts on Flock ALPR Cameras
Receive automated alerts when vehicles entered into established databases for missing and wanted persons are detected, including the FBI's National Crime Information Center (NCIC) and National Center for Missing & Exploited Children (NCMEC) databases.
Unlimited Custom Hot Lists Ability to add a suspect's license plate to a custom list and get alerted when it passes by a Flock camera
Docusign Envelope ID: 04491325-3F4E-4A26-90AD-BF3915448C0D Attachment 1
By executing this Order Form, Customer represents and warrants that it has read and agrees to all of the terms and conditions contained in the previously executed agreement.
The Parties have executed this Agreement as of the dates set forth below.
FLOCK GROUP, INC. Customer: CA - Watsonville PD
By:
\FSSignature2\
By:
\FSSignature1\
Name:
\FSFullname2\
Name:
\FSFullname1\
Title:
\FSTitle2\
Title:
\FSTitle1\
Date:
\FSDateSigned2\
Date:
\FSDateSigned1\
PO Number:
Docusign Envelope ID: 04491325-3F4E-4A26-90AD-BF3915448C0D City Manager
9/20/2025
Tamara Vides
9/22/2025
Dan Haley
Chief Legal Officer
Attachment 1
From: City Council
To: Eduardo Montesino; Vanessa Quiroz; Maria Orozco; Kristal Salcido; Casey Clark; Jimmy Dutra; Ari Parker; cityclerk
Subject: FW: Flock Camera
Date: Sunday, September 20, 2026 8:10:23 AM
________________________________________
From: Mary Reynolds <[email protected]>
Sent: Sunday, September 20, 2026 8:09:58 AM (UTC-08:00) Pacific Time (US & Canada) To: City Council
Subject: Flock Camera
[You don't often get email from [email protected]. Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ]
I 100% want to keep the flock cameras.
Mary Reynolds
37 Melwood St.
Watsonville, CA 95076
From: City Council
To: Eduardo Montesino; Vanessa Quiroz; Maria Orozco; Kristal Salcido; Casey Clark; Jimmy Dutra; Ari Parker; cityclerk
Subject: FW: Get rid of Flock cameras
Date: Monday, September 21, 2026 10:31:18 AM
From: Anita Salem <[email protected]>
Sent: Monday, September 21, 2026 10:30:53 AM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Get rid of Flock cameras
You don't often get email from [email protected]. Learn why this is important I’m asking you to respect our privacy. I frequently drive in Watsonville and do not want to be spied on by my government. Please
-Cancel the City of Watsonville’s Flock contract;
-Remove the Flock license plate reader cameras; and
-Hold public hearings on the privacy, data security, civil rights, and public safety impacts of Flock technology.
Anita
831.277.6616
From: City Council
To: Eduardo Montesino; Vanessa Quiroz; Maria Orozco; Kristal Salcido; Casey Clark; Jimmy Dutra; Ari Parker; cityclerk
Subject: FW: Public Comment
Date: Sunday, September 20, 2026 8:31:13 AM
________________________________________
From: Mary Reynolds <[email protected]>
Sent: Sunday, September 20, 2026 8:30:47 AM (UTC-08:00) Pacific Time (US & Canada) To: City Council
Subject: Public Comment
[You don't often get email from [email protected]. Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ]
I support Flock cameras.
Mary Reynolds
Sent from my iPhone
From: City Council
To: Eduardo Montesino; Vanessa Quiroz; Maria Orozco; Kristal Salcido; Casey Clark; Jimmy Dutra; Ari Parker; cityclerk
Subject: FW: Public Comment - Agenda Item 12c
Date: Sunday, September 20, 2026 10:57:27 AM
From: pamela sexton <[email protected]>
Sent: Sunday, September 20, 2026 10:56:58 AM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Public Comment - Agenda Item 12c
Dear Watsonville Councilmembers,
I am writing to you as a longtime Watsonville community member; as an ESL and citizenship teacher at the Watsonville Adult School; as a homeowner in downtown Watsonville and a local taxpayer. I am writing to express my strong opposition to the use of automated license plate reader (ALPR) systems, and specifically cameras manufactured by Flock Safety. I call on you cancel current Flock contracts and to remove all of the Flock license plate reader cameras.
Public safety is a shared concern, but continuous and indiscriminate mass surveillance is not the answer and does not move us toward the strategic plan goal of “safe and resilient communities”. In fact, it does the opposite. Automated mass surveillance systems are prone to misreads and algorithmic errors that can lead to high-risk stops of innocent community members. There are numerous examples of this where people have had to experience physical harm and trauma due to a mistake in the machine.
Flock cameras track and log the movements of every passing vehicle—not just those suspected of a crime—building searchable digital footprints of ordinary people - me, my family, my students, my neighbors. This technology records where we drive, when we travel, and which doctors, places of worship, or political protests we visit. I do not consent to this!
While the Flock company gives assurances of increased local control, there is too much evidence that their word cannot be trusted. Data gathered by these networks can be accessed or pooled by outside entities, including federal agencies or out-ofstate law enforcement, exposing Watsonville residents to unintended data sharing. Routine tracking of individuals undermines our constitutional right to privacy! Public money should be invested in proven resources that truly support community safety - not in expensive, dystopian, and error-prone surveillance tech.
Across the country, a growing number of cities and towns have listened to their residents, recognized these severe privacy risks, and deactivated or canceled their contracts with Flock.
I urge you to stand on the side of civil liberties and community trust. Please make
Watsonville a place where privacy and constitutional rights are respected.
Sincerely,
Pamela Sexton
831-254-0451
--
When we dream alone, it is only a dream, but when we dream together, it is the beginning of reality.
From: Sharon Spence
To: cityclerk
Subject: Public Comment for September 22, 2026 City Council Meeting – Support for Flock Safety Cameras Date: Sunday, September 20, 2026 11:27:04 AM
Attachments: Professional_Signature.png
You don't often get email from [email protected]. Learn why this is important Subject: Public Comment for September 22, 2026 City Council Meeting – Support for Flock Safety Cameras
Date: September 20, 2026
To: Watsonville City Clerk and Members of the Watsonville City Council From: Sharon Spence, Watsonville Resident
Delivery Via: [email protected]
Dear Honorable Mayor and Members of the Watsonville City Council, I am writing to express my strong support for the deployment of Flock Safety camera systems in our community to enhance public safety and support our local law enforcement infrastructure.
Modern public safety increasingly relies on advanced technology. Globally, ClosedCircuit Television (CCTV) networks are standard civic infrastructure used by nearly every sovereign nation. The Flock Safety system builds upon this foundation by providing automated license plate recognition (ALPR) and gunfire location technology. Rather than acting as a tool for invasive personal tracking, these networks function as critical situational awareness systems. They gather, process, and present real-time data that allows law enforcement, public transit authorities, and educational institutions to understand escalating emergencies, project outcomes, and make fast, informed decisions during active crises.
Living in an area prone to severe environmental threats, this technology is also vital for Watsonville's disaster resilience. In the wake of major earthquakes, excessive rainfall, or catastrophic flooding—like the Pajaro River levee breaches—first responders need immediate clarity. Flock systems can act as structural eyes on the ground, allowing emergency managers to quickly assess road blockages, identify severed evacuation routes, and coordinate rescue efforts when municipal infrastructure is compromised."
It is important to recognize that public surveillance infrastructure is already a routine part of modern life. Our communities are already surrounded by essential monitoring grids managed by departments of transportation, airport authorities, school districts, and commercial real estate entities. Furthermore, the digital surveillance systems and data profiling operated daily by major internet and social media corporations are vastly more invasive than any localized physical safety network.
We must also confront the current operational realities facing law enforcement.
Nationwide, sworn police personnel numbers dropped by 3% to 5.5% following years of intense public scrutiny, acute burnout, and high retirement rates. While communities frequently demand immediate police response times and increased
safety measures, there is often a conflicting reluctance to increase municipal funding to expand the workforce. In an era where physical law enforcement resources are stretched thin, advanced technology must bridge the gap.
Summary:
Using Flock cameras is a balanced, necessary step to protect Watsonville. By serving as an objective digital witness and a powerful crime deterrent, this technology provides our understaffed law enforcement officers with the real-time data they need to prevent crime and respond effectively to emergencies. I urge the City Council to support this vital investment in our community's safety.
Sincerely,
Sharon L. Spence
720 Oregon Street,
Watsonville, CA 95076
From: Sharon Spence
To: cityclerk
Subject: Public Comment for September 22, 2026 City Council Meeting – Support for Flock Safety Cameras Date: Sunday, September 20, 2026 11:57:10 AM
Attachments: Professional_Signature.png
You don't often get email from [email protected]. Learn why this is important Subject: Public Comment for September 22, 2026 City Council Meeting – Support for Flock Safety Cameras
Date: September 20, 2026
To: Watsonville City Clerk and Members of the Watsonville City Council From: Sharon Spence, Watsonville Resident
Delivery Via: [email protected]
Dear Honorable Mayor and Members of the Watsonville City Council, I am writing to express my strong support for the deployment of Flock Safety camera systems in our community to enhance public safety and support our local law enforcement infrastructure.
Modern public safety increasingly relies on advanced technology. Globally, ClosedCircuit Television (CCTV) networks are standard civic infrastructure used by nearly every sovereign nation. The Flock Safety system builds upon this foundation by providing automated license plate recognition (ALPR) and gunfire location technology. Rather than acting as a tool for invasive personal tracking, these networks function as critical situational awareness systems. They gather, process, and present real-time data that allows law enforcement, public transit authorities, and educational institutions to understand escalating emergencies, project outcomes, and make fast, informed decisions during active crises.
It is important to recognize that public surveillance infrastructure is already a routine part of modern life. Our communities are already surrounded by essential monitoring grids managed by departments of transportation, airport authorities, school districts, and commercial real estate entities. Furthermore, the digital surveillance systems and data profiling operated daily by major internet and social media corporations are vastly more invasive than any localized physical safety network.
We must also confront the current operational realities facing law enforcement.
Nationwide, sworn police personnel numbers dropped by 3% to 5.5% following years of intense public scrutiny, acute burnout, and high retirement rates. While communities frequently demand immediate police response times and increased safety measures, there is often a conflicting reluctance to increase municipal funding to expand the workforce. In an era where physical law enforcement resources are stretched thin, advanced technology must bridge the gap.
Summary:
Using Flock cameras is a balanced, necessary step to protect Watsonville. By serving as an objective digital witness and a powerful crime deterrent, this technology provides our understaffed law enforcement officers with the real-time data they need to prevent crime and respond effectively to emergencies. I urge the City Council to support this vital investment in our community's safety.
Sincerely,
Sharon L Spence
720 Oregon Street
Watsonville, CA 95076
From: City Council
To: Eduardo Montesino; Vanessa Quiroz; Maria Orozco; Kristal Salcido; Casey Clark; Jimmy Dutra; Ari Parker; cityclerk
Subject: FW: Flock
Date: Sunday, September 20, 2026 9:08:39 PM
From: Thomas Riordan <[email protected]>
Sent: Sunday, September 20, 2026 9:07:48 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Flock
You don't often get email from [email protected]. Learn why this is important I would like to ask that youCancel the City of Watsonville’s Flock contract; -Remove the Flock license plate reader cameras; and
-Hold public hearings on the privacy, data security, civil rights, and public safety impacts of Flock technology.
Thomas P Riordan
800 Brommer Street
Santa Cruz 95062
Thomas
/thank you
From: City Council
To: Eduardo Montesino; Vanessa Quiroz; Maria Orozco; Kristal Salcido; Casey Clark; Jimmy Dutra; Ari Parker; cityclerk
Subject: FW: Public Comment Item 12c
Date: Monday, September 21, 2026 8:07:03 AM
From: Cori Wolfland <[email protected]>
Sent: Monday, September 21, 2026 8:06:22 AM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Public Comment Item 12c
You don't often get email from [email protected]. Learn why this is important Hi all Councilmembers,
First, thank you for your service.
I am writing about the issue of Flock Cameras. I respectfully yet urgently ask that you cancel the City of Watsonville's Flock contract and remove all Flock cameras (license plate readers).
It is known that police departments and the Flock company share camera data with Federal agencies, including ICE. As ICE continues to terrorize our nation, most of all our vulnerable neighbors who have immigrated here, it is imperative that we remove license plate readers that facilitate ICE locating people. You have seen the videos and photos of people being violated, even killed, under ICE force. We cannot abide this regime - keeping Flock cameras in place is supporting that terror campaign.
Do not make us complicit.
Please, exercise your power by removing these cameras and canceling the contract.
While police and city officials may wish to keep cameras for crime investigations, much of that crime is property crime. That means that using this purpose as a reason to keep Flock is a trade-off decision. What you get: improved ability to resolve property crime – improved is a key word because they can do it without Flock as they have for decades. What you lose:
privacy and protections for MANY more people - everyone driving loses privacy. Are you comfortable with that trade-off? I am not.
Thank you,
Cori Walloon Wolfland
Concerned citizen of Santa Cruz
--
Cori Wolfland (they/them)
[email protected]
734-395-2693
From: City Council
To: Eduardo Montesino; Vanessa Quiroz; Maria Orozco; Kristal Salcido; Casey Clark; Jimmy Dutra; Ari Parker; cityclerk
Subject: FW: Flock
Date: Monday, September 21, 2026 8:25:06 AM
________________________________________
From: Bill Patterson <[email protected]>
Sent: Monday, September 21, 2026 8:24:21 AM (UTC-08:00) Pacific Time (US & Canada) To: City Council
Subject: Flock
[You don't often get email from [email protected]. Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ]
We citizens of Santa Cruz County petition our leaders to protect our privacy.
Many commercial and political entities threaten to utilize Flock Tech to reduce our freedoms.
Bill Patterson
From: City Council
To: Eduardo Montesino; Vanessa Quiroz; Maria Orozco; Kristal Salcido; Casey Clark; Jimmy Dutra; Ari Parker; cityclerk
Subject: FW: Cancel Flock Cameras
Date: Monday, September 21, 2026 10:07:48 AM
From: Lynne DeSpelder <[email protected]>
Sent: Monday, September 21, 2026 10:07:24 AM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Cancel Flock Cameras
You don't often get email from [email protected]. Learn why this is important This is an email message urging you to cancel the Flock camera project and get rid of those already installed. Our community does not need or want them. Misuse is not worth the negative outcome in the City. Thank you for your vote to dismantle them.
From: City Council
To: Eduardo Montesino; Vanessa Quiroz; Maria Orozco; Kristal Salcido; Casey Clark; Jimmy Dutra; Ari Parker; cityclerk
Subject: FW: Public Comment Item 12c
Date: Monday, September 21, 2026 10:11:47 AM
From: Yesenia Molina <[email protected]>
Sent: Monday, September 21, 2026 10:11:25 AM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Public Comment Item 12c
You don't often get email from [email protected]. Learn why this is important Hello,
Mya name is Yesenia Molina and as a resident, I strongly oppose the implementation of Flock safety cameras in our community. These systems subject every driver and bystander to continuous, warrantless mass surveillance under the guise of public safety. Collecting, storing, and tracking the movements of innocent people creates an invasive dragnet that erodes basic civil liberties.
Furthermore, I condemn the sharing and integration of this real-time location data with federal agencies like ICE. Automated license plate readers actively harm vulnerable immigrant communities, undermine local trust in public services, and expose residents to federal overreach. Our local resources and technology should protect civil rights, not construct a borderless surveillance network. I urge the council to reject the use of Flock cameras. --
iMiX~ Find the spark in life...
From: City Council
To: Eduardo Montesino; Vanessa Quiroz; Maria Orozco; Kristal Salcido; Casey Clark; Jimmy Dutra; Ari Parker; cityclerk
Subject: FW: Public Comment
Date: Monday, September 21, 2026 11:06:45 AM
________________________________________
From: Gigi <[email protected]>
Sent: Monday, September 21, 2026 11:06:01 AM (UTC-08:00) Pacific Time (US & Canada) To: City Council
Subject: Public Comment
[You don't often get email from [email protected]. Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ]
Hello to all city members,
This message is to express how myself and most of my community, colleagues and family think about the flock cameras. We DONT want them in our city, it’s ridiculous how just the target shopping center has about 12 cameras, through out the city there are cameras at every corner. We DONT FEEL SAFE with them. Our freedom has been stripped away we can’t go anywhere without being recorded. My stand and our community stand is OUT with the flock Cameras. We/ I dont consent to them.
Thank you for your time,
Watsonville resident
From: City Council
To: Eduardo Montesino; Vanessa Quiroz; Maria Orozco; Kristal Salcido; Casey Clark; Jimmy Dutra; Ari Parker; cityclerk
Subject: FW: Public Comment Item 12c
Date: Monday, September 21, 2026 1:48:25 PM
From: Laurel Woerner <[email protected]>
Sent: Monday, September 21, 2026 1:47:40 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Public Comment Item 12c
You don't often get email from [email protected]. Learn why this is important Our asks are clear:
-Cancel the City of Watsonville’s Flock contract;
-Remove the Flock license plate reader cameras; and
-Hold public hearings on the privacy, data security, civil rights, and public safety impacts of Flock technology.
--
Laurel Tenaya Woerner
+ 1 831 295 1518
From: City Council
To: Eduardo Montesino; Vanessa Quiroz; Maria Orozco; Kristal Salcido; Casey Clark; Jimmy Dutra; Ari Parker; cityclerk
Subject: FW: Public Comment Item 12c
Date: Monday, September 21, 2026 2:21:51 PM
From: Tamara Liu <[email protected]>
Sent: Monday, September 21, 2026 2:21:27 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Public Comment Item 12c
You don't often get email from [email protected]. Learn why this is important Hi,
I am a previous resident of Watsonville (now living in Santa Cruz) and currently work in Watsonville. I am emailing to ask you to take the following actions:
-Cancel the City of Watsonville’s Flock contract;
-Remove the Flock license plate reader cameras; and
-Hold public hearings on the privacy, data security, civil rights, and public safety impacts of Flock technology.
These actions will help ensure the rights of all local residents and increase the safety of our community.
Thank you,
Tamara Liu
From: City Council
To: Eduardo Montesino; Vanessa Quiroz; Maria Orozco; Kristal Salcido; Casey Clark; Jimmy Dutra; Ari Parker; cityclerk
Subject: FW: Cancel the City of Watsonville’s Flock contract Date: Monday, September 21, 2026 2:25:19 PM
From: [email protected] <[email protected]>
Sent: Monday, September 21, 2026 2:25:10 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Cancel the City of Watsonville’s Flock contract You don't often get email from [email protected]. Learn why this is important Cancel the City of Watsonville’s Flock contract;
Remove the Flock license plate reader cameras; and
Hold public hearings on the privacy, data security, civil rights, and public safety impacts of Flock technology.
Respectfully,
Michael Simone
128 Onyx Dr.
Watsonville, CA
From: City Council
To: Eduardo Montesino; Vanessa Quiroz; Maria Orozco; Kristal Salcido; Casey Clark; Jimmy Dutra; Ari Parker; cityclerk
Subject: FW: No Flock Cameras in Watsonville
Date: Monday, September 21, 2026 2:44:30 PM
From: Shizue Shikuma <[email protected]>
Sent: Monday, September 21, 2026 2:43:39 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: No Flock Cameras in Watsonville
You don't often get email from [email protected]. Learn why this is important Dear City Council,
Please do not approve Flock in Watsonville--it is repressive and profiles too many of our residents.
Sincerely,
Lois Shizue Shikuma
427 Bridge St, Watsonville, CA 95076
From: City Council
To: Eduardo Montesino; Vanessa Quiroz; Maria Orozco; Kristal Salcido; Casey Clark; Jimmy Dutra; Ari Parker; cityclerk
Subject: FW: Public Comment 12c
Date: Monday, September 21, 2026 2:56:58 PM
From: Tom Bentley <[email protected]>
Sent: Monday, September 21, 2026 2:55:18 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Public Comment 12c
You don't often get email from [email protected]. Learn why this is important Dear Councilmembers: I am greatly concerned about the abusive use of Flock cameras that is now being exposed across the country. These cameras violate the privacy rights of citizens, and do not belong in Watsonville, nor elsewhere.
Please cancel the Flock contract and remove the cameras. The potential for deep abuse, particularly in a Latino community, is alarming and real.
Thank you, Tom Bentley
Watsonville resident
________________________________
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From: City Council
To: Eduardo Montesino; Vanessa Quiroz; Maria Orozco; Kristal Salcido; Casey Clark; Jimmy Dutra; Ari Parker; cityclerk
Subject: FW: Agenda item 12C
Date: Monday, September 21, 2026 3:46:26 PM
________________________________________
From: David Cavanaugh <[email protected]>
Sent: Monday, September 21, 2026 3:46:03 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council
Subject: Agenda item 12C
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Please remove Flock cameras and other means of surveillance of citizens in Watsonville. Restore our civil rights and create policy that restores our right to privacy,
Thank you!
Dave Cavanaugh
Sent from my iPhone
From: City Council
To: Eduardo Montesino; Vanessa Quiroz; Maria Orozco; Kristal Salcido; Casey Clark; Jimmy Dutra; Ari Parker; cityclerk
Subject: FW: public comment item 12c
Date: Monday, September 21, 2026 4:15:37 PM
From: Audrey Jose <[email protected]>
Sent: Monday, September 21, 2026 4:15:11 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: public comment item 12c
You don't often get email from [email protected]. Learn why this is important Hello,
I would like to add a comment for the city council meeting tomorrow as I will not be able to attend in person. I would like to urge the city council to end their contract with flock cameras and remove all the cameras that have been installed in watsonville as they allow for dangerous behavior such as stalking and contribute to harmful levels of surveillance. There are better solutions out there for communities to look out for danger and flock cameras are a violation of privacy and allow for third parties to buy, sell, and edit the footage which could allow governments to arrest people for falsely generated footage of crimes. please get these and any other automatic license plate readers out of the city as soon as possible.
Sincerely,
Audrey Jose
Outlook
FLOCK
From Rebecca Garcia <[email protected]>
Date Mon 9/21/2026 5:04 PM
To Irwin Ortiz <[email protected]>
1 attachment (8 KB)
Flock 2.docx;
Hi Irwin, please send the copy of my attached letter to each of the Council members and to Tamara regarding Flock. Gracias,
Rebecca
9/23/26, 11:53 AM Inbox - Irwin Ortiz - Outlook
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To: City Council members
From: Rebecca J. García
RE: FLOCK
Dar Council members,
In August I spoke to Shebreh and Sonya from Santa Cruz City Council regarding their decision to eliminate Flock. Shebreh said she spoke to Flock representatives and they could not convince her they could protect Santa Cruz data. Their values and practices did not support the protection necessary to protect the community. She also said they were dismissive and uninformed.
Sonja with the City Attorney offered a substitute motion to keep Flock by adding safety features to protect the community at large. However Sonja recognizes that with technology there is potential for abuse and hacking. My question for you is to consider to what extent can abuse and hacking occur with AI. The latest research shows that AI will make decisions contrary to what we as community members would want. Please consider eliminating Flock.
Sincerely,
Rebecca García
Outlook
FW: Public Comment Item 12c
From City Council <[email protected]>
Date Mon 9/21/2026 5:06 PM
To Eduardo Montesino <[email protected]>; Vanessa Quiroz <[email protected]>; Maria Orozco <[email protected]>; Kristal Salcido <[email protected]>; Casey Clark <[email protected]>; Jimmy Dutra <[email protected]>; Ari Parker <[email protected]>; cityclerk <[email protected]>
From: Megan Robertson <[email protected]>
Sent: Monday, September 21, 2026 5:05:56 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>; Maria Orozco <[email protected]> Subject: Public Comment Item 12c
You don't often get email from [email protected]. Learn why this is important Dear Councilmember Orozco and Members of the Watsonville City Council, My name is Megan Robertson, and I am a resident of District 3. I am writing to you today not only as a concerned community member but also as a Licensed Clinical Social Worker serving local students and families at Cabrillo College. I am urging the City Council to take a definitive stand against mass surveillance by ending our city’s use of Automated License Plate Reader (ALPR) technology.
Specifically, my asks are that the City of Watsonville does not renew its contract with Flock Safety and immediately removes all existing Flock cameras from our community.
I do not support any ALPR cameras or mass surveillance in Watsonville. Forcing our residents to be subjected to constant, warrantless monitoring fundamentally undermines the privacy and civil liberties of our community. Furthermore, this technology has a well-documented history of being abused.
Across the country, there are widespread and frequent issues with data security, unauthorized sharing of sensitive location data with outside agencies, and a severe lack of robust oversight.
In my work at Cabrillo College, I see firsthand that a healthy, thriving community is built on trust, mutual support, and investing in human resources, not pervasive surveillance. Implementing surveillance networks creates an environment of suspicion and anxiety, and it historically disproportionately impacts our most vulnerable and marginalized neighbors. We should be investing our city's resources into programs that directly uplift our residents rather than paying private corporations to monitor them.
Please stand up for the privacy and safety of District 3 and all Watsonville residents. I respectfully ask Councilmember Orozco and the entire Council to vote against any renewal of the Flock Safety contract and commit to taking down the existing cameras.
9/23/26, 11:43 AM Mail - cityclerk - Outlook
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Thank you for your time, your service to our city, and your careful consideration of this urgent matter.
Sincerely,
Megan Robertson
9/23/26, 11:43 AM Mail - cityclerk - Outlook
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Outlook
FW: Public Comment for 9/22/26
From City Council <[email protected]>
Date Mon 9/21/2026 5:51 PM
To Eduardo Montesino <[email protected]>; Vanessa Quiroz <[email protected]>; Maria Orozco <[email protected]>; Kristal Salcido <[email protected]>; Casey Clark <[email protected]>; Jimmy Dutra <[email protected]>; Ari Parker <[email protected]>; cityclerk <[email protected]>
From: [email protected] <[email protected]>
Sent: Monday, September 21, 2026 5:51:13 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>; Maria Orozco <[email protected]> Subject: Public Comment for 9/22/26
You don't often get email from [email protected]. Learn why this is important Dear Mayor Salcido, Councilmember Orozco, and Members of the City Council, I write to ask you to please end Watsonville's use of Automated License Plate Reader (also called ALPR) technology. Surveillance systems that record location, time, and travel patterns are the definition of a dragnet: mass surveillance of the innocent in the hope of occasionally catching the guilty. Our residents, law-abiding citizens who have committed no crime and warrant no scrutiny, never consented to having their daily movements cataloged in a private contractor's for-sale database.
This is not a hypothetical risk. The Institute for Justice has documented over 200 nationwide cases of ALPR system abuse: misuse by officers to stalk exes and family members, shared with agencies like ICE for extrajudicial enforcement, cataloging those who attend protests, union meetings, or reproductive health clinics. Time and again, this technology has been trained disproportionately on Black, Latino, and low-income neighborhoods, turning entire communities into permanent suspects simply because of where they live. ALPR misreads and database errors have already led to innocent people being pulled from their cars at gunpoint and wrongfully arrested, because of plate misreads or incorrect stolen vehicle flags that were never cleared. This is the predictable result of building a system that tracks every resident with suspicion.
The Fourth Amendment exists precisely to prevent this kind of unreasonable search. Our founders understood that a government able to watch its citizens at all times, without individualized suspicion, is a government that cannot be trusted with that power. Data collected today for one purpose becomes available tomorrow for another: political retaliation, immigration enforcement, harassment of activists, or simple machine and human error with devastating consequences.
Watsonville can be a leader instead of a cautionary tale. Please end our ALPR program, or at minimum impose transparent auditing, a ban on data sharing with outside agencies, and prohibit retention of 9/23/26, 11:45 AM Mail - cityclerk - Outlook
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historical ALPR data absent an active, specific criminal investigation supported by a warrant.
Members of the Council, Watsonville is a city of hardworking families, of farmworkers and small business owners, of students and elders, of neighbors who look out for one another. We do not need a camera on every corner logging our lives to be safe. Our residents deserve a police department that investigates crime with due process. You took an oath to protect the rights of the people of Watsonville and tonight I am asking you to keep it. I urge you to stand with your constituents and the fourth amendment, not with dragnet enforcement, and certainly not with a surveillance vendor's sales pitch. Thank you for your time and willingness to listen.
John Robertson
9/23/26, 11:45 AM Mail - cityclerk - Outlook
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Outlook
FW: Public Remarks for Item 12.C - 9/22/26 - In Support of FLOCK Cameras By Donald Charles Schwartz, MBA, JD
From City Council <[email protected]>
Date Mon 9/21/2026 6:01 PM
To Eduardo Montesino <[email protected]>; Vanessa Quiroz <[email protected]>; Maria Orozco <[email protected]>; Kristal Salcido <[email protected]>; Casey Clark <[email protected]>; Jimmy Dutra <[email protected]>; Ari Parker <[email protected]>; cityclerk <[email protected]>
1 attachment (312 KB)
Donald Schwartz FLOCK Statement.pdf;
From: Donald Schwartz <[email protected]> Sent: Monday, September 21, 2026 6:00:49 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Public Remarks for Item 12.C - 9/22/26 - In Support of FLOCK Cameras By Donald Charles Schwartz, MBA, JD
You don't often get email from [email protected]. Learn why this is important Please find my Public Remarks to be included as set forth above. Thank you.
Donald C. Schwartz, MBA, JD
Please consider the environment before printing this email. 9/23/26, 11:46 AM Mail - cityclerk - Outlook
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Public Comment Supporting FLOCK
Camera Implementation in Watsonville,
California
To Be Included in Public Comments 9/21/26
Item 12.C Discussion Regarding The Watsonville Police Department’s Use of FLOCK Safety Cameras
By: Donald Charles Schwartz, JD, MBA
Speaker Background Statement
Good evening. My name is Donald Charles Schwartz. I come before you tonight with a perspective shaped by a lifetime commitment to both civil liberties and public safety—values that are not in conflict, but must work in partnership.
My family's dedication to justice runs deep. My grandfather co-founded the ACLU alongside Jane Addams, Clarence Darrow, and Roger Baldwin, and in recognition of his work Jane Addam’s gave her 1931 Nobel Peace Prize to my grandfather Charles P. Schwartz some 100 years ago. I am a 1972 graduate of Soquel High School and have been a member of the State Bar of California for more than 40 years, practicing law here in Santa Cruz County. In Washington, D.C., I had the honor of working with the Congressional Black Caucus to help pass the AntiApartheid Act of 1986, legislation that ended apartheid in South Africa and resulted in the eventual release of Nelson Mandela from Robben Island Prison.
My son, a graduate of Aptos High School, now serves as a police officer with the San Francisco Police Department. He holds three college degrees, including a master's in clinical psychology, and is currently completing his doctorate in clinical psychology. He understands policing not just as enforcement, but as a responsibility that requires balancing community safety with individual rights.
This background—rooted in civil liberties advocacy, legal practice, civil rights legislation, and law enforcement—informs my position tonight: FLOCK camera systems represent a valuable tool for Watsonville, when implemented with appropriate privacy protections and community oversight.
Why FLOCK Cameras Serve Watsonville's Public
Safety Interests
Watsonville faces the same challenges confronting communities across California: limited law enforcement resources, increasing property crimes, vehicle thefts, and the need to solve serious crimes efficiently while respecting residents' privacy. FLOCK cameras—automated license plate recognition systems—offer a targeted, constitutional approach to these challenges.
These systems capture license plate data from vehicles traveling on public roads, creating a searchable database that helps investigators identify vehicles connected to crimes, locate stolen vehicles, and find missing persons. Unlike traditional surveillance that monitors individuals' activities, ALPR technology focuses narrowly on vehicle license plates already displayed in public view, information that carries no reasonable expectation of privacy under California and federal law.
The benefits are substantial:
Solving Serious Crimes: When violent crimes occur—robberies, assaults, shootings—investigators can query ALPR data to identify vehicles present near the crime scene during the relevant timeframe. This capability dramatically accelerates investigations and increases clearance rates for crimes that devastate families and communities.
Recovering Stolen Vehicles: Vehicle theft remains a persistent problem.
FLOCK cameras create an automated alert system that notifies law enforcement when a stolen vehicle passes a camera location, enabling rapid recovery and reducing financial losses for victims.
Locating Missing Persons: When vulnerable individuals go missing—children, elderly persons with dementia, individuals in mental health crisis—ALPR data can help locate their vehicles quickly, potentially saving lives.
Officer Safety: Officers responding to calls can check whether vehicles associated with wanted individuals or firearms-related incidents are in the area, enhancing their situational awareness and safety.
Efficient Resource Use: Rather than dedicating officers to manual surveillance or checkpoint operations, ALPR systems provide continuous, automated coverage, freeing personnel for community policing and emergency response.
California's Legal Framework Protects Privacy
While Permitting ALPR Use
California law explicitly permits public agencies to operate ALPR systems while establishing mandatory privacy safeguards. The California Civil Code requires ALPR operators and end-users to implement comprehensive protections:
Usage and Privacy Policies: Public agencies must adopt and publish written policies specifying authorized purposes for ALPR use, employee training requirements, security measures, data-sharing restrictions, accuracy procedures, and retention limits. Cal Civ Code § 1798.90.5, Cal Civ Code § 1798.90.51 Access Controls and Auditing: Agencies must maintain records of who accesses ALPR information, when, for what purpose, and which license plates were queried, creating an audit trail that deters misuse and enables accountability. Cal Civ Code § 1798.90.52
Security Requirements: ALPR systems must have reasonable operational, administrative, technical, and physical safeguards protecting data from unauthorized access, destruction, use, modification, or disclosure. Cal Civ Code § 1798.90.51, Cal Civ Code § 1798.90.53
Public Transparency: Agencies must provide opportunities for public comment at regularly scheduled meetings before implementing ALPR programs and make usage policies publicly available online. Cal Civ Code § 1798.90.55 Data-Sharing Restrictions: Public agencies cannot sell, share, or transfer ALPR information except to other public agencies and only as permitted by law.
Cal Civ Code § 1798.90.55
Civil Remedies: Individuals harmed by unauthorized access, use, or security breaches can bring civil actions for damages, including minimum liquidated damages of $2,500, punitive damages for willful violations, attorney's fees, and injunctive relief. Cal Civ Code § 1798.90.54
These statutory protections create a comprehensive framework balancing legitimate law enforcement needs with privacy interests. Watsonville can and should implement FLOCK cameras within this framework, ensuring that deployment serves public safety without creating unchecked surveillance.
Addressing Civil Liberties Concerns Through
Transparent Implementation
As someone whose family helped found the ACLU and who spent decades working on civil rights legislation, I understand concerns about surveillance technology. Those concerns deserve serious consideration—and serious safeguards.
The key is implementing FLOCK cameras with robust limitations:
Narrow Purpose Restrictions: Watsonville should limit ALPR use to specific, defined law enforcement purposes: investigating reported crimes, locating stolen vehicles, finding missing persons, and serving warrants. The system should not be used for general surveillance, tracking lawful political activity, monitoring immigration status, or creating location databases on law-abiding residents.
Strict Retention Limits: California Vehicle Code provisions addressing similar automated enforcement systems require destruction of data within specified timeframes. Cal Veh Code § 40240 (2023) Watsonville should adopt comparable retention limits—retaining ALPR data only as long as necessary for legitimate investigations, typically no more than one year, and purging data not connected to active investigations.
Public Oversight: The City Council should require annual public reports on ALPR use, including aggregate statistics on queries performed, investigations assisted, vehicles recovered, crimes solved, and any data breaches or unauthorized access incidents. Regular public reporting creates transparency and accountability.
Training Requirements: All personnel authorized to access ALPR systems should complete training on privacy laws, constitutional limitations, proper use protocols, and consequences for misuse. Training ensures that officers understand both the capabilities and limitations of the technology.
Independent Audits: Watsonville should authorize independent audits of ALPR access logs to detect and deter misuse, with findings reported to the City Council and made available to the public.
Community Engagement: The City should establish ongoing opportunities for community input on ALPR policies, allowing residents to voice concerns and suggest improvements as the program develops.
These safeguards—drawn from California's statutory framework and best practices developed by privacy advocates—ensure that FLOCK cameras serve legitimate public safety interests without becoming tools of mass surveillance.
Learning From My Son's Experience in Law
Enforcement
My son's work as a San Francisco police officer, informed by his graduate education in clinical psychology, has taught our family valuable lessons about modern policing. Effective law enforcement requires both tools and judgment— technology that enhances investigative capabilities while respecting constitutional boundaries.
FLOCK cameras provide that balance. They don't replace human judgment; they support it. When a serious crime occurs, investigators still must develop leads, interview witnesses, analyze evidence, and build cases. ALPR data becomes one investigative tool among many—but often a decisive one that transforms an unsolvable case into a case with actionable leads.
My son has seen how limited resources force difficult choices: which cases to prioritize, which leads to pursue, how to allocate personnel across competing demands. Technology that makes investigations more efficient doesn't reduce the importance of community relationships or constitutional policing—it makes both more achievable by freeing resources for proactive engagement rather than reactive crisis response.
Conclusion: A Measured Approach Serving Both
Safety and Liberty
Watsonville can implement FLOCK cameras in a manner that honors both public safety imperatives and civil liberties protections. California law provides the framework; community engagement provides the oversight; transparent policies provide the accountability.
I urge the City Council to continue to approve FLOCK camera deployment with the following commitments:
1. Adopt a comprehensive usage and privacy policy meeting all requirements of California Civil Code Sections 1798.90.51 and 1798.90.53, including narrow purpose restrictions, security safeguards, and retention limits
2. Provide this policy to the public in writing and post it prominently on the City's website before system activation
3. Establish annual public reporting requirements covering system use, effectiveness metrics, and any privacy incidents
4. Require mandatory training for all personnel authorized to access ALPR data
5. Authorize independent audits of access logs with findings reported publicly
6. Create ongoing mechanisms for community input on ALPR policies and practices
This measured approach allows Watsonville to gain the public safety benefits of ALPR technology—faster investigations, more recovered property, enhanced officer safety—while maintaining the privacy protections and constitutional limitations that protect all residents.
My family's century-long commitment to civil liberties and my 40-year legal career practicing in this county convince me that we need not choose between safety and freedom. With proper safeguards, transparent policies, and community oversight, FLOCK cameras can serve both values.
I respectfully urge your support.
Thank you.
Donald Charles Schwartz, JD, MBA
Outlook
FW: Watsonville City Council
From City Council <[email protected]>
Date Mon 9/21/2026 7:20 PM
To Eduardo Montesino <[email protected]>; Vanessa Quiroz <[email protected]>; Maria Orozco <[email protected]>; Kristal Salcido <[email protected]>; Casey Clark <[email protected]>; Jimmy Dutra <[email protected]>; Ari Parker <[email protected]>; cityclerk <[email protected]>
________________________________________
From: Sringler <[email protected]>
Sent: Monday, September 21, 2026 7:19:43 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council
Subject: Watsonville City Council
[You don't often get email from [email protected]. Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ]
Please show respect for the community by canceling the flock contract until a forum can be held where both sides can present their views. We deserve the facts. Thanks for listening. Sarah Ringler Sent from my iPhone
9/23/26, 11:47 AM Mail - cityclerk - Outlook
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Outlook
FW: Remove Flock Cameras ASAP
From City Council <[email protected]>
Date Mon 9/21/2026 11:45 PM
To Eduardo Montesino <[email protected]>; Vanessa Quiroz <[email protected]>; Maria Orozco <[email protected]>; Kristal Salcido <[email protected]>; Casey Clark <[email protected]>; Jimmy Dutra <[email protected]>; Ari Parker <[email protected]>; cityclerk <[email protected]>
From: Victoria Banales <[email protected]>
Sent: Monday, September 21, 2026 11:45:05 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Remove Flock Cameras ASAP
You don't often get email from [email protected]. Learn why this is important Dear Casey Clark and the entire Watsonville City Council, I urge you to prioritize the removal of Flock "safety" cameras from our Watsonville community. For many residents, these devices do not create a sense of safety but instead raise serious concerns about privacy and civil liberties.
Our community should not be subjected to 24/7 monitoring as though we were living in George Orwell's 1984. Watsonville is an immigrant community, and these cameras are causing widespread distrust and fear, especially given the anti-immigrant political climate and ongoing ICE raids.
Moreover, reports of law enforcement's misuse of the system (over 200 cases!)--i.e., police officers stalking exes or romantic partners--have further eroded public trust and made us even more weary and distrustful of the surveillance technology.
Flock cameras have no place in our community and should never have been installed. Cities across California and the U.S., including Santa Cruz and Los Angeles, have begun deactivating and removing them. Even conservative "red" districts are deactivating them.
It's time for Watsonville to follow the lead of other cities and take meaningful action to protect our privacy and civil liberties.
Sincerely,
Dr. Victoria Bañales, District 5
72 Alisa Circle
Watsonville, CA 95076
(831) 252-8321
9/23/26, 11:51 AM Mail - cityclerk - Outlook
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Outlook
FW: Public comment item 12c
From City Council <[email protected]>
Date Tue 9/22/2026 8:12 AM
To Eduardo Montesino <[email protected]>; Vanessa Quiroz <[email protected]>; Maria Orozco <[email protected]>; Kristal Salcido <[email protected]>; Casey Clark <[email protected]>; Jimmy Dutra <[email protected]>; Ari Parker <[email protected]>; cityclerk <[email protected]>
From: Meghan Pickett <[email protected]>
Sent: Tuesday, September 22, 2026 8:12:37 AM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Public comment item 12c
You don't often get email from [email protected]. Learn why this is important Dear council members,
I respectfully request that you cancel the contract for the Flock cameras and remove the license plate reading cameras. I believe they pose a risk to our community’s privacy, data security, civil rights, and public safety.
Thank you for your consideration in this matter.
Meghan Pickett
9/23/26, 11:51 AM Mail - cityclerk - Outlook
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Outlook
FW: No Flock cameras!
From City Council <[email protected]>
Date Tue 9/22/2026 9:32 AM
To Eduardo Montesino <[email protected]>; Vanessa Quiroz <[email protected]>; Maria Orozco <[email protected]>; Kristal Salcido <[email protected]>; Casey Clark <[email protected]>; Jimmy Dutra <[email protected]>; Ari Parker <[email protected]>; cityclerk <[email protected]>
________________________________________
From: Randa Solick <[email protected]>
Sent: Tuesday, September 22, 2026 9:32:12 AM (UTC-08:00) Pacific Time (US & Canada) To: City Council
Subject: No Flock cameras!
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Already the national organizations are collecting, and selling, so much information about us. The police can do their jobs as they have been, without the cameras. The surveillance state is getting worse and we really have to stop it whenever we can.
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Outlook
FW: Public Comment Item 12c, meeting date 9/22/26
From City Council <[email protected]>
Date Tue 9/22/2026 10:29 AM
To Eduardo Montesino <[email protected]>; Vanessa Quiroz <[email protected]>; Maria Orozco <[email protected]>; Kristal Salcido <[email protected]>; Casey Clark <[email protected]>; Jimmy Dutra <[email protected]>; Ari Parker <[email protected]>; cityclerk <[email protected]>
From: Rose K. Murphy <[email protected]>
Sent: Tuesday, September 22, 2026 10:29:05 AM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Public Comment Item 12c, meeting date 9/22/26
You don't often get email from [email protected]. Learn why this is important Dear City Council Members,
I have lived in Watsonville for 14 years. I love this city. I live across Main Street from the mall and parking lots that host Ross, Staples, Target, and other businesses. I can see many Flock cameras from my back window.
I am extremely unsettled by the deployment of Flock cameras around Watsonville. We are a community with many immigrants, many people of color, and many people who are poor or working class. These are the groups that get targeted by federal agents and whose civil rights are trampled upon. There is no acceptable reason to provide data to help them harm the residents of Watsonville.
Around the country, there have been reports of government officials, especially police and other law enforcement agents, abusing their access to Flock's data, for illegal purposes, such as spying on exdomestic partners. There are no guardrails that have been able to prevent these occurrences. (See article in Mother Jones Magazine.)
I urge you to cancel the Watsonville City contract with Flock and remove all license plate reader cameras. Furthermore, I urge you not to sign any contracts with other providers of license plate reader technology in the future. Lastly, I urge you to hold hearings about the impact of Flock cameras and similar technology on the privacy, data security, civil rights, and public safety of Watsonville residents and visitors.
Thank you for your consideration.
Sincerely,
Rose K. Murphy
9/23/26, 11:56 AM Mail - cityclerk - Outlook
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Terry Loop, Watsonville
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Outlook
FW: Public Comment Item 12c
From City Council <[email protected]>
Date Tue 9/22/2026 10:42 AM
To Eduardo Montesino <[email protected]>; Vanessa Quiroz <[email protected]>; Maria Orozco <[email protected]>; Kristal Salcido <[email protected]>; Casey Clark <[email protected]>; Jimmy Dutra <[email protected]>; Ari Parker <[email protected]>; cityclerk <[email protected]>
From: Sierra Ramer <[email protected]>
Sent: Tuesday, September 22, 2026 10:42:01 AM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Public Comment Item 12c
You don't often get email from [email protected]. Learn why this is important Good morning,
I am writing today about my concerns with public comment item 12c for the use and contract with Flock cameras in Watsonville. Please see my comments below since I can not make it to tonight's city council meeting.
For our community's health and safety, I believe the city should:
-Cancel the City of Watsonville’s Flock contract;
-Remove the Flock license plate reader cameras; and
-Hold public hearings on the privacy, data security, civil rights, and public safety impacts of Flock technology.
Thank you!
Sierra R
9/23/26, 11:57 AM Mail - cityclerk - Outlook
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Outlook
FW: Public comment Item 12c--cancel the FLOCK contract! From City Council <[email protected]>
Date Tue 9/22/2026 11:08 AM
To Eduardo Montesino <[email protected]>; Vanessa Quiroz <[email protected]>; Maria Orozco <[email protected]>; Kristal Salcido <[email protected]>; Casey Clark <[email protected]>; Jimmy Dutra <[email protected]>; Ari Parker <[email protected]>; cityclerk <[email protected]>
From: Aileen Vance <[email protected]>
Sent: Tuesday, September 22, 2026 11:06:18 AM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Public comment Item 12c--cancel the FLOCK contract! You don't often get email from [email protected]. Learn why this is important I was shocked to hear that Watsonville is considering FLOCK cameras within the city. Although I can understand the desire to have access to technology that can help with identifying real criminals, all of the information we are seeing in the national news indicate that FLOCK is being used by ICE to harass and identify immigrants in our communities, whether they are here legally or not. FLOCK is being used as a tool to arrest innocent, hard-working people, to terrify and divide hard-working families and illegally arrest citizens who may appear to be "illegal” because of the color of their skin or where they go to work. The horror stories we have seen in other cities (like Portland Me, or Minneapolis, MN) point to an ill-trained ICE force who have been directed to detain and deport anyone they see fit regardless of due process of law, civil rights and often without any warrants. In the process, we have seen undue violence and inhumane detentions; some of these agents have committed murder.
Families in some of these cities have been afraid to leave their homes or attend schools or hearings for fear of being arrested, even if they were here legally! The economy of the Central Coast is rooted in agriculture and tourism and the Pájaro Valley has a long and rich history of being a diverse community of farmers and farmworkers. Where would Santa Cruz County be without immigrant labor in our hotels, restaurants, nursing homes, hospitals, fields, stores, bakeries, etc. The legacy of many of these immigrants families’ hard work and bravery is that their children and children’s children stay in our community and now sit at the leadership table of city and county government. They are teachers and school principals. They are innovators. They are lawyers and architects and doctors and more! The contributions of immigrants families in our community are inspiring and steadfast.
Why would Watsonville consider installing FLOCK cameras to further terrorize our immigrant workers? Despite the temptation to use them to fight real crimes, the dangers FLOCK cameras present far outweigh to benefits, in my opinion. I join other Santa Cruz county residents in strongly asking the City Council to do the following:
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-Cancel the City of Watsonville’s Flock contract;
-Remove the Flock license plate reader cameras; and
-Hold public hearings on the privacy, data security, civil rights, and public safety impacts of Flock technology.
I would add in addition to above that I hope Watsonville can find a way to make atrisk residents of the city feel safe and informed of their rights and what resources they have available to them. I know that YARR is doing some great work in that regard and I hope the City Council will consider bringing them into the conversation.
Thank you,
Aileen Vance
[email protected]
aileenvance.com
"If they don't give you a seat at the table, bring a folding chair." — Shirley Chisholm 9/23/26, 11:57 AM Mail - cityclerk - Outlook
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Outlook
FW: Public Comment- Agenda Item 12C
From City Council <[email protected]>
Date Tue 9/22/2026 12:35 PM
To Eduardo Montesino <[email protected]>; Vanessa Quiroz <[email protected]>; Maria Orozco <[email protected]>; Kristal Salcido <[email protected]>; Casey Clark <[email protected]>; Jimmy Dutra <[email protected]>; Ari Parker <[email protected]>; cityclerk <[email protected]>
From: Regina Araiza Sanchez <[email protected]>
Sent: Tuesday, September 22, 2026 12:34:50 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Public Comment- Agenda Item 12C
You don't often get email from [email protected]. Learn why this is important Dear Mayor and Council Members,
I am writing to address agenda item 12C and urge the Watsonville City Council to cancel the city’s contract with Flock and discontinue the use of automated license plate readers in our community.
Despite being described as a tool for safety, this technology does not prevent crime. Instead, it enables automated profiling, exposes local data to outside entities, and unfairly targets vulnerable members of our community.
True public safety relies on trust and community investment, not constant tracking. I urge the Council to cancel the Flock contract, remove these surveillance cameras, and protect the privacy and dignity of Watsonville residents. Our local resources should go toward community-centered public safety, not widespread neighborhood surveillance.
Mass surveillance has no place in Watsonville.
Respectfully,
Regina Araiza-Sanchez
Watsonville resident, District 5
9/23/26, 11:57 AM Mail - cityclerk - Outlook
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Outlook
FW: Public comment
From City Council <[email protected]>
Date Tue 9/22/2026 12:43 PM
To Eduardo Montesino <[email protected]>; Vanessa Quiroz <[email protected]>; Maria Orozco <[email protected]>; Kristal Salcido <[email protected]>; Casey Clark <[email protected]>; Jimmy Dutra <[email protected]>; Ari Parker <[email protected]>; cityclerk <[email protected]>
From: Alma Partida <[email protected]>
Sent: Tuesday, September 22, 2026 12:42:40 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Public comment
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12.c Discussion Regarding the WPDs use of Flock cameras Hello,
I write to you as a concerned mother of a soon to be middle schooler. I am concerned about Flock cameras facing PVUSD schools and the Target parking lot / shopping center where a lot of PVUSD students hang out.
There shouldn’t be surveillance to this degree in a students “third space”. There are hardly any spots for them to hang out as it is and the target shopping center should not be where they are targeted for policing.
I ask for an abolishment of the cameras altogether. These are MINORS! 9/23/26, 11:57 AM Mail - cityclerk - Outlook
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-Alma Partida
Resident of Watsonville
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Outlook
FW: Public Comment Item 12c
From City Council <[email protected]>
Date Tue 9/22/2026 1:03 PM
To Eduardo Montesino <[email protected]>; Vanessa Quiroz <[email protected]>; Maria Orozco <[email protected]>; Kristal Salcido <[email protected]>; Casey Clark <[email protected]>; Jimmy Dutra <[email protected]>; Ari Parker <[email protected]>; cityclerk <[email protected]>
From: Alexis Allison <[email protected]>
Sent: Tuesday, September 22, 2026 1:02:38 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Public Comment Item 12c
You don't often get email from [email protected]. Learn why this is important Good afternoon Watsonville City Council,
As a member of the community, our ask is clear;
1. Please cancel the City of Watsonville Flock contract
2. Remove the Flock license plate reader camera's
3. Hold public hearings on the privacy, data security, civil rights, and public safety impacts of Flock technology.
If flock cameras are allowed then why do we need a police department? I'd rather my tax dollars go to the police department than to a camera that cannot take immediate action or be held accountable if a mistake is made.
Alexis Allison
9/23/26, 12:00 PM Mail - cityclerk - Outlook
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Outlook
FW: Item 12C
From City Council <[email protected]>
Date Tue 9/22/2026 1:12 PM
To Eduardo Montesino <[email protected]>; Vanessa Quiroz <[email protected]>; Maria Orozco <[email protected]>; Kristal Salcido <[email protected]>; Casey Clark <[email protected]>; Jimmy Dutra <[email protected]>; Ari Parker <[email protected]>; cityclerk <[email protected]>
From: Maria Elena de la Garza <[email protected]>
Sent: Tuesday, September 22, 2026 1:10:34 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>; Tamara Vides <[email protected]> Cc: Paulina Moreno <[email protected]>
Subject: Item 12C
Dear City Councilmembers and City Manager Vides,
First and foremost, I write to you as a District 2 resident, a Watsonville native, and a member of this community. I also write as the CEO of the Community Action Board of Santa Cruz County (CAB), an organization whose mission is to eliminate poverty, advance equity, and advocate for the needs and priorities of our community.
CAB has been a proud partner of the City of Watsonville for decades. We value our relationship with the City and take seriously our responsibility to elevate community voices—particularly those of residents who are often underrepresented in civic decision-making.
We understand and support the community’s need for safety. At the same time, decisions regarding surveillance and the use of Flock cameras have significant implications for privacy, trust, and our relationship with law enforcement. We believe the City can—and should—find a path forward that prioritizes public safety while ensuring meaningful community participation and transparency.
With that in mind, I respectfully request that the City Council consider the following before making a decision regarding Flock cameras:
1. Convene a well-publicized community town hall, with sufficient time for meaningful outreach. Consider contracting with trusted community messengers to conduct door-todoor outreach and/or holding conversations within each Council district to ensure residents have a genuine opportunity to participate.
2. Invite the Watsonville Police Chief and WPD leadership to listen to community concerns, explain the public safety rationale, and answer residents’ questions directly.
3. Invite Flock Safety representatives to provide a clear overview of the technology, how information is collected, accessed, retained, and shared, and the safeguards in place— and to answer questions from the community.
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4. Partner with local community-based organizations to conduct a community survey that reaches residents who may not participate in traditional City meetings, including through trusted staff and existing community networks.
5. Consider forming an Ad Hoc Community Committee representing diverse community perspectives to review the information and community feedback and provide recommendations to the Council.
These steps would provide the Council with something essential before making a decision of this magnitude: a fuller understanding of what our community knows, what residents are concerned about, what questions remain unanswered, and what safeguards our community believes are necessary.
Public safety and community trust do not have to be competing priorities. We have an opportunity to demonstrate that Watsonville can pursue both—by making decisions with the community, not simply for the community.
CAB stands ready to be a partner in creating a meaningful and inclusive community engagement process.
Thank you for your consideration and for your continued commitment to the residents of Watsonville.
With gratitude and respect,
Maria Elena De La Garza
Chief Executive Officer
Community Action Board of Santa Cruz County, Inc.
MariaElena De La Garza
Chief Executive Officer
[email protected] | 831-7632147 Ext. 203
Community Action Board of Santa Cruz County, Inc.
406 Main St., Suite 208, Watsonville, CA 95076
I invite you to watch and share my recent TEDX presentation that I dedicate to ALL the fierce Latina Leaders (xingonas!) who have helped shape me and inspire me on a daily basis!:
https://www.youtube.com/watch?v=GAlfTZqZqOU;
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Outlook
FW: Public Comment Item 12c
From City Council <[email protected]>
Date Tue 9/22/2026 2:00 PM
To Eduardo Montesino <[email protected]>; Vanessa Quiroz <[email protected]>; Maria Orozco <[email protected]>; Kristal Salcido <[email protected]>; Casey Clark <[email protected]>; Jimmy Dutra <[email protected]>; Ari Parker <[email protected]>; cityclerk <[email protected]>
From: Cara Beban <[email protected]>
Sent: Tuesday, September 22, 2026 2:00:07 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Subject: Public Comment Item 12c
You don't often get email from [email protected]. Learn why this is important To whom it may concern,
I am writing as a concerned resident of Santa Cruz County regarding the Flock surveillance cameras and license plate readers in Watsonville. It is imperative that Watsonville's contract with Flock be cancelled immediately.
Watsonville is full of families and workers who have lived there peacefully for generations. It is an abhorrent violation of citizens' privacy and safety to monitor them using technology that has been involved in numerous security scandals.
This “safety” company cannot be trusted to keep us truly safe. In addition to collected data being illegally misused by law enforcement, they have been proven to share data with out-of-state police departments. Flock cameras are hackable and portal access credentials have even been found on the dark web. Our data is not being protected!
The city is responsible for these unconstitutional violations of data sharing on the dark web, with hackers and outside law enforcement, and rights violations against marginalized communities.
Cancel the Flock contract immediately, and offer public hearings to educate the community on the impact of this critical data security and civil rights issue.
Sincerely,
Cara Beban
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Outlook
FW: Agenda item 12c on the 9/22 agenda
From City Council <[email protected]>
Date Tue 9/22/2026 3:16 PM
To Eduardo Montesino <[email protected]>; Vanessa Quiroz <[email protected]>; Maria Orozco <[email protected]>; Kristal Salcido <[email protected]>; Casey Clark <[email protected]>; Jimmy Dutra <[email protected]>; Ari Parker <[email protected]>; cityclerk <[email protected]>
From: Stephanie Barron Lu <[email protected]>
Sent: Tuesday, September 22, 2026 3:16:05 PM (UTC-08:00) Pacific Time (US & Canada) To: citymanager <[email protected]>; City Council <[email protected]> Subject: RE: Agenda item 12c on the 9/22 agenda
You don't often get email from [email protected]. Learn why this is important Hello, my name is Stephanie Barron Lu,
I am grateful first and foremost for your service-- I do not envy the decisions you are charged with making, nor the responsibility to weigh out the very real implications positive and negative on the lives of your constituency.
I hope you receive this email and this comment with the concern, curiosity, and care with which it is being written. 🙏🏽💗
I would like to preface that my opposition to sustaining/expanding Flock contract doesn’t need to be a criticism of our local police departments. This doesn’t even need to be a moment of criticism towards this administration.
I am writing to request you eliminate Flock in our beautiful city of Watsonville, please do not sustain or expand upon the existing 37 cameras.
At the last city council meeting the argument for flock being approved was by stating that this would not harm undocumented or aspiring citizens and that they even pulled on our heart strings of “what if your child or your car were taken, wouldn’t you want every resource to get them back?”… As a mother I can tell you that the fact of where they are located doesn’t give me peace of mind, it shows me the inherently racist positioning points to our Latinx community being seen as needing to be monitored and surveilled.
Facts; there are no flock cameras in Scotts Valley, no flock cameras in Santa Cruz now that Santa Cruz City Council voted them out, and around 10 cameras in Capitola with many pointed just directly into the Home Depot parking lot…
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Flock is a system of surveillance that has been shown to be used to target and harass people, and has been used by not only ICE but also by just any hacker that manages onto this system. Regardless of the abuses of power that have been documented by police officers, these systems have no local ownership-- the very premise of an effective flock system is for the use of outside agencies to coordinate with one another accessing sensitive data without oversight. This is one genie that is not too late to put back in the bottle!
Santa Cruz City council members met with Flock representatives and were moved to vote for eliminating the contract altogether. We have an opportunity in Watsonville to eliminate flock and give Monterey County a leg to stand on.
I encourage you to see this as a moment where your voice, your vote can effectively “get the flock out of Watsonville”.
With heart,
Stephanie
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Outlook
FW: Public comment on agenda item 12 c
From City Council <[email protected]>
Date Tue 9/22/2026 3:21 PM
To Eduardo Montesino <[email protected]>; Vanessa Quiroz <[email protected]>; Maria Orozco <[email protected]>; Kristal Salcido <[email protected]>; Casey Clark <[email protected]>; Jimmy Dutra <[email protected]>; Ari Parker <[email protected]>; cityclerk <[email protected]>
________________________________________
From: Kathryn and Takashi Mizuno <[email protected]>
Sent: Tuesday, September 22, 2026 3:21:26 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council
Subject: Public comment on agenda item 12 c
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To members of the City Council
From Kathryn Mizuno, PVUSD teacher, retired
I am writing to ask the City of Watsonville to stop using invasive FLOCK cameras. I spoke up asking the City Council not to approve them when the issue first came up several months ago. Our Police Department made a presentation at that Council meeting explaining how useful these cameras are to them in solving crimes, and promising not to share the data from them. I said at the time, and it has become increasingly clear in the months since then, that the Police Department cannot control how the unscrupulous companies such as Palantir that control FLOCK are sharing the camera data indiscriminately.
In Watsonville we pride ourselves on protecting the most vulnerable among us. We must take the lead be following the example of countless communities throughout the USA that have cancelled their FLOCK accounts because it is clear they are placing all of us in danger — most especially our vulnerable immigrant community.
We are a sanctuary city. We must not use surveillance tools such as FLOCK. The good intentions of our Police Department are not a valid excuse. They cannot control how FLOCK data is shared.
WATSONVILLE MUST CANCEL ITS FLOCK SUBSCRIPTION!
Thank you,
Kathryn Mizuno
Retired PVUSD teacher
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Outlook
Public Comment in Opposition to Item 12c Flock Cameras
From Bernie Gomez <[email protected]>
Date Tue 9/22/2026 3:35 PM
To cityclerk <[email protected]>
You don't often get email from [email protected]. Learn why this is important Greetings,
I am writing you to express my opposition to any expansion, maintenance and renewal of these 37 Flock Cameras (according to the agenda report) that are currently being deployed in Watsonville.
The truth is we can’t afford to spend anymore public funds on technology that carries so much controversy especially when it’s been used to perpetuate anti-immigrant actions against people of all statuses. Just because it hasn’t happened here (the we know of) doesn’t mean that it won’t. We have seen in previous reporting that outside agencies have been given permission to scan, research and share data related to Watsonville. (And I say permission because they weren't deterred nor denyied.) Even when you’ve had a supposed policy by Flock that it didn’t allow such things. So someone is lying Them or You.
You have to really ask yourself is it ok to have 37 cameras in a small town where majority of its population is of color and of mixed status. Is it ok to see a predominately white city (Santa Cruz) cancel their contract and a predominantly brown city (Watsonville) want to expand? Im not race bating just making a clear observation.
Ask yourself why are there so many of these cameras focused in retail areas? Target shopping center alone has more than 6 why? I thought these were suppose to be located at entrances and exits of the city?
I would also encourage you to ask the police chief why is he lobbying the community to show up in support of this contract through social media platform Instagram? Is he using official influence to generate support for his agenda. Ethical or Unethical? That is an honest objective question.
We just can’t afford to allow the invasive apparatus continue to capture every single image of vehicle, faces, or other identifying markers of every person that drives by these cameras. That includes you too!
All that is happening is focusing on the problem but a true leader focuses on a solution. And camera surveillance is not a solution.
I believe we can make better use of any and all funds related to this contract and continue investing in the development of our community infrastructure, create positive youth development opportunities, chip away at deferred maintenance, or how about you use that $140k and support the hungry in our community. Help get the sick medicine? Clothing for kids? Material for students? 9/23/26, 12:01 PM Mail - cityclerk - Outlook
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Either way I appreciate your time and service in helping govern the city of Watsonville. Vote NO on Flock.
Thank you,
Bernard Gomez MILPA
--
9/23/26, 12:01 PM Mail - cityclerk - Outlook
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Outlook
FW: Public Comment - Agenda Item 12C
From City Council <[email protected]>
Date Tue 9/22/2026 4:52 PM
To Eduardo Montesino <[email protected]>; Vanessa Quiroz <[email protected]>; Maria Orozco <[email protected]>; Kristal Salcido <[email protected]>; Casey Clark <[email protected]>; Jimmy Dutra <[email protected]>; Ari Parker <[email protected]>; cityclerk <[email protected]>
From: FRANK PATITUCCI <[email protected]>
Sent: Tuesday, September 22, 2026 4:52:07 PM (UTC-08:00) Pacific Time (US & Canada) To: City Council <[email protected]>
Cc: Shirley Dinkins <[email protected]>
Subject: Public Comment - Agenda Item 12C
You don't often get email from [email protected]. Learn why this is important Greetings,
We would like to express our very strong support for removing and disabling the Flock camera system from the streets of Watsonville. We believe that this kind of surveillance is a direct violation of every citizen's right to privacy. Whatever benefit there might be from these kind of systems is greatly offset by the potential for misuse and abuse of the information collected.
Please make Watsonville a city that protects each individual's right to privacy.
We look forward to your decision.
Thank you,
Shirley Dinkins
Frank Patitucci
9/23/26, 12:04 PM Mail - cityclerk - Outlook
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The Truth about Flock ALPR Cameras
Flock ALPR cameras are marketed as a tool that makes communities safer, yet a closer look reveals the alarming truth
What Flock says ... What the record shows ... Sources
"We don't share with ICE" Flock ran pilot programs with CBP • b1tps;lla12 ews,QQmLac:tiQleLirn and HSI. 4,000+ immigration migrntiQ -bQrdec-patcQl-suD!ei lookups found nationwide that we llance-drivers-ice-trumi;2-9f5d0 know of. 5469ce8c629d6fecf32d32098
cd
WPD shares our data with 312 • htt1;1s://www.404media.co/ice-t outside agencies they don't a1;1s-into-nationwide-ai-enable control. For example, El Cajon, d-Qamern- etwQc~-data-sbQW CA, which shares ALPR data with ~
ICE and is being sued by the CA • htti;2s:LLcalmatters.org/econom Office of the Attorney General. y/technology/2025/06/californi a-i;2olice-sharing-license-i;2late
WPD Policy 470.4 states they can -reader-data/
share our data for purposes of • htt1;1s://transgarency. flocksafet "homeland security". y_.com/watsonville-ca-gd
• htti;2s:/LQag,ca,gQv/news/i;2ress
The response provided by City of -relegses.lgttorney-genergl-bo Watsonville, PRA Request nta-continues-legal-challenge
#25-395 shows WPD data being -stoi;2-el-cajon-illegally-sharing shared through other PDs to
federal agencies such as HSI
(Division of ICE), ATF, and
Customs and Border Patrol
"Customers are in control of In Mountain View, CA, Illinois, • htti;2s://www,ktvu.comLnewsLm cameras and data sharing" Massachusetts, federal agencies ountain-view-joins-growing-lis were granted access to data t-cities-dumi;2ing-flock-safety-c without consent of the local police ameras
department and often in violation • httgs://www.ilsos.gov/news/20 of State law. 25/august-25-2025-giannoulia
s-audit-finds-license-glate-rea
Cambridge, MA: Contract deC QQmpa Y..-i -YiQlatiQ -Qf-st terminated for "breach of trust" - ate-law.html
cameras installed after council • httgs://data.aclum.org/2025/1 ordered deactivation. 0/07 /flock-g ives-law-enforcem
ent-all-over-the-count[Y..-acces
s-to-y_o u r-location/
• httgs://www.thecrimson.com/a
cticleL2Q25L:l 2Lj QLcambcidge-e
nds-flock-QQntractL
"Devices and data are secure" There are 51 security findings and • htti;2s://www.wy_den.senate.go 22 confirmed vulnerabilities of the v/imo/media/doc/wy_den letter Flock system. Condor cameras to ftc on flockgdf.gdf
were found online with no • httgs://github.com/GainSec/a password. nti-crime-ecosy_stem-research
lblQblmai LwbitepapeclGai S
WPD Policy 470.6 says they store ec Wbitepapec AotiCcimeEQ
our data for a minimum of one osystem.pdf
year. Even Flock has reduced their • https://www.watsonville.gov/1 recommendation from 30 days to 865/Policy-and-Training#doca 7 days for data storage. QQess-2Qa15Qd2QZ89Z1a69db
1 fce93144a 184
"ALPR cameras reduce crime" Statistical analyses have not • httgs://www.ktvu.com/news/more shown large sustained -lic~n§~-glat~-(~~d~r§-m~-i;;Qmin improvements in crime rates g-to-ba~-area-but-do-tbe~-wor~ • httgs://link.sgringer.com/article/1
0.1007ls11292-021-09473-~
• bttps :llwww, forbes ,Qornlsit~sl!:.~r
usfarivar/2024/02/29/flock-ai-ca
meras-ma~-not-reduce-crimeL?s
b=6djb582Qjd6d
"Officers only have access to still Flock FreeForm: product • https:[Lpatents.google.comlpa images of vehicle license plates, searches for people by physical tent/US 11416545B 1 not vehicle occupants" description. The platform is • https://www.flocksafety.com/p designed to go far beyond still roducts/gunshot-detection images of plates.
Raven: gunshot mies now
detecting "human voices."
"You have nothing to worry about The Flock surveillance system • https :LL reason .coml2026l08l1 if you are not committing crimes" allows officers to add vehicles to 3/flock-cameras-and-license- "Hotlists", resulting in innocent plate-readers-are-everywhere people across the US being -can-we-trust-cops-with-them/ • https://www.404media.co/lapd arrested, criminalized, and thrown -regularly-pulled-over-innocen in jail due to inaccurate or t-1,2eQ1,2le-beQause-liQe se-1.2lat outdated Hotlist tags. LAPD e-readers-flagged-their-cars-a cancelled Flock after internal s-stolen/
audits found "Hotlist Hits" were • https://transparency. flocksafet inaccurate and resulted in y.com/watsonville-ca-pd
innocent individuals being tracked. • https://www.watsonville.gov/1 865/Policy-and-Training#doca
QQeSS-2Qa15Qd2QZ89Z1a69db WPD also has a high number of 1 fQe93144a 184 "Hotlist Hits" (over 6k in the past
30 days).
WPD Policy 470.S(b) states users
don't even need "reasonable
I suspicion" or "probable cause" to
use ALPRs.
Watsonville Police Department
Watsonville PD Policy Manual
470 -Automated license plate readers (ALPRs)
470.1 - 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. 470.2 - Policy
The policy of the Watsonville Police Department is to utilize ALPR technology to capture and store digital license plate data and images while recognizing the established privacy rights of the public.
All data and images gathered by the ALPR are for the official use of this department. Because such data may contain confidential information, it is not open to public review.
The Watsonville Police Department does not permit the sharing of ALPR data gathered by the City or its contractors/subcontractors 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).
470.3 - Policy
The policy of the Watsonville Police Department is to utilize ALPR technology to capture and store digital license plate data and images while recognizing the established privacy rights of the public.
All data and images gathered by the ALPR are for the official use of this department. Because such data may contain confidential information, it is not open to public review. 470.4 - Administration
The ALPR technology, also known as License Plate Recognition (LPR), allows for the automated detection of license plates. It is used by the Watsonville Police Department 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 Field Operations Captain. The Field Operations Captain will assign Department members to administer the day-to-day operation of the ALPR equipment and data.
All data collected by ALPR technology is downloaded to a CJIS compliant cloud-based server. 4 70.4.1 - ALPR administrator
The Field Operations Captain 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 Page 571 of 716 (Civil Code § 1798.90.51; Civil Code § 1798.90.53):
Copyright Lexipol, LLC 2026/08/20, All Rights Reserved.
Published with permission by Watsonville Police Department Watsonville Police Department
Watsonville PD Policy Manual
Automated License Plate Readers (ALPRs)
(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 department's website.
470.5 - Operations
Use of an ALPR is restricted to the purposes outlined below. Department 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. (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. (d) No member of this department shall operate ALPR equipment or access ALPR data without first completing department-approved training.
( e) No ALPR operator may access department, state or federal data unless otherwise authorized to doso.
(f) The officer shall verify an ALPR response through the California Law Enforcement Telecommunications System (CLETS) before taking enforcement action that is based solely on an ALPR alert.
470.6 - Data collection and retention
The Field Operations Captain is responsible for ensuring systems and processes are in place for the proper collection and retention of ALPR data. Data will be transferred from vehicles to the designated storage in accordance with department procedures.
All ALPR data downloaded to the server should be stored for a minimum of one year and in accordance with the established records retention schedule. Thereafter, ALPR data should be Copyright Lexipol, LLC 2026/08/20, All Rights Reserved.
Published with permission by Watsonville Police Department 470.7 - Accountability
Watsonville Police Department
Watsonville PD Policy Manual
All data will be closely safeguarded and protected by both procedural and technological means. The Watsonville Police Department 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).
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 department-related civil or administrative action. c. ALPR system audits should be conducted monthly.
d. Every ALPR Detection Browsing Inquiry must be documented by either the CAD Incident Details Report number and/or Watsonville Police case number and a reason for search.
For security or data breaches, see the Records Release and Maintenance Policy. 470.8 - Releasing ALPR data
The ALPR data may be shared only with public agencies and only as otherwise permitted by law (Civil Code § 1798.90.55).
For purposes of this section, a public agency is limited to California state or local agencies, including law enforcement agencies, and does not include out-of-state or federal law enforcement agencies (Civil Code § 1798.90.5).
The following procedures are guidelines for ALPR requests:
a. The agency makes a request for the ALPR data.
b. The request is reviewed by the Field Operations Captain or the authorized designee and approved before the request is fulfilled.
Copyright Lexipol, LLC 2026/08/20, All Rights Reserved.
Published with permission by Watsonville Police Department Automated License Plate Readers (ALPRs) -
Watsonville Police Department
Watsonville PD Policy Manual
Automated License Plate Readers (ALPRs)
Requests for ALPR data by non-California public agencies will be processed as provided in the Records Maintenance and Release Policy (Civil Code § 1798.90.55). 470.9 - ALPR data detection browsing audits
It is the responsibility of the Field Operations Captain or the Chiefs designee to ensure that an audit is conducted of ALPR detection browsing inquiries at least once during each month. The Department will audit a sampling of the ALPR system utilization from the prior month period to verify proper use in accordance with the above-authorized uses.
470.10 - Training
The Field Operations Captain should ensure that members receive department-approved training for those authorized to use or access the ALPR system (Civil Code § 1798.90.51; Civil Code § 1798.90.53).
Copyright Lexipol, LLC 2026/08/20, All Rights
Reserved.
Published with permission by Watsonville Police
Department
Automated License Plate Readers (ALPRs)
- 475
9/21/26, 10:18AM Flock Safety - Watsonville CA PD Transparency Portal 0 Last updated: Mon Sep 21 2026
Overview
Watsonville CA PD uses Flock Safety technology to capture objective evidence without compromising on individual privacy. Watsonville CA PD utilizes retroactive search to solve crimes after they've occurred. Additionally, Watsonville CA PD utilizes real time alerting of hotlist vehicles to capture wanted criminals. In an effort to ensure proper usage and guardrails are in place, they have made the below policies and usage statistics available to the public.
Community Impact
Data & Usage Summary
Data Retention
The number of days data is retained.
30 days
https://transparency.flocksafety.com/watsonville-ca-pd 1/4
9/21/26, 10:18AM Flock Safety - Watsonville CA PD Transparency Portal Total Cameras
Number of LPR and other cameras.
33 Vehicles detected in the last 30 days
Number of unique plate reads over the last 30 days.
325,654
Number of Searches
Total user search sessions over the last 30 days.
171
Number of Hotlist Hits
Total hotlist hits over the last 30 days.
5,978
Sharing Network Data With
Organizations granted access to Watsonville CA PD data.
Visit Flock
https://transparency.flocksafety.com/watsonville-ca-pd 2/4
' . 9/21/26, 10:18AM Flock Safety - Watsonville CA PD Transparency Portal Downey PD CA Dublin CA PD (ACSO)
East Bay Parks CA PD East Palo Alto CA PD
El Cajon CA PD El Centro CA PD
1 El Dorado County CA SO El Monte CA PD
l
El Segundo CA PD Elk Grove CA PD
Poiicy & rust
What's Detected
License Plates, Vehicles
What's Not Detected
Facial recognition, People, Gender, Race
Acceptable Use Policy
Data is used for law enforcement purposes only. Data is owned by Watsonville CA PD and is never sold to 3rd parties.
Prohibited Uses
Immigration enforcement, traffic enforcement, harrassment or intimidation, usage based solely on a protected class (i.e. race, sex, religion), Personal use. https://transparency.flocksafety.com/watsonville-ca-pd 3/4
9/21/26, 10:18AM Flock Safety - Watsonville CA PD Transparency Portal Access Policy
All system access requires a valid reason and is stored indefinitely.
Hotlist Policy
Hotlist hits are required to be human verified prior to action.
Provided by Flock Safety
https://transparency.flocksafety.com/watsonville-ca-pd 4/4
, 9/21/.26, 10:19AM , Attorney General Banta Continues Legal Challenge to Stop El Cajon from Illegally Sharing License Plate Data I State of California ... ng§I Subscribe to Our Newsletter
ROB BONTA
Attorney General
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Attorney General Bonta Continues Legal
Challenge to Stop El Cajon from Illegally
Sharing License Plate Data
Press Release I Attorney General Bonta Continues Legal Challenge to Stop El ...
Wednesday, January 21, 2026
Contact: (916) 210-6000, [email protected]
OAKLAND - California Attorney General Rob Bonta today filed a motion in California v.
City of El Cajon as part of his continued effort to vindicate the privacy rights of Californians and enforce California law. On October 3, 2025, Attorney General Bonta filed a lawsuit against the City of El Cajon over its refusal to comply with state law by sharing data pulled from Automated License Plate Reader (ALPR) systems with over 100 out-ofstate law enforcement agencies. California law prohibits local law enforcement entities from sharing ALPR data with federal and out-of-state agencies. Despite clear guidance and multiple warnings, the City of El Cajon Police Department continues to share this sensitive data nationwide. As a result, Attorney General Bonta is asking the San Diego County Superior Court to declare these actions unlawful and compel El Cajon to follow state law and perform its duty of protecting sensitive ALPR data and the privacy rights of Californians.
https://oag.ca.gov/news/press-releases/attorney-general-bonta-continues-legal-challenge-stop-el-cajon-illegally-sharing 1/3
9/21/26, 10:19AM Attorney General Sonia Continues Legal Challenge to Stop El Cajon from Illegally Sharing License Plate Data I State of California ... "At a time when personal data is treated like gold, we need to ensure that state and local agencies are doing their part to protect it," said Attorney General Bonta. "As the Trump Administration continues to target Americans' private and sensitive data to use beyond its intended purpose, it is important that we maintain safeguards to ensure this technology is used appropriately and lawfully. California law requires ALPR data to remain within state lines. With this latest action, I'm asking the court to immediately halt the sharing of license plate data and keep El Cajon from jeopardizing the privacy and safety of Californians."
ALPR technology uses computer-controlled camera systems mounted at various locations, including streetlights and freeway overpasses, to scan all license plate numbers that come into view. The data collected through these systems reveal the individual movements of California residents, including their driving patterns and locations of residences, places of worship, workplaces, medical providers, and schools. Sharing this data with out-of-state agencies is a violation of California law that requires California law enforcement agencies that collect ALPR data to only share that data with California public agencies. Moreover, once data is shared with out-of-state agencies and no longer subject to California privacy protections, it can then be shared with federal agencies in further violation of California law.
In October 2023, Attorney General Bonta issued a law enforcement bulletin providing guidance and model policies regarding the use of data collected or accessed through an ALPR system. The bulletin advised that ALPR data can only be shared with "public agencies," and that the term "public agency," as defined in state law, does not include out-of-state and federal agencies. After learning that the City of El Cajon was sharing ALPR data with numerous out-of-state law enforcement agencies, the Attorney General contacted the El Cajon Police Chief regarding the limitations on ALPR https://oag.ca.gov/news/press-releases/attorney-general-bonta-continues-legal-challenge-stop-el-cajon-illegally-sharing 2/3
,, 9/21/?..p, 10:19 AM Attorney General Banta Continues Legal Challenge to Stop El Cajon from Illegally Sharing License Plate Data I State of California ... data-sharing in state law. Despite this and subsequent outreach, the El Cajon Police Department and the City of El Cajon have refused to cease the unlawful practice of sharing ALPR data with out-of-state agencies.
To protect Californians' private data, Attorney General Bonta requests that the San Diego County Superior Court issue a writ of mandamus ordering the City of El Cajon, the El Cajon Police Department, and Chief Jeremiah Larson to follow California law and to cease sharing ALPR data with out-of-state public agencies. Attorney General Bonta further requests declaratory and injunctive relief.
###
Office of the Attorney General Accessibility Privacy Policy Conditions of Use Disclaimer © 2026 DOJ
https://oag.ca.gov/news/press-releases/attorney-general-bonta-continues-legal-challenge-stop-el-cajon-illegally-sharing 3/3
'9/22/26, 1 1 :37 AM Mountain View joins growing list of cities dumping Flock Safety cameras I KTVU FOX 2 Watch Live
Mountain View joins growing list of cities dumpin!
Flock Safety cameras
By Tori Gaines KTVU FOX 2 News Published February 25, 2026 11 :08 PM PST Mountain View joins growing list of cities dumping Flock Safety cameras The Mountain View City Council voted unanimously to end the city's contract w Flock Safety for automated license plate reading cameras on Tuesday.
The Brief
• The City of Mountain View has ended its contract with Flock Safety. • The County of Santa Clara Board of Supervisors voted to end the county's use of Flock Safety data.
• The Santa Clara County Sheriff's Office says it has never shared county data with feder agencies.
https://www.ktvu.com/news/mountain-view-joins-growing-list-cities-dumping-flock-safety-cameras 1/4
9/22/26, 11 :37 AM Mountain View joins growing list of cities dumping Flock Safety cameras I KTVU FOX 2 MOUNTAIN VIEW, Calif. - The Mountain View City Council voted unanimously end the city's contract with Flock Safety for automated license plate reading cameras on Tuesday. Mountain View now joins a growing list of cities that have ended contracts with or sued Flock Safety over data privacy concerns.
Earlier this month, the Mountain View Chief of Police Mike Canfield informed residents that federal agencies had accessed the city's ALPR data against the city's policies.
"If we were going to use a tool, the goal of that tool is to benefit our communit1 and not cause harm. So this is why we moved so fast," Mountain View Mayor Emily Ann Ramos told KTVU.
Flock Safety's automated license plate readers have been a helpful tool for Bay Area law enforcement agencies, often aiding in criminal arrests and the recove of stolen property.
But when Canfield learned out-of-state agencies had accessed data from their cameras, without the city's awareness or permission, he turned them off. "I'm so happy that the chief took it upon himself to pause it. He didn't have the authority to cancel the contract without council, so he had to pause it," Ramos said.
Flock has previously said it does not share data with federal agencies unless authorized.
What they're saying:
The County of Santa Clara also took notice. Santa Clara County Supervisor Betty Duong says her county can't risk working with a vendor that cannot protect its data.
https://www.ktvu.com/news/mountain-view-joins-growing-list-cities-dumping-flock-safety-cameras 2/4
.9/22/26, 41 :37 AM Mountain View joins growing list of cities dumping Flock Safety cameras I KTVU FOX 2 11Until they get their situation right, I cannot, in good conscience, allow our cour to be involved or engaged with a vendor that is so problematic right now," Duo told KTVU.
The Santa Clara County Board of Supervisors voted 3-2 to end the county's access to Flock Safety cameras and their data. As of that vote, the Santa Clara County Sheriffs Office wi ll no longer have access to the ALPR data either.
The sheriff's office confirmed to KTVU that it has not shared any county data wi federal agencies, but it still supports the "responsible deployment" of ALPR tee "License plate readers help us solve violent crimes and keep our neighbors saf Sheriff RobertJonsen said. 11The results speak for themselves. 11 Supervisor Duong says she wants her residents to be a part of shaping the use Al and ALPR tech, perhaps with another vendor.
11Without local government's voice, without the residents' voice, there would be one creating policies around usage and best practices for these things," Duong told KTVU.
But city leadership in Mountain View says new surveillance tech isn't coming th city's way any time soon.
11This was such a big breach of trust for our community. It's gonna take some ti1 for our community to rebuild that trust altogether with any kind of technology,' Ramos said.
Some cities in the county still have contracts with Flock Safety, and Supervisor Duong says, if they choose to move to new vendors, the county will reassess Al usage at that time.
https://www.ktvu.com/news/mountain-view-joins-growing-list-cities-dumping-flock-safety-cameras 3/4
ILLINOIS SECRETARY of_ STATE
ALEXI GIANNOULIAS
Home > > 2025 News > Giannoulias' Audit Finds License Plate Reader Company in Violation of State Law August 25, 2025
Giannoulias' Audit finds License Plate
Reader Company in Violation of State
Law
Flock Safety Shared Illinois Data with U.S. Customs and Border Protection Secretary Orders Flock to Shut off Data Access
e Holding Flock Accountable Illinois Secretary of State [cc]
0:02 1 '$4
Secretary of State Alexi Giannoulias' office recently discovered that U.S. Customs and Border Protection gained access to Illinois license plate camera data-a violation of state law his office initiated.
During a recent audit, Giannoulias' office found that Flock Safety, which operates the largest automated license plate reader (ALPR) system in the nation, allowed U.S. Customs and Border Protection to access Illinois license plate cameras on Illinois roads and surveil drivers. As a result, Giannoulias immediately ordered the company to shut off access to U.S. Customs and Border Protection. "This sharing of license plate data of motorists who drive on Illinois roads is a clear violation of the state law. This law passed two years ago aimed to strengthen how data is shared and prevent this exact thing from happening," Giannoulias said. "I take my responsibility as Secretary of State seriously. It's why we spearheaded this legislation, which now gives us the tools needed to hold Flock accountable for its actions."
1/2
In June, the Secretary of State's office announced it would conduct a sample audit of Flock Safety data sharing with local law enforcement.
As a result of the sample audit that included a sampling of 12 local law enforcement agencies, the office discovered late last week that Flock did not have proper safeguards in place for data sharing, which was compounded by the fact that the company was running a pilot program with U.S. Customs and Border Protection, which Flock leadership was unaware of. This was uncovered as part of the Secretary of State's audit, and Flock has also since paused its pilot with CBP and other federal agencies, not only in Illinois but nationwide.
In addition, Giannoulias called on local police departments to re-examine their agreements with Flock and what access they grant law enforcement to their ALPR cameras to ensure they do not violate the state's Trust Act, which restricts local law enforcement in Illinois with collaborating with federal authorities - including ICE-on immigration enforcement without a court warrant.
The revelation comes just two months after Giannoulias ordered Flock to block outside law enforcement from seeking Illinois data related to abortion and immigration, according to a state law he spearheaded that was enacted two years ago.
Back to Top ©
2/2
9/21/26, 10:14 AM Border Patrol monitors US drivers and detains Americans for 'suspicious' travel I AP News The U.S. Border Patrol is monitoring millions of American drivers nationwide in a secretive program to identify and detain people whose travel patterns it deems suspicious. (AP virten· M,rshall Rit,el\ Read More BY filllQlillllAND GARANCE BURKE
Updated 1:27 PM PDT, November 20, 2025
~l!aii21
The U S Border Patrol is monitoring millions of American drivers nationwide in a secretive program to identify and detain people whose travel patterns it deems suspicious, The Associated Press has found.
The predictive intelligence program has resulted in people being stopped, searched and in some cases arrested. A network of cameras scans and records vehicle license plate information, and an algorithm flags vehicles deemed suspicious based on where they came from, where they were going and which route they took. Federal agents in turn may then flag local law enforcement.
Suddenly, drivers find themselves pulled over - often for reasons cited such as speeding, failure to signal, the wrong window tint or even a dangling air freshener blocking the view. They are then aggressively questioned and searched, with no inkling that the roads they drove put them on law enforcement's radar.
Once limited to policing the nation's boundaries, the Border Patrol has built a surveillance system stretching into the country's interior that can monitor ordinary Americans' daily actions and connections for anomalies instead of simply targeting wanted suspects. Started about a decade ago to fight illegal border-related activities and the trafficking of both drugs and people, it has expanded over the past five years. https://apnews.com/article/immigration-border-patrol-surveillance-drivers-ice-trump-9f5d05469ce8c629d6fecf32d32098cd 1/15
9/21/26, 10:14AM Border Patrol monitors US drivers and detains Americans for 'suspicious' travel I AP News The Border Patrol has recently grown even more powerful through collaborations with other agencies, drawing information from license plate readers nationwide run by the Qrug Enforcement Admjnjstratjon. private companies and, increasingly, local law enforcement programs funded through federal grants. Texas law enforcement agencies have asked Border Patrol to use facial recognition to identify drivers, documents show.
This active role beyond the borders is part of the quiet transformation of its parent agency, US Customs and Border Protection, into something more akin to a domestic intelligence operation. Under the Trump administration's heightened immigration enforcement efforts, CBP is now poised to get more than $2.7 billion to build out border surveillance systems such as the license plate reader program by layering in artificial intelligence and other emerging technologies.
The result is a mass surveillance network with a particularly American focus: cars.
This investigation, the first to reveal details of how the program works on America's roads, is based on interviews with eight former government officials with direct knowledge of the program who spoke on the condition of anonymity because they weren't authorized to speak to the media, as well as dozens of federal, state and local officials, attorneys and privacy experts. The AP also reviewed thousands of pages of court and government documents, state grant and law enforcement data, and arrest reports.
The Border Patrol has for years hidden details of its license plate reader program, trying to keep any mention of the program out of court documents and police reports, former officials say, even going so far as to propose dropping charges rather than risk revealing any details about the placement and use of their covert license plate readers. Readers are often disguised along highways in traffic safety equipment like drums and barrels.
The Border Patrol has defined its own criteria for which drivers' behavior should be deemed suspicious or tied to drug or human trafficking, stopping people for anything from driving on backcountry roads, being in a rental car or making short trips to the border region. The agency's network of cameras now extends along the southern border in Texas, Arizona and California, and also monitors drivers traveling near the U.S.-Canada border.
And it reaches far into the interior, impacting residents of big metropolitan areas and people driving to and from large cities such as Chicago and Detroit, as well as from Los Angeles, San Antonio, and Houston to and from the Mexican border region. In one example, AP found the agency has placed at least four cameras in the greater Phoenix area over the years, one of which was more than 120 miles (193 kilometers) from the Mexican frontier, beyond the agency's usual jurisdiction of 100 miles (161 kilometers) from a land or sea border. The AP also identified several camera locations in metropolitan Detroit, as well as one placed near the Michigan-Indiana border to capture traffic headed towards Chicago or Gary, Indiana, or other nearby destinations.
https://apnews.com/article/immigration-border-patrol-surveillance-drivers-ice-trump-9f5d05469ce8c629d6fecf32d32098cd 2/15
9/21/26, 10:14AM Border Patrol monitors US drivers and detains Americans for 'suspicious' travel I AP News A license plate reader used by U.S. Border Patrol is hidden in a traffic cone while capturing passing vehicles on AZ Highway B5, Tuesday, Oct. 21, 2025, in Gila Bend, Ariz. (AP Photo/Ross D. Franklin) License this P.hoto Read More Border Patrol's parent agency, U.S. Customs and Border Protection, said they use license plate readers to help identify threats and disrupt criminal networks and are "governed by a stringent, multi-layered policy framework, as well as federal law and constitutional protections, to ensure the technology is applied responsibly and for clearly defined security purposes." "For national security reasons, we do not detail the specific operational applications," the agency said. While the U.S. Border Patrol primarily operates within 100 miles of the border, it is legally allowed "to operate anywhere in the United States," the agency added.
While collecting license plates from cars on public roads has generally been upheld by courts, some legal scholars see the growth of large digital surveillance networks such as Border Patrol's as raising constitutional questions. Courts have started to recognize that "large-scale surveillance technology that's capturing everyone and everywhere at every time" might be unconstitutional under the Fourth Amendment, which protects people from unreasonable searches, said Andrew Ferguson, a law professor at George Washington University.
Today, predictive surveillance is embedded into America's roadways. Mass surveillance techniques are also used in a range of other countries, from authoritarian governments such as China to, increasingly, democracies in the U.K. and Europe in the name of national security and public safety. "They are collecting mass amounts of information about who people are, where they go, what they do, and who they know ... engaging in dragnet surveillance of Americans on the streets, on the highways, in their cities, in their communities," Nicole Ozer, the executive director of the Center for Constitutional Democracy at UC Law San Francisco, said in response to the AP's findings. "These surveillance systems do not make communities safer."
'We did everything right and had nothing to hide'
https://apnews.com/article/immigration-border-patrol-surveillance-drivers-ice-trump-9f5d05469ce8c629d6fecf32d32098cd 3/15
9/21/26, 10:14 AM Border Patrol monitors US drivers and detains Americans for 'suspicious' travel I AP News A license plate reader stands along the side of a road, Wednesday, Oct.15, 2025, in Stockdale, Texas. (AP Photo/David Goldm,11, Read More In February, Lorenzo Gutierrez Lugo, a driver for a small trucking company that specializes in transporting furniture, clothing and other belongings to families in Mexico, was driving south to the border city of Brownsville, Texas, carrying packages from immigrant communities in South Carolina's low country.
Gutierrez Lugo was pulled over by a local police officer in Kingsville, a small Texas city near Corpus Christi that lies about 100 miles from the Mexican border. The officer, Richard Beltran, cited the truck's speed of 50 mph (80 kph) in a 45 mph (72 kph) zone as the reason for the stop.
But speeding was a pretext: Border Patrol had requested the stop and said the black Dodge pickup with a white trailer could contain contraband, according to police and court records. U.S. Route 77 passes through Kingsville, a route that state and federal authorities scrutinize for trafficking of drugs, money and people.
Gutierrez Lugo, who through a lawyer declined to comment, was interrogated about the route he drove, based on license plate reader data, per the police report and court records. He consented to a search of his car by Beltran and Border Patrol agents, who eventually arrived to assist.
Image recognition analysis overlaid on drivers and vehicles on Texas roads. (AP video Marshall Ritzel) https://apnews.com/article/immigration-border-patrol-surveillance-drivers-ice-trump-9f5d05469ce8c629d6fecf32d32098cd 4/15
9/21/26, 10:14 AM Border Patrol monitors US drivers and detains Americans for 'suspicious' travel I AP News They unearthed no contraband. But Beltran arrested Gutierrez Lugo on suspicion of money laundering and engaging in organized criminal activity because he was carrying thousands of dollars in cash - money his supervisor said came directly from customers in local Latino communities, who are accustomed to paying in cash. No criminal charges were ultimately brought against Gutierrez Lugo and an effort by prosecutors to seize the cash, vehicle and trailer as contraband was eventually dropped.
Luis Barrios owns the trucking company, Paqueteria El Guero, that employed the driver. He told AP he hires people with work authorization in the United States and was taken aback by the treatment of his employee and his trailer.
"We did everything right and had nothing to hide, and that was ultimately what they found," said Barrios, who estimates he spent $20,000 in legal fees to clear his driver's name and get the trailer out of impound.
Border Patrol agents and local police have many names for these kinds of stops: "whisper," "intel" or "wall" stops. Those stops are meant to conceal - or wall off - that the true reason for the stop is a tip from federal agents sitting miles away, watching data feeds showing who's traveling on America's roads and predicting who is "suspicious," according to documents and people interviewed by the AP.
In 2022, a man from Houston had his car searched from top to bottom by Texas sheriff's deputies outside San Antonio after they got a similar tipoff from Border Patrol agents about the driver, Alek Schott.
Alek Schott stands next to a Flock Safety license plate reader in his neighborhood, Thursday, Oct. 16, 2025, in Houston. (AP Photo/David Goldman) license this p.l!Q!Q Read More
Federal agents observed that Schott had made an overnight trip from Houston to Carrizo Springs, Texas, and back, court records show. They knew he stayed overnight in a hotel about 80 miles (129 kilometers) from the U.S.- Mexico border. They knew that in the morning Schott met a female colleague there before they drove together to a business meeting.
At Border Patrol's request, Schott was pulled over by Bexar County sheriff's deputies. The deputies held Schott by the side of the road for more than an hour, searched his car and found nothing. "The beautiful thing about the Texas Traffic Code is there's thousands of things you can stop a vehicle for," said Joel Babb, the sheriff's deputy who stopped Schott's car, in a deposition in a lawsuit Schott f iled alleging violations of his constitutional rights.
https:l/apnews.com/article/immigration-border-patrol-surveillance-drivers-ice-trump-9f5d05469ce8c629d6fecf32d32098cd 5/15
9/21/26, 10:14 AM Border Patrol monitors US drivers and detains Americans for 'suspicious' travel I AP News Alek Schott watches police body camera video of his vehicle search, Thursday, Oct.16, 2025, while sitting at his home in Houston. (AP Photo/David Goldman) License this AMl!l Read More
According to testimony and documents released as part of Schott's lawsuit, Babb was on a group chat with federal agents called Northwest Highway. Babb deleted the WhatsApp chat off his phone but Schott's lawyers were able to recover some of the text messages.
Through a public records act request, the AP also obtained more than 70 pages of the Northwest Highway group chats from June and July of this year from a Texas county that had at least one sheriff's deputy active in the chat. The AP was able to associate numerous phone numbers in both sets of documents with Border Patrol agents and Texas law enforcement officials.
The chat logs show Border Patrol agents and Texas sheriffs deputies trading tips about vehicles' travel patterns - based on suspicions about little more than someone taking a quick trip to the border region and back. The chats show how thoroughly Texas highways are surveilled by this federal-local partnership and how much detailed information is informally shared.
In one exchange a law enforcement official included a photo of someone's driver's license and told the group the person, who they identified using an abbreviation for someone in the country illegally, was headed westbound. "Need BP?," responded a group member whose number was labeled "bp Intel." "Yes sir," the official answered, and a Border Patrol agent was en route.
Border Patrol agents and local law enforcement shared information about U.S. citizens' social media profiles and home addresses with each other after stopping them on the road. Chats show Border Patrol was also able to determine whether vehicles were rentals and whether drivers worked for rideshare services. https://apnews.com/article/immigration-border-patrol-surveillance-drivers-ice-trump-9f5d05469ce8c629d6fecf32d32098cd 6/15
9/21/26, 10:14AM Border Patrol monitors US drivers and detains Americans for 'suspicious' travel I AP News Alek Schott sits for a photo in his car near a route he occasionally takes for work trips Wednesday, Oct. 15, 2025, in Stockdale, Texas. (AP Photo/David Goldman) ~p.!!Ql2 Read More
In Schott's case, Babb testified that federal agents "actually watch travel patterns on the highway" through license plate scans and other surveillance technologies. He added: "I just know that they have a lot of toys over there on the federal side."
After finding nothing in Schott's car, Babb said "nine times out of 10, this is what happens," a phrase Schott's lawyers claimed in court filings shows the sheriff's department finds nothing suspicious in most of its searches. Babb did not respond to multiple requests for comment from AP.
The Bexar County sheriff's office declined to comment due to pending litigation and referred all questions about the Schott case to the county's district attorney. The district attorney did not respond to a request for comment.
The case is pending in federal court in Texas. Schott said in an interview with the AP: "I didn't know it was illegal to drive in Texas."
'Patterns of life' and license plates
hltps://apnews.com/article/immigration-border-patrol-surveillance-drivers-ice-trump-9f5d05469ce8c629d6fecf32d32098cd 7/15
9/21/26, 10:14 AM Border Patrol monitors US drivers and detains Americans for 'suspicious' travel I AP News A license plate reader used by U.S. Border Patrol is hidden in a sand crash barrel along the state Highway 80, Thursday, Oct. 23, 2025, in Douglas, Ariz. (AP Photo/Ross D. Franklin) License this p.!m12 Read More
Today, the deserts, forests and mountains of the nation's land borders are dotted with checkpoints and increasingly, surveillance towers, Predator drones, thermal cameras and license plate readers, both covert and overt.
Border Patrol's parent agency got authorization to run a domestic license plate reader program in 2017, according to a .Qepartment of Homeland Securjty policy document. At the t ime, the agency said that it might use hidden license plate readers "for a set period of time while CBP is conducting an investigation of an area of interest or smuggling route. Once the investigation is complete, or the illicit activit y has stopped in that area, the covert cameras are removed," the document states.
But that's not how the program has operated in practice, according to interviews, police reports and court documents. License plate readers have become a major - and in some places permanent - fixture of the border region.
In a budget request to Congress in fiscal year 2024, CBP said that its Conveyance Monitoring and Predictive Recognition System, or CMPRS, "collects license plate images and matches the processed images against established hot lists to assist ... in identifying travel patterns indicative of illegal border related activities." Several new developer jobs have been posted seeking applicants to help modernize its license plate surveillance system in recent months. Numerous Border Patrol sectors now have special intelligence units that can analyze license plate reader data, and tie commercial license plate readers to its national network, according to documents and interviews.
https:l/apnews.com/article/immigration-border-patrol-surveillance-drivers-ice-trump-9f5d05469ce8c629d6fecf32d32098cd 8/15
9/21/26, 10:14 AM Border Patrol monitors US drivers and detains Americans for 'suspicious' travel I AP News A U.S. Border Patrol vehicle sits along the Rio Grande river across the border from Mexico, Tuesday, Oct. 14, 2025, in Laredo, Texas. {AP Photo/David Goldman) License this p.!!.fil!! Read More
Border Patrol worked with other law enforcement agencies in Southern California about a decade ago to develop pattern recognition, said a former CBP official who spoke on the condition of anonymity for fear of reprisal. Over time, the agency learned to develop what it calls "patterns of life" of vehicle movements by sifting through the license plate data and determining "abnormal" routes, evaluating if drivers were purposely avoiding official checkpoints. Some cameras can take photos of a vehicle's plates as well as its driver's face, the official said.
Another former Border Patrol official compared it to a more technologically sophisticated version of what agents used to do in the field - develop hunches based on experience about which vehicles or routes smugglers might use, find a legal basis for the stop like speeding and pull drivers over for questioning.
The cameras take pictures of vehicle license plates. Then, the photos are "read" by the system, which automatically detects and distills the images into numbers and letters, tied to a geographic location, former CBP officials said. The AP could not determine how precisely the system's algorithm defines a quick turnaround or an odd route. Over time, the agency has amassed databases replete with images of license plates, and the system's algorithm can flag an unusual "pattern of life" for human inspection. https://apnews.com/article/immigration-border-patrol-surveillance-drivers-ice-trump-9f5d05469ce8c629d6fecf32d32098cd 9/15
9/21/26, 10:14 AM Border Patrol monitors US drivers and detains Americans for 'suspicious' travel I AP News A remote camera hidden in an electrical box is used as surveillance technology, Tuesday, July 29, 2025, in Sierra Vista, A,, , Read More The Border Patrol also has access to a nationwide network of plate readers run by the Drug Enforcement Administration, documents show, and was authorized in 2020 to access license plate reader systems sold by private companies. In documents obtained by the AP, a Border Patrol official boasted about being able to see that a vehicle that had traveled to "Dallas, Little Rock, Arkansas and Atlanta" before ending up south of San Antonio.
Documents show that Border Patrol or CBP has in the past had access to data from at least three private sector vendors: Reker, Vigilant Solutions and Flock Safety.
Through Flock alone, Border Patrol for a time had access to at least 1,600 license plate readers across 22 states, and some counties have reported looking up license plates on behalf of CBP even in states like California and Illinois that ban sharing data with federal immigration authorities, according to an AP analysis of police disclosures. A Flock spokesperson told AP the company "for now" had paused jts Pil21.PJ:[email protected]. with CBP and a separate OHS agency, Homeland Security Investigations, and declined to discuss the type or volume of data shared with either federal agency, other than to say agencies could search for vehicles wanted in conjunction with a crime. No agencies currently list Border Patrol as receiving Flock data. Vigilant and Reker did not respond to requests for comment.
Also from AP's investigation into the use of surveillance technology:
• U.S. tech firms to a large degree d.e.s.igned and built China's surveillance state, playing a far greater role in enabling rights abuses than known before. • Across five Republican and Democratic administrat ions, the US, government has r.e~Y. allowed and even actively...h.elped American firms to sell technologY. to Chinese P.Qlic.e.
Where Border Patrol places its cameras is a closely guarded secret. However, through public records requests, the AP obtained dozens of permits the agency filed with Arizona and Michigan for permission to place cameras on state-owned land. The permits show the agency frequently disguises its cameras by concealing them in traffic equipment like the yellow and orange barrels that dot American roadways, or by labeling them as jobsite equipment. An AP photographer in October visited the locations identified in more https://apnews.com/article/immigration-border-patrol-surveillance-drivers-ice-trump-9f5d05469ce8c629d6fecf32d32098cd 10/15
9/21/26, 10:14 AM Border Patrol monitors US drivers and detains Americans for 'suspicious' travel I AP News than two dozen permit applications in Arizona, finding that most of the Border Patrol's hidden equipment remains in place today. Spokespeople for the Arizona and Michigan departments of transportation said they approve permits based on whether they follow state and federal rules and are not privy to details on how license plate readers are used.
Texas, California, and other border states did not provide documents in response to the AP's public records requests.
CBP's attorneys and personnel instructed local cities and counties in both Arizona and Texas to withhold records from the AP that might have revealed details about the program's operations, even though they were requested under state open records laws, according to emails and legal briefs filed with state governments.
For example, CBP claimed records requested by the AP in Texas "would permit private citizens to anticipate weaknesses in a police department, avoid detection, jeopardize officer safety, and generally undermine police efforts." Michigan redacted the exact locations of Border Patrol equipment, but the AP was able to determine general locations from the name of the county.
One page of the group chats obtained by the AP shows that a participant enabled WhatsApp's disappearing messages feature to ensure communications were deleted automatically.
Transformation of CBP into intelligence agency
A license plate reader used by U.S. Border Patrol sits along US Highway 191, Thursday, Oct. 23, 2025, in Douglas. Ariz. (AP Photo/Ross D. Franklin) ~P.hOtO Read More
The Border Patrol's license plate reader program is just one part of a steady transformation of its parent agency, CBP, in the years since 9/11 into an intelligence operation whose reach extends far beyond borders, according to interviews with former officials.
CBP has quietly amassed access to far more information from ports of entry, airports and intelligence centers than other local, state and federal law enforcement agencies. And like a domestic spy agency, CBP has mostly hidden its role in the dissemination of intelligence on purely domestic travel through its use of whisper stops.
Border Patrol has also extended the reach of its license plate surveillance program by paying for local law enforcement to run plate readers on their behalf.
https://apnews.com/article/immigration-border-patrol-surveillance-drivers-ice-trump-9f5d05469ce8c629d6fecf32d32098cd 11/15
9/21/26, 10:14 AM Border Patrol monitors US drivers and detains Americans for 'suspicious' travel I AP News Cochise County Sheriff's Deputy AJ Shaw drives during a patrol, Tuesday, June 17, 2025, in Naco, Ariz, (AP Photo/Ross D. Franklu Read More A federal grant program called Operation Stonegarden, which has existed in some form for nearly two decades, has handed out hundreds of millions of dollars to buy automated license plate readers, cameraequipped drones and other surveillance gear for local police and sheriffs agencies. Stonegarden grant funds also pay for local law enforcement overtime, which deputizes local officers to work on Border Patrol enforcement priorities. Under President Donald Trump, the Republican-led Congress this year allocated $450 million for Stonegarden to be handed out over the next four fiscal years. In the previous four fiscal years, the program gave out $342 million.
In Cochise County, Arizona, Sheriff Mark Dannels said Stonegarden grants, which have been used to buy plate readers and pay for overtime, have let his deputies merge their mission with Border Patrol's to prioritize border security.
"If we're sharing our authorities, we can put some consequences behind, or deterrence behind, 'Don't come here,'" he said.
In 2021, the Ward County, Texas, sheriff sought grant funding from DHS to buy a "covert, mobile, License Plate Reader" to pipe data to Border Patrol's Big Bend Sector Intelligence Unit. The sheriff's department did not respond to a request for comment.
Other documents AP obtained show that Border Patrol connects locally owned and operated license plate readers bought through Stonegarden grants to its computer systems, vastly increasing the federal agency's surveillance network.
https://apnews.com/article/immigration-border-patrol-surveillance-drivers-ice-trump-9f5d05469ce8c629d6fecf32d32098cd 12/15
9/21/26, 10:14 AM Border Patrol monitors US drivers and detains Americans for 'suspicious' travel I AP News Cochise County Sheriff Mark Dannels poses for a photograph, Tuesday, July 29, 2025, in Sierra Vista, Ariz. (AP Photo/Ross D. Frankh11) Read More How many people have been caught up in the Border Patrol's dragnet is unknown. One former Border Patrol agent who worked on the license plate reader pattern detection program in California said the program had an B5% success rate of discovering contraband once he learned to identify patterns that looked suspicious.
But another former official in a different Border Patrol sector said he was unaware of successful interdictions based solely on license plate patterns.
In Trump's second term, Border Patrol has extended its reach and power as border crossings have slowed to historic lows and freed up agents for operations in the heartland. Border Patrol Sector Chjef Gregory~. for example, was tapped to direct hundreds of agents from multiple OHS agencies in the administration's immigration sweeps across Los Angeles, more than 150 miles (241 kilometers) from his office in El Centro, California. Bovina later was elevated to lead the aggressive immigration crackdown in Chicago. Numerous Border Patrol officials have also been tapped to replace ICE leadership.
A drone used as surveillance technology is flown by a Cochise County law enforcement official, Tuesday, July 29, 2025, in Sierra Vista, Ariz. (AP Photo/Ross D. Franklin)~- Read More
https://apnews.com/article/immigration-border-patrol-surveillance-drivers-ice-trump-9f5d05469ce8c629d6fecf32d32098cd 13/15
9/21/26, 10:14AM Border Patrol monitors US drivers and detains Americans for 'suspicious' travel I AP News The result has been more encounters between the agency and the general public than ever before. "We took Alek's case because it was a clear-cut example of an unconstitutional traffic stop," said Christie Hebert, who works at the nonprofit public interest law firm Institute for Justice and represents Schott. "What we found was something much larger - a system of mass surveillance that threatens people's freedom of movement."
AP found numerous other examples similar to what Schott and the delivery driver experienced in reviewing court records in border communities and along known smuggling routes in Texas and California. Several police reports and court records the AP examined cite "suspicious" travel patterns or vague tipoffs from the Border Patrol or other unnamed law enforcement agencies. In another federal court document filed in California, a Border Patrol agent acknowledged "conducting targeted analysis on vehicles exhibiting suspicious travel patterns" as the reason he singled out a Nissan Altima traveling near San Diego.
In cases reviewed by the AP, local law enforcement sometimes tried to conceal the role the Border Patrol plays in passing along intelligence. Babb, the deputy who stopped Schott, testified he typically uses the phrase "subsequent to prior knowledge" when describing whisper stops in his police reports to acknowledge that the tip came from another law enforcement agency without revealing too much in written documents he w rites memorializing motorist encounters.
Once they pull over a vehicle deemed suspicious, officers often aggressively question drivers about their travels, their belongings, their jobs, how they know the passengers in the car, and much more, police records and bodyworn camera footage obtained by the AP show. One Texas officer demanded details from a man about where he met his current sexual partner. Often drivers, such as the one working for the South Carolina moving company, were arrested on suspicion of money laundering merely for carrying a few thousand dollars worth of cash, with no apparent connection to illegal activity. Prosecutors filed lawsuits to try to seize money or vehicles on the suspicion they were linked to trafficking.
Alek Schott sits for a photo in his car near a route he occasionally takes for work trips Wednesday, Oct. 15, 2025, in Stockdale, Texas. (AP Photo/David Goldman) License this P.hoto Read More
Schott warns that for every success story touted by Border Patrol, there are far more innocent people who don't realize they've become ensnared in a technology-driven enforcement operation. "I assume for every one person like me, who's actually standing up, there's a thousand people who just don't have the means or the time or, you know, they just leave frustrated and angry. They don't have the ability to move forward and hold anyone accountable," Schott said. "I think there's thousands of people getting treated this way."
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9/21/26, 10:14 AM Border Patrol monitors US drivers and detains Americans for 'suspicious' travel I AP News Tau reported from Washington, Laredo, San Antonio, Kingsville and Victoria, Texas. Burke reported from San Francisco. AP writers Aaron Kessler in Washington, Jim Vertuno in San Antonio, AP video producer Serginho Roosblad in Bisbee, Arizona, and AP photographers Ross D. Franklin in Phoenix and David Goldman in Houston contributed reporting. Ismael M. Belkoura in Washington also contributed.
Contact AP's global investigative team at [email protected] or hllps·//www,aR.QrgL.tiRSJ.
BYRON TAU Tau is an investigative reporter in the Washington, D.C. bureau of the Associated Press. He focuses on reporting stories about national security, law enforcement, technology and government accountability. He can be reached on Signal at byrontau.01
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GARANCE BURKE Burke is a global investigative journalist with The Associated Press based in San Francisco. She focuses on ,artificial intelligence and government accountability, and her work has been honored with the 2026 Pulitzer Prize in International reporting and with a documentary Emmy Award. She can be reached on Signal at garanceburke.33
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https://apnews.com/article/immigration-border-patrol-surveillance-drivers-ice-trump-9f5d05469ce8c629d6fecf32d32098cd 15/15
' 9/21/26,' 10:17 AM ICE Taps into Nationwide Al-Enabled Camera Network, Data Shows FOIA
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fe JASON KOEBLER , . JOSEPH COX · MAY 27, 2025 AT 9:36 AM Flock's automatic license plate reader {ALPR) cameras are in more than 5,000 communities around the U.S. Local police are doing lookups in the nationwide system for ICE.
https://www.404media.co/ice-taps-into-nationwide-ai-enabled-camera-network-data-shows/ 1/18
9/21/26, 10:17 AM ICE Taps into Nationwide Al-Enabled Camera Network, Data Shows , ----- ,c
IMAGES: FLOCK MARKETING MATERIAL AND MEDIA KIT. COLLAGE: 404 MEDIA . 404 Media is an independent website whose work is written, reported, and owned by human journalists. Our intended audience is real people, not Al scrapers, bots, or a search algorithm. Become a paid subscriber here for access to all of our articles ad-free and bonus content.
Data from a license plate-scanning tool that is primarily marketed as a surveillance solution for small towns to combat crimes like car jackings or finding missing people is being used by ICE, according to data reviewed by 404 Media. Local police around the country are performing lookups in Flock's Alpowered automatic license plate reader (ALPR) system for "immigration" related searches and as part of other ICE investigations, giving federal law enforcement side-door access to a tool that it currently does not have a formal contract for. htlps://www.404media.co/ice-taps-into-nationwide-ai-enabled-camera-network-data-shows/ 2/18
9/21/26,' 10:17 AM ICE Taps into Nationwide Al-Enabled Camera Network, Data Shows The massive trove of lookup data was obtained by researchers who asked to remain anonymous to avoid potential retaliation and shared with 404 Media. It shows more than 4,000 nation and statewide lookups by local and state police done either at the behest of the federal government or as an "informal" favor to federal law enforcement, or with a potential immigration focus, according to statements from police departments and sheriff offices collected by 404 Media.
It shows that, while Flock does not have a contract with ICE, the agency sources data from Flock's cameras by making requests to local law enforcement. The data reviewed by 404 Media was obtained using a public records request from the Danville, Illinois Police Department, and shows the Flock search logs from police departments around the country.
As part of a Flock search, police have to provide a "reason" they are performing the lookup. In the "reason" field for searches of Danville's cameras, officers from across the U.S. wrote "immigration," "ICE," "ICE+ERO," which is ICE's Enforcement and Removal Operations, the section that focuses on deportations; "illegal immigration," "ICE WARRANT," and other immigration-related reasons.
Although lookups mentioning ICE occurred across both the Biden and Trump administrations, all of the lookups that explicitly list "immigration" as their reason were made after Trump was inaugurated, according to the data.
Do you know anything else about Flock? We would love to hear from you. Using a non-work device, you can message Jason securely on Signal at jason.404 and Joseph at
joseph.404
The Department of Homeland Security does use license plate scanning cameras at the border and has shown great interest in the technology. Immigration advocates have been concerned that ICE could turn to local agencies' ALPR networks, but this is the first confirmation such data access is happening during Trump's mass deportation efforts.
https://www.404media.co/ice-taps-into-nationwide-ai-enabled-camera-network-data-shows/ 3/18
9/21/26, 10:17 AM ICE Taps into Nationwide Al-Enabled Camera Network, Data Shows "Different law enforcement systems serve different purposes and might be more appropriate for one agency or another. There should be public conversations about what we want different agencies to be able to do," Jay Stanley, senior policy analyst at the ACLU's Speech, Privacy, and Technology Project, told 404 Media. "I assume there's a fair number of community residents who accept giving police the power to deploy license plate readers to catch a bank robber, who would absolutely gag on the idea that their community's cameras have become part of a nationwide ICE surveillance infrastructure. And yet if this kind of informal backdoor access to surveillance devices is allowed, then there's functionally no limits to what systems ICE can tap into with no public oversight or control into what they are tapping into."
https://www.404media.co/ice-taps-into-nationwide-ai-enabled-camera-network-data-shows/ 4/18
' 9/21/26,' 10:17 AM ICE Taps into Nationwide Al-Enabled Camera Network, Data Shows Org Name Total Networks Total Devices Time Frame Case# Reason Sea.rch Time searched Searched
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DallaslX PD 6674 77771 ICE+EAO 3/6/2025, 05:20:28
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Dallas 1X PD 6674 77771 ICE+ERO 3/6/2025, 05:20:51
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DallaslX PD 6674 77771 ICE+ERO 3/6/2025, 05:21 :01
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DallaslX PD 6674 77771 ICE+EAO 3/6/2025, 05:21 :19
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DallaslX PD 6674 77771 ICE+ERO 3/6/2025, 05:22:36
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DallaslXPD 6674 77771 ICE+ERO 3/6/2025, 05:22:48
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DallaslX PD 6674 77771 ICE+ERO 3/6/2025, 05:22:57
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-- --- -- -- --- -- Dallas 1X PD 6674 77771 ICE+ERO 3/6/2025, 05:23:32 AMUTC
DallaslX PD 6674 77771 ICE+ERO 3/6/2Q25, 05:23:57
AMUTC
- - DallaslX PD 6674 77771 ICE+ERO 3/6/2025, 05:24:11
AMUTO
DallaslX PD 6674 77771 ICE+ERO 3/6/2025, 05:24:31
AMl,JTC
DallaslX PD 6674 77771 ICE+EAO 3/6/2025, 05:24:36
AMUTC
- ----
Lowndes County 6074 76290 Ice 3/6/2025, 05:47:38
GASO PMUTC
Lowndes County 6075 76298 Ice 3/6/2025, 06:04:05
GASO PMUTC
Lowndes County 6076 76319 Ice 3/6/2025, 07:18:31
GASO PMUTC
Lowndes County 6076 76318 Ice 3/6/2025, 07:24:08
GASO PMUTC
Lownd~s County 6076 76321 Ice 3/6/2025, 07:43:45
GASO PMUTC
Banks County GA 6076 76218 HSI 3/6/2025, 08:09:56
so PMUTC
A SCREENSHOT OF THE DATA.
Flock says its ALPR cameras are "trusted by more than 5,000 communities across the country." These cameras continuously record the plates, color, and brand of vehicles passing in front of them. Law enforcement can then perform searches to see where exactly a vehicle, and by extension person, was at a certain time or map out their movements across a wide date range. Flock is also developing a new product cal led Nova which will supplement that ALPR data https://www.404media.co/ice-taps-into-nationwide-ai-enabled-camera-network-data-shows/ 5/18
9/21/26, 10:17 AM ICE Taps into Nationwide Al-Enabled Camera Network, Data Shows with people lookup tools, data brokers, and data breaches to "jump from LPR [license plate reader] to person," 404 Media previously revealed. Law enforcement typica lly do these lookups without a warrant or court order, something which an ongoing lawsuit argues is unconstitutional.
Law enforcement agencies are able to search their own Flock cameras, but also those in other states or even nationwide. A Flock user guide says that na_ti~nal lookues allow "all law enforcement agencies across the country" who are also opted into that setting to search a user's cameras.
That user guide also says that users can "run a Network Audit to see who has searched your network from any agency in the Flock system." The 404 Media Podcast
Is Al M aking Us Less Human?
e SAVE TO SPOTIFY SHARE SUBSCRIBE DESCRIPTION •II
The researchers used a public records request to obtain the Danville Police Department's Network Audit. Because Flock allows police departments to share their cameras' records across a nation and statewide network of law enforcement agencies, the audit shows whenever Danville's camera records were searched by police departments around the country.
The data used to report this story shows in real numbers how expansive Flock's nationwide network of cameras has become. When the Dallas Police Department, for example, performed a series of searches for "ICE+ERO" on March 6, the department wasn't just searching its own cameras, it was searching 6,674 different individual Flock camera networks composed of 77,771 https://www.404media.co/ice-taps-into-nationwide-ai-enabled-camera-network-data-shows/ 6/18
9/21/26,' 10:17 AM ICE Taps into Nationwide Al-Enabled Camera Network, Data Shows total devices, the data says. (The Dallas Police Department declined to comment on its searches).
Searches across Danville's Flock cameras came from other agencies in Illinois, such as the Chicago Police Department. The data also includes state and local law enforcement agencies from all over the country, such as sheriff offices and police departments in Florida, Arkansas, Louisiana, South Carolina, Virginia, Arizona, and Texas. The Florida Highway Patrol and Missouri State Highway Patrol are also included in the data. The network audit stretches from June 1, 2024 to May 5, 2025 and contains millions of total searches. The researchers then narrowed that data to the more than 4,000 searches that contained immigration keywords in the "reason" field.
"I can't speak for the company as a whole, but I was unaware that Flock's tools were being used by local departments in collaboration with ICE. I'm disappointed, but not surprised," a Flock source said. 404 Media granted the source anonymity as they were not permitted to speak to the press. "It's really important that people understand how this tech- which they pay for with tax dollars- is used, since ultimately it's up to state and local governments to draw the boundaries of fair use by law enforcement."
https://www.404media.co/ice-taps-into-nationwide-ai-enabled-camera-network-data-shows/ 7/18
9/21/26, 10:17 AM ICE Taps into Nationwide Al-Enabled Camera Network, Data Shows IMAGE FROM FLOCK'S MEDIA KIT .
There are some caveats with the data. Many of the entries list the lookup reason as HSI, and HSI has a broad criminal investigative mandate beyond immigration enforcement, meaning that the police are helping a division of ICE but may not be using Flock specifically for immigration enforcement. Some law enforcement agencies told 404 Media they are not engaging in immigration enforcement despite the reason for the Flock lookup saying "immigration." A Missouri State Highway Patrol spokesperson told 404 Media that although the listed reason for using Flock was "immigration," the lookup "was related to a traffic stop with indicators of possible human trafficking." The spokesperson added "We are in the process of obtaining the training and creating the applicable policies" for immigration enforcement. Other agencies that listed https://www.404media.co/ice-taps-into-nationwide-ai-enabled-camera-network-data-shows/ 8/18
9/21/26; 10:17 AM ICE Taps into Nationwide Al-Enabled Camera Network, Data Shows "immigration" as the reason for the lookup did not respond to a request for comment.
The Trump administration has made a point of encouraging state and local police departments, which do not normally have authority to enforce immigration laws, to apply for a program called 287(g), which allows ICE to "delegate" the enforcement of immigration laws to local police. A January executive order issued by Trump instructs OHS and ICE "to authorize State and local law enforcement officials, as the Secretary of Homeland Security determines are qualified and appropriate, to perform the functions of immigration officers in relation to the investigation, apprehension, or detention of aliens in the United States."
It is particularly notable that the data in question came from an Illinois police department, because Illinois is one of the few states that specifically bans the use of ALPR data for immigration enforcement. Illinois-based police departments that ran searches shown in the data insisted that the searches were for criminal cases or were not specifically for immigration enforcement purposes.
"The chart [data] provided does not indicate that Danville PD is searching Flock LPR data or acting for another municipal, county, or state LE agency, nor ICE regarding immigration," Danville's police chief Chris Yates told 404 Media. "As required by the State of Illinois we ensure that we will not use LPR data or enforce a law or relate a person's immigration status." Yates did not respond to follow up questions about why the Flock audit showed searches for immigration-related reasons from other agencies around the country. "Long-story-short, what is being alleged is not happening," Danville's mayor, Rickey Williams Jr added.
https://www.404media.co/ice-taps-into-nationwide-ai-enabled-camera-network-data-shows/ 9/18
9/21/26, 10:17 AM ICE Taps into Nationwide Al-Enabled Camera Network, Data Shows -
Org Name Total Networks Total Devices Time Frame Case# ! Reason Search Time Searched Searched
Houston TX PD 3743 53855 Immigration 3/1/2025, 02:06:19 PMUTC ---- --- - -- --- Houston TX PD 3743 53855 Immigration 3/1/2025, 02:28:24 PMUTC
Houston TX PD 3743 53855 Immigration 3/1/2025, 02:45:30 PMUTC -- - - - --- - Houston TX PD 3743 53855 Immigration 3/1/2025, 03:22:52 PMUTC - - - - - - - Houston TX PD 3743 53855 Immigration 3/1/2025, 03:23:04 PMUTC
Houston TX PD 3743 53855 Immigration 3/1/2025, 03:24:08
PMUTC -
Houston TX PD 3743 53855 Immigration 3/1/2'025, 04:21 :31 PMUTC -- ·- -- -- - -- - 1---- -
Houston TX PD 3743 53855 Immigration 3/1/2025, 10:39:14 AMUTC
Houston TX PD 3743 53855 Immigration 3/1/2025, 11 :07:05 AMUTC - --- - - Houston TX PD 3743 53855 Immigration 3/1/2025, 11 :43:14 AMUTC
Houston TX PD 3743 53855 Immigration 3/1/2025, 12:04:53
PMUTC -
Houston TX PD 3743 53855 lmmlgratlon 3/1/2025, 12:44:15
PMUTC I
Houston TX PD 3743 53855 I Immigration ___ 3/1/2025, 12:47:51
PMUTC -- - -- '-
Missouri State 6140 76756 250138003 IMMIGRATION 3/10/2025, Highway Patrol 01 :51 :07 AM UTC
Missouri State 6140 76756 250138003 IMMIGRATION 3/10/2025, Highway Patrol 01 :52:01 AM UTC -- ----- - - - --- --- -- Banks County GA 6088 76506 HSI 3/10/2025, so 01 :58:03 PM UTC
Banks County GA 8088 76506 HSI 3/10/2025,
so 02:00:59 PM UTC - Mesa AZ. PD 6318 77032 25-700 Immigration 3/10/2025, vlolatolln 04:55:21 PM UTC
Houston TX PD 3743 53855 Immigration 3/1/2025, 02:06:19 PMUTC
Houston TX PD 3743 53855 j Immigration 3/1/2025, 02:28:24 PMUTC
A SCREENSHOT OF THE DATA .
But Danville's own data is showing that these searches by other police departments are in fact happening, and 404 Media confirmed the details of several searches with the departments that performed the search. The police departments we got details from said that sometimes searches for federal agencies are "informal," and sometimes they are part of a specific investigation. htlps://www.404media.co/ice-laps-into-nationwide-ai-enabled-camera-network-data-shows/ 10/18
, 9/21/26; 10:17 AM ICE Taps into Nationwide Al-Enabled Camera Network, Data Shows What is clear, however, is that ICE and HSI have gained side-door access to a tool that they do not formally have access to.
Andrew Perley, the deputy chief of the Village of Glencoe, Illinois police department, told 404 Media that a specific search "was not related to an investigation involving immigration status. The inquiry was an informal request from Homeland Security Investigations into a criminal matter aside from immigration." Ryan Glew of Evanston, Illinois police department, told 404 Media that one of their specific searches was because "We were assisting Homeland Security in the apprehension of a wanted subject. The subject was part of a nationwide retail theft ring that was responsible for millions of dollars from stores across the country. The queries were not immigration-related." Other police departments in Illinois we spoke to said that some of the searches were done to "assist" federal law enforcement, or that the searches were done by one of their "task force officers," who are local police that are embedded with federal units. Mike Yott, the police chief of Palos Heights, Illinois, said that, due to Illinois law, his department does not do immigration enforcement. But he said that he did not know what a search performed by one of its department's task force officers embedded with the Drug Enforcement Administration was for, even though it read "immigration violation."
"Based on the limited information on the report, the coding/wording may be poor and the use of Flock may be part of a narcotics investigation or a fugitive status warrant, which does on occasion involve people with various immigration statuses," Yott said.
The fact that police almost never get a warrant to perform a Flock search means that there is not as much oversight into its use, which leads to local police either formally or informally helping the feds by doing lookups. https://www.404media.co/ice-taps-into-nationwide-ai-enabled-camera-network-data-shows/ 11/18
9/21/26, 10:17 AM ICE Taps into Nationwide Al-Enabled Camera Network, Data Shows OrgName
I
Total Networks Totel Devices Time Frame Case# Reason Search Time Searched Searched
Hanover Park IL PD 1764 1764 11/22/2024, HSI 11/26/2024, 02:30:24 PM UTC 04:18:54 PM UTC
11/22/2024,
08:00:00 PM UTC - ---
Hanover Park IL PD 1764 1764 11/18/2024, HSI 11/26/2024, 02:30:24 PM UTC 04:25:42 PM UTC
11/22/2024,
09:00:00 PM UTC
Hanover Park IL PD 1764 1764 11/18/2024, HSI 11/26/2024, 02:30:24 PM UTC 04:25:49 PM UTC
11/22/2024,
09:00:00 PM UTC
H"o"' PMklL PO I 1764 1764 11/1 8/2024, HSI 11/26/2024, 02:30:24 PM UTC 04:36:02 PM UTC
11/22/2024,
09:00:00 PM UTC
Hanover Park IL PD 1764 1764 11/18/2024, HSI 11/26/2024, 02:30:24 PM UTC 04:36:09 PM UTC
11/22/2024,
09:00:00 PM UTC --- Hanover Park IL PD 1764 1764 11/18/2024, HSI 11/26/2024, 02:30:24 PM UTC 05:06:29 PM UTC
11/22/2024,
09:00:00 PM UTC
Hanover Park IL PD 1764 1764 11/18/2024, HSI 11/26/2024, 02:30:24 PM UTC 05:07:50 PM UTC
11/22/2024,
09:00:00 PM UTC
Isle Of Wight 5593 5593 10/27/2024, 56T-CBP 254564 11/26/2024, County VA SO 09:20:05 PM UTC 09:20:12 PM UTC
11/26/2024,
09:20:05 PM UTC
Butler Township OH 5647 5647 10/27/2024, HSI-Drug Lead 11/26/2024, PD 09:34:28 PM UTC 09:34:38 PM UTC
11/26/2024,
09:34:28 PM UTC
Hanover Park IL PD 1765 1765 11/20/2024, HSI 11/27/2024, 01 :30:17 PM UTC 03:23:56 PM UTC
11/24/2024,
03:30:17 PM UTC
Hanover Park IL PD 1764 1764 11/22/2024, HSI 11/26/2024, 02:30:24 PM UTC 04:18:54 PM UTC
11/22/2024,
08:00:00 PM UTC
Hanover Park IL PD 1764 1764 11/18/2024, HSI 11/26/2024, 02:30:24 PM UTC 04:25:42 PM UTC
11/??/?0?d
A SCREENSHOT OF THE DATA .
"Law enforcement really likes license plate readers because of the lack of restrictions on that data. They don't feel like they need a warrant. Oftentimes there are no restrictions whatsoever on what they search," Dave Maass, who studies border technology at the Electronic Frontier Foundation, told 404 Media. "It might be totally true that some of these searches are for people who have https://www.404media.co/ice-taps-into-nationwide-ai-enabled-camera-network-data-shows/ 12/18
9/21/26: 10:17 AM ICE Taps into Nationwide Al-Enabled Camera Network, Data Shows warrants or who are wanted for criminal activity. They might be looking for a terrorist, who knows. But that's kind of the point- we don't know." Flock said in a statement that "We are committed to ensuring every customer can leverage technology in a way that reflects their values, and support democratically-authorized governing bodies to determine what that means for their community."
"All Flock customers own and control 100% of the data collected by their Flock systems and choose who to share data with. The tools are fully auditable, indefinitely saving usage reports so command staff or city leadership has full insight into the use of the products. The network audit logs are an example of this auditing-by-design approach," the statement continued. The company said its tools have helped law enforcement locate more than 1,000 missing persons. "We work with local governments across the country to adopt best practices on LPR policies, including robust auditing requirements. Flock's platform requires double opt-in for agencies to share data amongst each other- we recommend every agency adopt a strong LPR policy, conduct regular audits, and be thoughtful about how and with whom they share data," the statement continued. "What is incredibly frustrating is that Flock in particular in Illinois marketed themselves to a bunch of communities in the suburbs and in Central Illinois as a device that would be critical to combatting an uptick in crime, violent crime, gun violence. But this is really a national system of data once you start collecting this, whether it's Bloomington or Springfield or Danville, you start looping together those networks," Edwin Yohnka, director of communications and public policy for ACLU Illinois, told 404 Media. "So it is incredibly troubling to see this list of places from around the country who are performing these searches of Illinois cameras."
https://www.404media.co/ice-taps-into-nationwide-ai-enabled-camera-network-data-shows/ 13/18
9/21/26, 10:17 AM ICE Taps into Nationwide Al-Enabled Camera Network, Data Shows OHS did not respond to multiple requests for comment.
404 Media is an independent website whose work is written, reported, and owned by human journalists. Our intended audience is real people, not Al scrapers, bots, or a search algorithm. Become a paid subscriber here for access to all of our articles ad-free and bonus content.
ABOUT THE AUTHOR
Jason is a cofounder of 404 Media. He was previously the editor-inchief of Motherboard. He loves the Freedom of Information Act and surfing.
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hltps://www.404media.co/ice-taps-into-nationwide-ai-enabled-camera-network•data-shows/ 14/18
9/21/26: 10:17 AM ICE Taps into Nationwide Al-Enabled Camera Network, Data Shows ~--)P>(E)~O:umo 1 P,lclng N111otivo 1.3.7 RFPA170CT002 00000009 ID40919 FOUOICUIILES P•n,gon SOiul.lonl (US), Inc
1.0 Introduction
PArtgon Solul.iont (US), Inc (Parogon). • who,'.fy owned aubskjijry of Pa,•oon ~ulioos, Ud., llritt l, Is p:oued lo one, uva pridno nl lf3liva 1n Ultponll IO RFP#70CTO0 OOOOOOOD tot !he Un'lod SlDtet i!PJ!JlllroA!ll 91Ji<mtljl.'J'l_~.'!Wl;Jy_(l)jjSJ.tlQlllt!l!\l!!.~t,YJtlYl..nyll.~~J'.!!<.'J.(l.!~!l.[ _ l~ll4J,l~l(7Jl!Cl lb\14\.lb\17\IE\
We Sued ICE to Get Its Spyware Contract. The
Agency Is Redacting Essential ly Everything
Paragon's software is capable of remotely breaking into phones and accessing messages from encrypted messaging apps. Our lawsuit aims to pry records about it from ICE.
f) JOSEPH COX · JUN 1, 2026
https://www.404media.co/ice-taps-into-nationwide-ai-enabled-camera-network-data-shows/ 15/18
9/21/26, 10:17 AM ICE Taps into Nationwide Al-Enabled Camera Network, Data Shows Emails Reveal Space Force's Hardest Mission Is
Writing a Song
Internal Space Force emails obtained by 404 Media show the work it takes to have a government agency make a new theme song. A general even wanted to start the whole thing over again .
• JOSEPH COX • APR 15, 2026
https://www.404media.co/ice-taps-into-nationwide-ai-enabled-camera-network-data-shows/ 16/18
• 9/21/26', 10:17 AM ICE Taps into Nationwide Al-Enabled Camera Network, Data Shows Unparalleled access to hidden
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9/2.1/26, 10:V AM California police illegally share license plate reader data to ICE Donate
Politics Housing Education Economy Immigration Environment California Voices Investigations Imp:
.- ' . • -. ' .. • - ' •• • : -:.. • t •,.: :.,; • • • • ' - • .,. - • • - l • I
TECHNOLOGY
California police are illegally sharing license plate data with ICE and Border Patrol
"') • BV KHARI JOHNSON AND MOHAMED AL ELEW
~ JUNE 13, 2025
Republish
A line of cars outside the County of Riverside Registrar of Voters office in Riverside on Nov. 5, 2024. Photo by Jules Hotz for CalMatters https://calmatters.org/economy/technology/2025/06/california-police-sharing-license-plate-reader-data/ 1/6
9/21/26, 10:17 AM California police illegally share license plate reader data to ICE
IN SUMMARY
LAPD and the counties of San Diego, Orange, and Riverside have repeatedly shared automated license plate reader data to federal agencies
Law enforcement agencies across Southern California violated state law more than 100 times last month by sharing information from automated license plate readers with federal agents, records show.
The Los Angeles Police Department and sheriff's departments in San Diego and Orange counties searched license plate readings on behalf of Immigration and Customs Enforcement and Customs and Border Protection, according to a database of queries obtained by anti-surveillance group Oakland Privacy and provided to CalMatters.
Under a 10-year-old California measure, known as Senate Bill 34, state law enforcement agencies are barred from sharing license plate reader data with out-of-state public agencies or federal entities. The law has been routinely violated; civil liberties groups in 2023 found that 71 California law enforcement agencies had broken it. Later that year, Attorney General Rob Bonta issued an advisorY. providing police with snecific guidance on how to comply with the law.
In addition to detailing the prohibition on out-of-state sharing, Bonta noted that operators of license plate readers must state the purpose of their use every time they access the information.
This log is where police searching Riverside County data revealed their cooperation with ICE, often using the term "HSI," referring to the agency's Homeland Security Investigations unit. The term "CBP" was also repeatedly listed as a search purpose.
Among the 10 agencies that conducted searches on behalf of ICE, six are in Los Angeles County and nine are in Southern California. Two agencies, the sheriff's departments for Orange and San Diego counties, carried out searches on the behalf of Customs and Border Protection or the Border Patrol. "This is a big deal, it's part of the problem, and we need the attorney general's office to start litigating," said Brian Hofer, former chair of the privacy commission for the City of Oakland.
Hofer said cities can put all the sanctuary policies on the books that they want, but if they're not shutting down the data sharing between local authorities and federal agencies like ICE, those protections are meaningless.
https://calmatters.org/economy/technology/2025/06/california-police-sharing-license-plate-reader-data/ 2/6
9/2.1/26, 10:17 AM California police illegally share license plate reader data to ICE The Riverside County Sheriff's Office, which logged four searches in the database with the purpose "hsinvest," told CalMatters that it shares license plate data with federal agencies for criminal investigations of matters like narcotics and human trafficking but does not provide ICE with such data for immigration enforcement. It said the fom searches last month were for one or more narcotics investigations and not in collaboration with a federal agency.
"We acknowledge that some justifications entered by our personnel may not align with our policy, and this is an issue we need to address with those who are not complying," said a representative from Riverside County Sheriff's Office Media Information Bureau about vague justifications entered by their deputies.
The Orange County Sheriff's Office did not respond to a request for comment. The Los Angeles Police Department declined to respond to questions from CalMatters about the search records. Bonta's office did not respond to a request for comment.
San Diego County Sheriff's Department provided a statement that said, "This matter requires further internal review. If any of our personnel are found in violation of our policies, we will take the appropriate action." ''This is a big deal, it's part of the problem, and
we need the attorney general's office to start
litigating.''
- BRIAN HOFER, CHAIR OF THE PRIVACY COMMISSION FOR THE CITY OF OAKLAND Tracy Rosenberg, advocacy director of Oakland Privacy, was disturbed by instances where police obscmed the pmpose of their searches by using vague terms, like "investigation" or "criminal justice," raising the question of whether they were complying with Bonta's guidance. By CalMatters' count, this happened more than 64,000 times out of the 491,000 queries in the database of searches from April 28 to May 30. "I've always been told all of this is carefully logged and tracked and they know why these logs are being accessed," Rosenberg said. "But now that I'm in this log it's obvious that they don't, and the reasons are completely obscured."
https://calmatters.org/economy/technology/2025/06/california-police-sharing-license-plate-reader-data/ 3/6
9/21/26, 10:17 AM California police illegally share license plate reader data to ICE Rosenberg found the vague reasons more disturbing than the openly disclosed federal searches - partly because they leave open the possibility that a search was carried out for a federal agency. Some agencies gave vague reasons for a majority of their queries.
"It seems like no one, [Riverside] Sheriff [Chad] Bianco included, knows why those location data searches were done in Riverside's [license plate] database," she said.
Automated license plate readers in Riverside County are part of a system powered by Flock, a company that works with law enforcement agencies in thousands of communities nationwide. The records obtained by Privacy Oakland came from a Flock audit report generated by the Riverside County Sheriff's Office.
The Falcon license plate-reading camera. Photo courtesy of Flock Safety Evidence of the sharing comes less than a week after President Trump ordered the deployment of Marines and the California National Guard to Los Angeles amid escalating protests there against deportations. Roughly two weeks ago, 404 Media renorted that local police in Illinois carried out searches on behalf of ICE agents. https:l/calmatters.org/economy/technology/2025/06/california-police-sharing-license-plate-reader-data/ 4/6
9/4,1/26, 10:F AM California police illegally share license plate reader data to ICE The Riverside County Sheriff's Department is headed by Sheriff Chad Bianco, a supporter of President Donald Trump. Bianco launched a run for California governor in February, shortly after telling local residents in a video P-Osted on social media that Riverside County sheriff's deputies "have not, are not, and will not engage in any type of immigration enforcement." In the same video, Bianco said he plans to continue to fight to reform state sanctuary: laws and that "I will do everything I can within the confines of the sanctuary state laws of California to cooperate with ICE to remove criminals from our jails." "We already knew that Sheriff Bianco supports Trump and his deportation machine," said Javier Hernandez, executive director of Inland Coalition for Immigrant Justice. The group of more than 35 organizations provides legal services for undocumented people and responds to alerts about ICE raids in Riverside and San Bernardino counties east of Los Angeles, a region known as the Inland Empire.
But Hernandez said Bianco still "has to follow the laws of this state even if he doesn't agree with them." The coalition plans to urge the attorney general's office to investigate any violations of state law.
Seth Hall, a longtime member of the TRUST SD Coalition, which has called for controls on license plate readers in San Diego, hopes knowledge of local police sharing data with ICE can make a difference as TRUST SD mounts a campaign to convince the San Diego City Council to defund police use of Flock. An annual surveillance reP-ort released in February disclosed that the San Diego Police Department shared license plate reader data with several outside agencies including ICE and the Border Patrol. Cooperation with federal authorities, he said, is a sore point in San Diego after ICE raided an Italian restaurant earlier this month and community: members fought back.
"It just hits a little harder when there's people on the street setting off flash bangs,"he said.
State Senator Sabrina Cervantes, a Democrat from Riverside, introduced a bill to regulate automated license P-late readers earlier this year, because "law enforcement agencies across our state are not following existing state law governing the use of automated license plate readers" and a audit by state employees in 2020 showed that. She did not respond to a request to comment on the sheriff's license plate log.
The risk of automatic license plate readers has been brought into focus by deportations, said Rosenberg of Oakland Privacy. The longtime argument against building a surveillance state used to be hypothetical. "It's 2025 and it's not hypothetical anymore," she said. https:l/calmatters.org/economyltechnology/2025/06/california-police-sharing-license-plate-reader-data/ 5/6
Flock Gives Law Enforcement All Over the Country Access OCTOBER 7, 2025 I IN POLICING, PRIVACY/SURVEILLANCE, TECHNOLOGY I BY GIDEON EPSTEIN Police in Texas, Florida, and thousands of departments nationwide can track Massachusetts drivers in real-time - without a warrant, probable cause, or even reasc the ACLU of Massachusetts reveal that police across the state are collecting detailed information about the locations of Massachusetts drivers and sharing that inf organizations all over the country - including in states that have passed laws banning abortion and gender-affirming healthcare for minors, and laws requiring p< The records and other publicly available information confirm that over 80 Massachusetts police departments have entered into contracts to deploy Flock Safety's, drivers when they pass one of Flock's cameras on the roads. Over the past three years, Massachusetts police have spent over $2 million in taxpayer funds on this t LPR data collected in their jurisdiction with Flock to be entered into its national database, where it can be accessed by thousands of out-of-state police departmen Page 629 of 716 At minimum, this dragnet surveillance means warrantless tracking of everyone on the road. At worst, it means a digital police state wherein law enforcement offici track protesters, political opponents, immigrants, patients, and others not suspected of any crime and use the information to hurt them.
What Is Flock and How Does It Work?
Flock Safety is a major player in the LPR industry, contracting with thousands of law enforcement agencies, running LPR surveillance across nearly 7,000 networks, 2025. The company's CEO claims their technology can eradicate all crime in America - though that's more marketing hype than reality.
License plate readers are cameras that automatically capture and record license plates, locations, and timestamps as vehicles pass by. These Al-enabled systems al where they've been.
At the crux of the problems with Flock is their nationwide data sharing model. Police departments that contract with Flock can choose to share the LPR data they< departments, with all departments in their state, or with the entire Flock network nationwide. But Flock has designed its system to incentivize maximum sharing: if entire nationwide network, that department can also search the entire nationwide network. In effect: "You show me yours, I'll show you mine." This Flock training ~ demonstrates how seamless and unrestricted data sharing operates within Flock's system. To share their data with police nationwide, all an administrator needs to
This screenshot from Flock's training materials shows that simply by selecting "Enable National LookupLJ" agencies contracted with Flock can give their staff access to Flock's national database and, in tur
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While departments contracted with Flock can opt to only accept specific data sharing requests, departments also have the option of automatically accepting sharing requests from other agencies.
We know many Massachusetts police departments are taking part in this nationwide network because, after submitting public records requests with nearly 80 dep Network Audits[.]" These network audits document searches conducted by police across the country of approximately 7,000 agencies and organizations' LPR data, dozens of Massachusetts police departments. What this means in practice is that officers with the Florida Highway Patrol and those in Dallas, TX, Jacksonville, FL, C where and when Massachusetts residents are driving, even when they are in Massachusetts - all without demonstrating any probable cause or even reasonable s Even some federal law enforcement agencies may have access to Flock's database, despite Flock's recent assertion that it ended its pilot program with the Depart, Protection (CBP). News reports indicate local police have conducted searches on behalf of ICE agents.
And that's not all. Flock isn't the only license plate reader company with a large presence in Massachusetts. The Massachusetts State Police (MSP) and some local 1 company that maintains its own national database and has contracts with agencies nationwide - including those in states that have passed extreme restrictions o also has contracts with federal agencies, including ICE. Indeed, records obtained through a public records request to the town of Auburn, Massachusetts show ICE The ACLU of Massachusetts is currently involved in public records litigation to learn more about the MSP's license plate reader surveillance network and its statew that litigation progresses.