Now even knowing only the number of times my plate was registered in the Flock network is a “privacy” concern. And since the California state law doesn’t specifically state they have to provide this information, they’re refusing. Here’s my (and Gemini’s) response:
October 20, 2026
Rachele Berglund, Esq.
Herr Pedersen & Berglund LLP
Attorneys for Visalia Police Department
RE: Response to Determination on Public Records Act Request #26-1986 (License Plate JJRJR ALPR Count)
Dear Ms. Berglund:
Thank you for your response dated October 19, 2026, regarding CPRA Request #26-1986. I am writing to clarify the legal basis of my request, address the exemptions asserted in your determination, and narrow the scope of the request to assist the Visalia Police Department in fulfilling its statutory duties.
1. Database Extraction Is Not “Record Creation” Under California Law
Your response states that no record containing the requested tally exists and that the CPRA does not require the Department to create a new record. While I agree that agencies are not required to generate custom written reports or conduct legal synthesis, the California Supreme Court has clarified how this rule applies to electronic databases.
Under Gov. Code § 7922.570 (formerly § 6253.9) and the California Supreme Court’s decision in National Lawyers Guild v. City of Hayward (2020) 9 Cal.5th 1178, performing a search query or extracting compiled data from an existing government database does not constitute the creation of a new record. The underlying raw ALPR data exists within the software system maintained and used by the Department. Executing a search in the Flock software interface for a specific license plate over a 30-day window to yield a hit count is a standard data extraction process under Gov. Code § 7922.575, not the manufacturing of non-existent data.
2. The ACLU Privacy Exemption Is Inapplicable to an Aggregate Count
Your response relies on ACLU Foundation of Southern California v. Superior Court (2017) 3 Cal.5th 1032 and the catch-all exemption (Gov. Code § 7922.000) to argue that disclosure implicates privacy interests regarding vehicle locations and movements.
The privacy concerns highlighted in ACLU center on location tracking—specifically, GPS coordinates, timestamps, and contextual photographs that reveal individual travel patterns over time. My request explicitly excludes all location data, GPS coordinates, timestamps, photographs, and officer details. A single, aggregate numerical count contains zero location or tracking information and therefore does not compromise personal privacy. Under the balancing test of Gov. Code § 7922.000, the public interest in understanding the scope of local ALPR system usage clearly outweighs any privacy claim attached to an isolated number.
3. Modified and Narrowed Request Scope
To minimize administrative burden and resolve the jurisdictional objections raised regarding third-party feeds under Gov. Code § 7920.530, I am revising and narrowing my request as follows:
Narrowed Request: I request an electronic export or system-generated query summary showing the total numerical count of recorded instances in which California license plate JJRJR was recorded, captured, or logged during the most recent 30-day retention period, restricted exclusively to ALPR cameras owned, leased, or directly operated by the Visalia Police Department. As before, this request explicitly excludes dates, timestamps, geographical locations, GPS coordinates, vehicle photos, context images, officer names, and associated case numbers.
4. Statutory Duty to Assist (Gov. Code § 7922.600)
Under Gov. Code § 7922.600, public agencies have an affirmative duty to assist requesters in identifying records and information that are responsive to the request, describing the information technology and physical location in which the records exist, and providing suggestions for overcoming any practical obstacles to disclosure.
If the Department maintains that entering a license plate query into its ALPR user interface to generate a result count presents a technical obstacle, please outline the specific technical limitations under Gov. Code § 7922.600 so we can reach a practical resolution.
Please confirm receipt of this modified request and advise when the responsive data extraction will be provided.
Sincerely,
Jimmie Joe Reeves, Jr.
*****************
We’ll see if this budges them on releasing the information. I’m not holding my breath.
On September 10, 2026, I filed a California Public Records Act request of the City of Visalia, and the Visalia Police Department. On October 5, I got my response.
A lot to digest there, but let’s start with “5. The Department’s case/incident number is withheld.” A lot of verbiage to deny giving me the case numbers associated with each incident that was allegedly solved with the use of the Flock ALPR system.
They’re also saying they don’t have to release “arrest and incident information” that is more than a year old, and that “much” of my requested information predates that by “many months”, but they are giving it to me (minus what they decided to withhold) “in the interest of transparency”.
They tell me how generous they were being by including information that was more than a year old, citing a court case that they claim means they didn’t have to.
Visalia, I hate to say it, but “transparency” went out the window a long time ago. (Encrypting police radio transmissions and removing a data field on the Flock transparency page was just the beginning.)
Other information gleaned from the “response” –
From January 1, 2025 through May 29, 2026, there were 123 incidents solved which were attributed to Flock ALPR use by the Visalia Police Department.
To justify mass surveillance, proponents of ALPR systems often talk about two types of incidents: missing persons, and stolen cars. In Visalia’s record, there are no cases of missing persons found using the Flock system. Out of 123 incidents that were attributed to the Flock system, only 45 are stolen vehicles.
Six were violent crimes – assault with a deadly weapon, armed robbery, and a home invasion.
The rest of the cases “solved” by Flock ALPR data are not classified as violent crimes.
I had asked for location information, as well. Either addresses of incidents, or the hundred block and street name. They refused to provide that, stating the “existing” data only listed VPD “area” zones, and they didn’t have to provide the address or location information more detailed than that.
In the time period covered by the data released, Flock ALPR cameras took more than 5,950,000 images of license plates. Perhaps many more. The “transparency” page lists an average monthly “unique plate reads” of more than 300,000 every 30 days. Multiply that by the 17 months of data released, and the total number surveillance images is staggering.
And, at $3,000 a year per camera, expensive. (The cameras are not bought by and owned by Visalia. They are a subscription. The cameras and related equipment remain the property of Flock.)
The next steps being taken on Mt. Whitney High School’s upgrade are in process. The Visalia Unified School District is working on drawing up plans to build a new administration, library, and classroom buildings. The first stage is a two-story admin/library/classroom building in currently vacant space on the campus, followed by the demolition of the current admin/classroom building and the construction of a new, single-story classroom building.
The big issue for many Mt. Whitney alumni, and other interested citizens, is the preservation of a large oak tree on the campus. It’s dedicated to the memory of “The Winningest Coach in Pioneer History”, Douglas P. Rudolf. Coach Rudolf was at Mt. Whitney from 1969 to 2012. Early presentations showed one of the new buildings sitting directly where the memorial and historic oak currently exist.
Screenshot
The District heard loud and clear from the public, as well as Whitney alumni and teachers (current and retired), that removal of the tree and memorial was not acceptable. The have adjusted their plans accordingly.
The District, in current presentations, is saying the tree and memorial will be preserved.
The other trees in the same area will probably not survive the project. One is clearly dying, if not already dead. The others may not be able to, one, survive the construction-caused disruption to the ground in the area, and two, may end up being too close to the new buildings to allow them to remain.
On the left, the memorial tree to be preserved. The others to the right are likely destined to be removed. At least one of them is dying/dead.
The Mt. Whitney High School Campus, and the planned new construction.
Final design work is being done now, and the District will be holding more public meetings to inform the public of the plans, and to take input on those designs. The District has not, as yet, determined the exact footprints of the buildings, nor their final appearance.
Current timelines have construction of the new, two-story, building beginning in June of 2028, and taking 13 months. There is no current timeline on demolition and replacement of the current admin building, but bids are expected in March of 2028.
Funding is from 2018’s Measure A, of $37 million, “other” funding of $36 million, for a total project cost of $73 million. In several years time, grant funds of $33 million will come from the State of California as part of the project. That money will go to other projects in the District. (In a confusing (to me, anyway) government shuffle, in about three years the state of California will provide funds designated for this project. Money from the bond will then be “freed up”, and be available for other projects.)
On August 26, 2016, I filed a California Public Records Act request with the City of Visalia regarding this particular Flock camera. It’s located on Demaree Street, just south of Goshen Avenue, in Visalia. When I noticed it one day driving by, I had questions.
There are all kinds of requirements for things close to city streets, especially for those items in the public right-of-way. I decided to check to see if those requirements had been met for this installation. I wrote a very involved public records request about it, and got my reply today.
The response was underwhelming.
Either most of my request was ignored, or the City let this thing be put up with almost no oversight, and in violation of it’s own documents regarding the installation.
Here’s the complete response to my request. I’ll add the entire request at the end of this blog, as it’s quite extensive.
The “Training Bulletin” for the Visalia Police Department, dated January 16, 2025 contains the following sentence:
“Any successfully investigated case and/or arrest that involved the use of a Flock ALPR shall be logged in Spillman under Circumstances Code FLOCK.”
Spillman is the program which basically runs the Sheriff’s Office. Dispatch enters calls with it, it controls the Records data, and provides statistical information, among many other things.
Since the Visalia Police Department has indicated that the Flock Automated License Plate Reader system has been instrumental in a dramatic decrease in auto thefts, I’ve decided to see just how effective it actually has been. I want to see every incident they’ve attributed to the Flock cameras since this bulletin became operative.
The City’s lawyers have given themselves until October 15, 2026 to respond to my request.
There’s been a recent public outcry about the possibility of a data center being sited on the property of the Tulare County Fairgrounds. Many county residents are adamantly opposed to the idea, and have flooded the last two Fair Board meetings with public comments. The proposal, while not a full-blown data center of the type most imagine when hearing the term, the “resilience center” does include what is called an “edge computing center”. The project is part of a state-funded initiative to improve disaster response capabilities.
Global Stack USA has proposed numerous projects across California, usually at a county fairground site. Offers of building a “resilience center” at no cost to the fairgrounds is tempting for fair boards who are constantly trying to keep their fairs budgets in the black.
There are at least two flies in the ointment of these proposals, though. One is a 99 year lease, and the other is the data center.
With lots of misinformation floating around about just what is being proposed by Global Stack USA (a company less than a year old), I decided to get some facts directly from the horse’s mouth, as it were. I’ve made another Public Records Act request.
At the June 23, 2026, Tulare County Board of Supervisor’s meeting, the Tulare County Sheriff’s Office was authorized to implement plans to operate a “Drone As First Responder” program. Purchased through Motorola, the system will, in the Sheriff’s Office words, “enhance operational efficiency, officer safety, emergency response capabilities, and public safety operations through implementation of a Drone as First Responder (DFR) program utilizing the Motorola Solutions BRINC drone platform.”
The Supervisors, in a consent calendar item not pulled (no public presentation or discussion), approved the proposal. There is no cost for the first year of the program. If, after a year-long “test program”, the County wishes to continue, the cost is just under $560,000 a year, for four more years. The Sheriff’s Office plans to use AB 109 Public Safety Realignment grant funding to pay for the cost of this program.
The Sheriff’s Office has used drones for several years, but these models are a technological leap in capabilities. Previously, a Deputy would have to respond to a scene and deploy a drone from their patrol vehicle. With this system, the drones can be deployed from fixed as well as mobile locations.
It’s been an interesting summer. It’s ending on a (not so) high note, as someone has tried to get me kicked off the Visalia City Council’s Citizens Advisory Committee (CAC). Can you guess who it was, and why? Here’s the letter sent to the City Council and the City representative on the Advisory Committee:
I would agree with one thing in his letter. “…minor children are entirely uninvolved.” There was and is no danger to anyone’s children. (except when he gave out his home address while challenging another subject on Facebook, inviting them over to “continue” a heated conversation in person. oh, did he mention that the children are his, and the lawyer is his ex-wife? And she never asked to have her name redacted? No? Interesting.)
Since I wouldn’t submit to his demands, he published an Op-Ed in GV Wire attacking me, then the next day sent this letter to the City of Visalia. In it, he’s essentially begging someone, anyone, on the City Council, to agree with him, and move to have me dismissed from the CAC.
That didn’t happen. I’m still on the Committee. In fact, I’ve recently been made Vice-Chair. (and I’ve already presided over a meeting, as the Chair was not able to attend. Go me.)
There’s been a lot of drama stirred up around this nonsense. I’m comfortable in my editorial decisions regarding this entire series of events, and my actions in response to ‘Karen’. I’ll be happy to be done with it, but ‘Karens’ seldom know when to stop. We’ll see what happens next.
At the October 21, 2024 City Council meeting, Consent Agenda item #6, file #24-0415, was approved with no separate discussion. That item was to enter into an agreement with Flock Safety out of Atlanta, Georgia, for their Automated License Plate Reader subscription service. Visalia Police Department wanted to install 22 cameras around the city, and have access to 18 other cameras operated by other organizations, for a total of 40 installations.
The issue here? The agenda packet does not reflect the reality of what the City Council was being asked to approve.
The information provided to the City Council says, “The Visalia Police Department has thoroughly researched various methods to prevent and respond to Part One crimes within the City of Visalia and County of Tulare.”
Let’s look at the “Background Discussion” presented by city staff in the agenda packet.
Background Discussion:
Flock Safety fixed-mount ALPR cameras have become one of the most popular ALPR cameras available to law enforcement and are also available to school districts, businesses, and hospitals.
True.
Currently, there are 18 Flock Safety fixed-mount ALPR cameras operating throughout the City of Visalia. These cameras are installed at various businesses and properties which are owned by private entities.
Also true.
As a Flock Safety customer, the Visalia Police Department would gain access to the 18 existing Flock Safety fixed-mount ALPR cameras at no additional cost. This would expand the network of ALPR cameras available to the Visalia Police Department significantly.
True.
Nationwide, all law enforcement owned Flock Safety ALPR cameras…
Not true. No Flock Safety ALPR cameras are owned by anyone other than Flock. They are the sole property of Flock. The City is entering into a lease.
communicate with each other, allowing law enforcement to track offenders from jurisdictions outside of the City of Visalia.
The cameras do not ‘communicate’ with each other. They take images, scan those images with a program to extract the license plate number, and send the image and the data to a central server, maintained as proprietary by Flock. The images can be further analyzed by Flock’s proprietary software for information other than simply license plate numbers. They do allow law enforcement agencies from outside the City of Visalia to access that data – if they subscribe to the service, or present a subpoena.
Locally, Flock Safety fixed-mount ALPR cameras are installed in the following cities: Farmersville, Woodlake, Porterville, Lindsay, Tulare, Hanford, Lemoore, Corcoran, Orange Cove, Reedley, Fowler, and Fresno. These cities combined have a total of more than 250 Flock Safety fixed-mount ALPR cameras, which the Visalia Police Department would gain access to after becoming a customer.
True.
Flock Safety fixed-mount ALPR cameras have no infrastructure requirements resulting in zero utility costs. The cameras are powered by solar and utilize a wireless LTE connectivity. Flock Safety services, maintains, and replaces each fixed-mount ALPR camera at no additional cost for the contracted period.
True. If the cameras or other parts of the system fail, Flock will replace them. If they are damaged or stolen, the City pays to replace them, at over $600-$800 per camera. Damage to the solar panel, cell equipment, or other parts of the unit are extra.
Flock Safety is the only fixed-mount ALPR camera company that provides connectivity with the existing Flock Safety fixed-mount ALPR cameras that are installed throughout the City of Visalia and surrounding jurisdictions. They are also the only company that features technology that is capable of capturing vehicle identifiers other than license plates.
There’s an important bit of information that I suspect many hope flies by unnoticed. “vehicle identifiers other than license plates”. And the data is used to train their own, again proprietary, AI.
Fiscal Impact:
No new appropriations required at this time. There will be two (2) separate contracts due to separate funding sources. Contract #1 is for nine (9) cameras and contract #2 is for 13 Cameras. The cost variance between the two projects is primarily due to differences in equipment and installation infrastructure.
I also have questions about the funding source, but that’s maybe for a different blog.
The ALPR cameras purchased under contract #1 are being installed on CalTrans right of way infrastructure which has an increased installation cost. Furthermore, two of the ALPR cameras included in this contract are more costly due to their range capabilities.
The cameras are not being “purchased”, they are being leased. While Flock claims, and contractually promises, that the data these cameras produce belong to the subscriber, and will not be ‘sold’, they do require “a non-exclusive, worldwide, perpetual, royalty-free right to use and distribute such Anonymized Data…”. There is no way (publicly revealed, anyway) for the City of Visalia to insure the data is secure, and not used in violation of California law, or the 4th Amendment to the US Constitution. (A class action lawsuit against Flock is in the beginning stages of court right now, based on 4th Amendment claims)
Purchased? Leased? Semantics? Maybe. But reading the Consent Agenda packet, would a City Council person necessarily understand that, one, the City was not “purchasing” the system, and, two, that the details presented in the agenda packet were not accurate? Many city council members rely heavily on the city staff to provide them with reliable information on which to base their decisions. Incomplete or misleading information, put in a consent calendar item, might reasonably fly right past them.
The Police Department recently told the Valley Voice that “according to their data, 2025 saw a 39% reduction in stolen vehicles, which VPD attributes to the Flock cameras it began using in 2024.” While that may be, correlation is not causation. We are not given the data required to authenticate the effectiveness of the Flock cameras.
As I’ve stated in previous blogs, I’m not against these kinds of camera systems, if they are the property of, controlled by, and accessed only by local government(s). With Flock, agencies do not control the system, they only have access to it. The data, while said to be owned by the agency and not sold to anyone else, is solely controlled by Flock. Past incidents have shown the ease at which access control is lost, and how the system can be abused, even by authorized personnel.
Look at the Consent Calendar agenda item yourself, and decide. Did it accurately reflect what the Police Department wanted the City to do? Does it fully inform the Council about what they were being asked to authorize? Did it really result in a 39% reduction in stolen vehicles?
Or is “lease” and “purchase” just an issue of semantics?
Random thoughts, occasional rants, illuminating commentary, and an odd story now and then from the world of 9-1-1 dispatching. All this and more from a gay liberal atheist living in California’s Bible belt. I recently married, so MAGA beware! I’m your worst nightmare! Some names have been omitted to protect the innocent, but the guilty will be hung out to dry!
And the answer is still NO
October 19, 2026
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Now even knowing only the number of times my plate was registered in the Flock network is a “privacy” concern. And since the California state law doesn’t specifically state they have to provide this information, they’re refusing. Here’s my (and Gemini’s) response:
October 20, 2026
Rachele Berglund, Esq.
Herr Pedersen & Berglund LLP
Attorneys for Visalia Police Department
RE: Response to Determination on Public Records Act Request #26-1986 (License Plate JJRJR ALPR Count)
Dear Ms. Berglund:
Thank you for your response dated October 19, 2026, regarding CPRA Request #26-1986. I am writing to clarify the legal basis of my request, address the exemptions asserted in your determination, and narrow the scope of the request to assist the Visalia Police Department in fulfilling its statutory duties.
1. Database Extraction Is Not “Record Creation” Under California Law
Your response states that no record containing the requested tally exists and that the CPRA does not require the Department to create a new record. While I agree that agencies are not required to generate custom written reports or conduct legal synthesis, the California Supreme Court has clarified how this rule applies to electronic databases.
Under Gov. Code § 7922.570 (formerly § 6253.9) and the California Supreme Court’s decision in National Lawyers Guild v. City of Hayward (2020) 9 Cal.5th 1178, performing a search query or extracting compiled data from an existing government database does not constitute the creation of a new record. The underlying raw ALPR data exists within the software system maintained and used by the Department. Executing a search in the Flock software interface for a specific license plate over a 30-day window to yield a hit count is a standard data extraction process under Gov. Code § 7922.575, not the manufacturing of non-existent data.
2. The ACLU Privacy Exemption Is Inapplicable to an Aggregate Count
Your response relies on ACLU Foundation of Southern California v. Superior Court (2017) 3 Cal.5th 1032 and the catch-all exemption (Gov. Code § 7922.000) to argue that disclosure implicates privacy interests regarding vehicle locations and movements.
The privacy concerns highlighted in ACLU center on location tracking—specifically, GPS coordinates, timestamps, and contextual photographs that reveal individual travel patterns over time. My request explicitly excludes all location data, GPS coordinates, timestamps, photographs, and officer details. A single, aggregate numerical count contains zero location or tracking information and therefore does not compromise personal privacy. Under the balancing test of Gov. Code § 7922.000, the public interest in understanding the scope of local ALPR system usage clearly outweighs any privacy claim attached to an isolated number.
3. Modified and Narrowed Request Scope
To minimize administrative burden and resolve the jurisdictional objections raised regarding third-party feeds under Gov. Code § 7920.530, I am revising and narrowing my request as follows:
4. Statutory Duty to Assist (Gov. Code § 7922.600)
Under Gov. Code § 7922.600, public agencies have an affirmative duty to assist requesters in identifying records and information that are responsive to the request, describing the information technology and physical location in which the records exist, and providing suggestions for overcoming any practical obstacles to disclosure.
If the Department maintains that entering a license plate query into its ALPR user interface to generate a result count presents a technical obstacle, please outline the specific technical limitations under Gov. Code § 7922.600 so we can reach a practical resolution.
Please confirm receipt of this modified request and advise when the responsive data extraction will be provided.
Sincerely,
Jimmie Joe Reeves, Jr.
*****************
We’ll see if this budges them on releasing the information. I’m not holding my breath.
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