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.

TCP.01Download

Some additional information was provided in this packet, unrelated to my request, concerning different Flock camera installations, at Demaree and Caldwell, and Demaree at Tulare Avenue.

As for this request’s subject, right off the bat we can see that the pole and camera are not situated where the documents indicate. That pole sits much closer to the roadway than the ten feet specified in the plans. It’s also further north than the site map shows.

I asked for permits, and documentation regarding design requirements for any break-away standards for poles so close to the roadway, but other than design information on the poles, the cameras and computer mounting, there was nothing in the City’s response regarding that. Either the City allowed Flock to just put this camera up without that process, or they did not bother to include them in my response packet.

Here’s my Public Records Request:

CPRA Visalia 8_26_26 Flock Demaree_Goshen

Flock Safety ALPR Camera Installation — Demaree Street South of Goshen Avenue

To: City of Visalia, City Clerk’s Office

Also applicable to: City of Visalia Engineering/Public Works Department and Visalia Police Department

Pursuant to the California Public Records Act, California Government Code § 7920.000 et seq., I request access to and copies of all existing public records relating to the Flock Safety automated license plate reader (ALPR) camera installation located on Demaree Street, south of Goshen Avenue, on the west side of Demaree Street, in the area between the sidewalk and the roadway, where the camera is oriented toward southbound traffic.

This request concerns the specific standalone Flock camera pole at this location, rather than Flock installations generally.

For purposes of identifying the installation, the location may be described as:

Demaree Street south of Goshen Avenue, west side of Demaree Street, in the dirt/landscaped strip between the sidewalk and the roadway, adjacent to the red-painted curb/no-parking area.

  1. Encroachment permits and approvals

Please provide all records relating to any encroachment permit, right-of-way permit, construction permit, or other authorization issued for this Flock camera installation, including:

The complete encroachment permit application;
The issued encroachment permit;
All permit conditions;
Permit amendments or revisions;
Permit extensions;
Notices to proceed or notices to start work;
Inspection records;
Final inspection records;
Records of City acceptance of the completed installation;
Any correspondence concerning approval, denial, modification, or conditions placed upon the installation.


2. Approved engineering and construction plans

Please provide all approved and submitted engineering, construction, and site plans for this specific installation, including:

Site plans;
Pole-location plans;
Construction drawings;
Civil engineering drawings;
Foundation/footing/caisson drawings;
Pole detail drawings;
Equipment mounting details;
Camera mounting details;
Solar-panel mounting details;
Electrical plans;
Underground utility plans;
Right-of-way plans;
As-built drawings;
Any revisions to the original plans.
Please provide both the originally submitted plans and the final/approved plans, if both are maintained.

  1. Pole design and specifications

Please provide all records identifying the exact pole installed at this location, including:

Manufacturer;
Manufacturer’s model number;
Product name;
Pole height;
Pole diameter;
Pole material;
Pole weight, if available;
Foundation specifications;
Base-plate specifications;
Anchor-bolt specifications;
Breakaway/slip-base specifications;
Installation instructions;
Manufacturer engineering drawings;
Manufacturer installation documentation;
Product data sheets;
Any engineering certification for the pole.
Please also provide any record identifying whether the pole is classified by the City, Flock Safety, the manufacturer, or an engineer as:

breakaway;
yielding;
frangible;
crashworthy;
non-breakaway;
fixed;
rigid; or
otherwise designed to resist vehicle impact.


4. Breakaway and crashworthiness documentation

Please provide all records concerning whether the pole was required to be breakaway or crashworthy at this location.

This request specifically includes:

Any City engineering analysis concerning breakaway requirements;
Any City engineering determination that a breakaway pole was or was not required;
Any analysis of the pole’s location relative to the roadway, curb, sidewalk, shoulder, clear zone, or clear recovery zone;
Any MASH testing or certification;
Any NCHRP 350 testing or certification;
Any crashworthiness certification;
Any manufacturer’s crashworthiness documentation;
Any slip-base or breakaway certification;
Any calculations or engineering reports concerning vehicle impact;
Any engineering justification for using a non-breakaway pole;
Any waiver, variance, exception, deviation, or other authorization permitting a non-breakaway pole.
If the City determined that the pole did not need to be breakaway because of its location, please provide the existing record documenting that determination.

  1. Clear-zone / roadside safety analysis

Please provide all records concerning the location of this pole relative to the traveled portion of Demaree Street.

This includes any measurements, drawings, photographs, surveys, engineering calculations, or other records identifying:

Distance from the edge of the travel lane to the pole;
Distance from the face of the curb to the pole;
Distance from the pole to the sidewalk;
Roadway width;
Lane width;
Posted speed limit;
Design speed, if available;
Applicable clear zone;
Clear recovery zone;
Roadside recovery area;
Any roadside safety zone applicable to this location.
Please provide any analysis concerning whether the pole constitutes a roadside fixed object or obstacle and whether relocation, breakaway treatment, shielding, or another safety treatment was considered.

  1. Applicable engineering standards

Please provide all records identifying the engineering standards, specifications, manuals, policies, or other criteria relied upon by the City in approving this particular Flock camera pole.

This request includes any records citing or applying:

California Manual on Uniform Traffic Control Devices (CA MUTCD);
Caltrans Highway Design Manual;
Caltrans Traffic Safety Systems Manual;
Caltrans Standard Plans;
City of Visalia Engineering Standards;
City of Visalia Encroachment Permit Policy Manual;
AASHTO standards;
MASH standards;
NCHRP standards;
Flock Safety engineering standards;
Manufacturer specifications;
Any other applicable roadside safety or crashworthiness standard.
Please provide the specific section, provision, engineering standard, or design criterion relied upon where such a record exists.

  1. The City’s June 2026 Flock project

Please provide all records relating to the Flock Safety ALPR Camera Installation Project described by the City of Visalia in its June 2026 California Environmental Quality Act (CEQA) filing, including the project described as involving:

“a new breakaway support pole with concrete foundation, solar panel, and camera unit.”

Please specifically identify whether the Demaree Street installation is included within that project.

If it is included, please provide all records identifying the approved pole design for this location and all records showing whether the pole actually installed conforms to that approved design.

If the Demaree Street installation is not included in that project, please provide records identifying the separate project, permit, contract, or authorization under which it was installed.

  1. Communications concerning this specific pole

Please provide communications, including emails, memoranda, letters, text messages maintained as public records, meeting notes, and other writings, between or among:

City of Visalia Engineering/Public Works;
City of Visalia Police Department;
City Manager’s Office;
City Clerk’s Office;
City Traffic Engineering staff;
City inspectors;
Flock Safety;
Flock Safety contractors or installers;
The contractor responsible for installing the pole; and
Any engineering consultant involved with the installation,
concerning the specific Flock camera/pole at Demaree Street south of Goshen Avenue.

Please include communications concerning:

Pole selection;
Pole location;
Pole design;
Breakaway requirements;
Crashworthiness;
Roadway safety;
Clear-zone or clear-recovery-zone concerns;
Encroachment approval;
Construction;
Inspection;
Modifications;
Complaints or safety concerns;
Any deviation from approved plans.


9. Contracts, purchase orders, and invoices specific to the installation

Please provide records sufficient to identify the contract, purchase order, work order, invoice, or other procurement record associated with the installation at this location, including:

Contractor name;
Installation contractor;
Engineering contractor/consultant;
Purchase order;
Work order;
Invoice;
Scope of work;
Pole/equipment specifications;
Cost of installation;
Any change orders;
Any documentation concerning substitutions of equipment or materials.


10. Inspection and as-built verification

Please provide all records showing that the completed installation was inspected against the approved plans and specifications.

This specifically includes any record showing:

The pole model actually installed;
The pole’s foundation;
The pole’s base or breakaway mechanism;
The camera mounting assembly;
Solar-panel assembly;
Final location;
Measurements from the curb or roadway;
Photographs taken during inspection;
Punch lists;
Corrections;
Notices of nonconforming work;
Final approval or acceptance.


11. Complaints, safety concerns, or subsequent review

Please provide records of any complaints, inquiries, safety reviews, engineering reviews, or internal discussions concerning the safety or placement of the Flock camera pole at this location.

This includes records concerning whether the pole:

Is too close to the roadway;
Is a fixed roadside obstruction;
Should be moved;
Should be replaced with a breakaway pole;
Requires shielding;
Does not comply with the approved plans;
Does not comply with City engineering standards; or
Presents a potential vehicle-impact hazard.


12. Records concerning replacement or modification

Please provide records concerning any planned, proposed, discussed, or completed modification, replacement, relocation, or retrofit of this particular Flock pole, including any proposed conversion to a breakaway or crashworthy pole.

  1. Request for electronic production

I request that responsive records be provided electronically, preferably in their native electronic format where reasonably available, including PDF, CAD, Excel, email, or other native formats as applicable.

For engineering drawings, please provide the highest-resolution electronic version reasonably available.

For emails, please include attachments and the available metadata/header information sufficient to identify the sender, recipient, date, and subject.

  1. Search parameters

Please search records maintained by or available to the following City departments, divisions, employees, consultants, and contractors as applicable:

City Clerk’s Office;
Engineering/Public Works;
Traffic Engineering;
Development/Encroachment Permit staff;
City Manager’s Office;
Visalia Police Department;
Procurement/Purchasing;
Risk Management;
Any City employee responsible for the Flock Safety program;
Any engineering consultant involved with the project; and
Any contractor responsible for installation.
The requested time period is January 1, 2025 through the date this request is processed.

For communications specifically concerning the Demaree Street installation, please search using combinations of terms including, but not limited to:

“Flock,” “Flock Safety,” “ALPR,” “LPR,” “license plate reader,” “Demaree,” “Goshen,” “Demaree Street,” “Goshen Avenue,” “breakaway,” “crashworthy,” “MASH,” “NCHRP,” “slip base,” “pole,” “camera pole,” “encroachment,” “right-of-way,” “clear zone,” “clear recovery zone,” “roadside safety,” and the name of the applicable contractor or engineering consultant.

  1. If records are withheld or redacted

If any responsive record or portion of a record is withheld, please identify the specific legal basis for withholding or redaction and provide all reasonably segregable portions of the record.

If the City contends that a particular exemption applies, please identify the specific California Government Code section or other legal authority relied upon.

If responsive records are maintained by another City department or agency, please forward this request to the appropriate custodian or advise me where the request should be directed.

If the City determines that some portion of this request is overly broad, please contact me before denying the request so that the request can be reasonably narrowed while preserving the records most directly relevant to the pole at this location.

I am particularly interested in records establishing the approved pole design, the actual pole installed, whether the pole is breakaway/crashworthy, the engineering basis for its placement immediately adjacent to the roadway, and whether the completed installation conforms to the City’s approved plans and applicable engineering standards.

Thank you for your assistance.

CPRA Visalia 8_26_26 Flock Demaree_Download

And, yes, I used AI to formulate that request. I told it what I wanted, and it gave me that response, which I used with some minor edits.
Here are my past Flock-related blog posts: