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.
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?
The devil’s in the details, as they say, and boy are there some details here! Let’s take a look.
428.3 “…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.”
“Homeland Security”. California law prohibits the release of ALPR data generated in California to Federal agencies.
California Civil Code § 1798.90.51: Mandates that an ALPR operator or end-user must not share ALPR data with agencies or entities that are not state or local law enforcement agencies operating strictly under California state law.
California Civil Code § 1798.90.55: Prohibits public agencies from selling, sharing, or transferring ALPR information, limiting valid dissemination solely to authorized local/state public agencies operating within California for defined law enforcement purposes.
As long as they’re operating only based on California law, and not in conjunction with any Federal or out-of-state agency, they could, theoretically, use ALPR data for a perceived “homeland security” threat. But if they call in the Feds, they can’t give any of the ALPR data that they developed from their investigation to them.
Here’s the real devil, in my opinion, though:
428.7
(a) The agency makes a written request for the ALPR data that includes:
The name of the agency.
The name of the person requesting.
The intended purpose of obtaining the information.
(b) The request is reviewed by the Operations Support Division Captain or the authorized designee and approved before the request is fulfilled.
(c) The approved request is retained on file.
On 9/6/2026, there were 258 agencies listed on the Visalia Police Department’s Flock Transparency page as “Sharing Network Data With – Organizations granted access to Visalia CA PD data.”
From May 1, 2026 through June 1, 2026, there were 507,696 “hits” on Visalia PD’s Flock data set. California Highway Patrol was the biggest user, with 46,693 inquiries. That’s just one month’s worth of data access. (Visalia PD accessed the data only 1,634 times in that month, for comparison.)
Somehow, I doubt Visalia Police Department received 507,696 written requests for information which included the name of the agency, the requesting officer’s name, and the purpose for obtaining the information, which was then processed and approved before the data was released.
Now, I’m not a lawyer. I’ve never played one on TV. Hell, I didn’t even stay in a Holiday Inn Express last night. But it seems to me that the rule book isn’t being followed. The data is being accessed randomly by any agency on the “granted” list unsupervised. None of the required review or approvals are being done. Visalia PD has simply opened it’s data to anyone on that list. (To be sure, it’s a pretty common way to operate, as far as I can determine, statewide. Agencies all over the state are allowing the same access. The policy manual is one that is from a template, used by many agencies, and modified to reflect Visalia-specific regulation. One wonders how well it’s read before operations begin.)
I’m not universally against license plate reader systems. They have legitimate uses in the law enforcement world. What I don’t like is agencies, and especially the Visalia Police Department, giving control of these systems to an outside organization. The data is taken by cameras not owned by Visalia, the data is stored on servers not under the physical control of Visalia, and the programs used to access that data are proprietary property of Flock. The only real security on the data is Flock saying, “trust us, bro”. News reports the past few years tell us we can’t.
There are plenty of other ‘devils’ playing in this ongoing drama with Flock. Their use of the data, regardless of their claims that the customers own and control it and they won’t sell it, even though there are three places in the contract where the following is stated: “Customer hereby grants Flock a non-exclusive, worldwide, perpetual, royalty-free right to use and distribute such Anonymized Data to improve and enhance the Services and for other development, diagnostic and corrective purposes, and other Flock offerings.”
They also will use the data, anonymized (whatever that means. How do you anonymize data but still do this) to teach their AI program: “including the training of machine learning algorithms.”
Automated License Plate Readers are the camel’s nose. The rest of the camel is all the things they will (not can, will) do with the data we pay them to collect. The nose is in the tent. Maybe the camel has his entire head inside.
Did you ever watch the TV show, “Person of Interest”? Mr. Finch was trying to create an AI that could hunt terrorists. He succeeded. A joke of the show was that before he could create that machine, he had to create the availability of data, so he created social media. Now everyone provided the data he needed to train his AI. If you followed the show, you know how well all of that turned out.
We have some decisions to make. And some decisions already made to overturn. At the very least, change the policy manual to reflect how things are actually done.
Or we can just trust the government to always do the right thing, and protect us from bad actors. We’ve seen how well that’s worked out in the past, haven’t we?
These are all but one of the times I’ve spoken at the Visalia City Council, during Public Comments. My first time isn’t on their website, and was in 2012, when I accepted the first June Pride Month Proclamation issued by the City of Visalia. It was the first Pride Month Proclamation by a government body in the Southern San Joaquin Valley.
I got bored, so I counted the times I appeared before the City Council, according to the minutes. As of this writing, I’m at 58 times.
There are fewer than 58 entries above, because I spoke several times at several meetings. One time I had so much to say about things that I spoke five times! Another day it was four. It’s usually just once per meeting.
I still get nervous, sometimes, but I probably enjoy it more than I should.
Lest you think I’m hogging all the time, there’s a lady that has spoken over 85 times in the same time frame. I don’t know if she enjoys it or not.
If you would like to let them know what you think about things, here’s the 4-1-1:
PUBLIC COMMENTS
This is the time for general public comment on issues within the jurisdiction of the Visalia City Council. Each speaker tonight may speak for up to 3 minutes during this general comment period on a matter that is not on this agenda. The public may also make one comment for up to 3 minutes prior to the consideration of the Consent Calendar, and immediately before any regular agenda item is heard. The Council asks that you keep you comments concise and positive. Creative criticism, presented with appropriate courtesy, is welcome. Each speaker will be allowed three minutes and a timer will notify you when your time is expired. Please begin your comments by stating and spelling your name and providing your city of residence.
There are general public comments at the beginning of each session (work session and regular session), before the Consent Calendar, and after each item on the regular agenda, regarding that item.
Come join us at the meetings, on the first and third Mondays of each month (except on holidays, when they generally meet Tuesday). The regular session starts at 7pm, at City Hall, 707 W. Acequia. Work sessions start anywhere between 4pm and 5:30pm. Check the agenda for exact times.
No documents were presented regarding Lowe’s and Home Depot, so, assuming the lawyers are giving me the all the information the city has, there are no agreements of any kind for the Visalia Police Department to access any data collected by cameras owned by those companies.
Does that mean if VPD wanted to check that data, they’d have to get a subpoena? Can they simply call over and ask? If granted permission (and why would they not be?), do they have to go to the location and get access using the store’s system, or can they log in and take the data directly from Flock’s servers? I don’t know.
As far as the Visalia Economic Development Corporation is concerned, I’m not certain they’ve ever actually installed any cameras. One camera is shown in the industrial park, but I have as yet been unable to determine if that is part of the VPD network, or is operated by VEDC. At approximately $3,000 each per year, VEDC may not have the money to maintain the subscription.
What’s more interesting is the letter from the VEDC to a rather extensive email list about Flock needing to preserve data due to a class-action lawsuit that is pending. Check out some of the people they sent it to:
A Visalia City Council member, the Visalia City Manager, the Visalia Assistant City Manager, someone at Southern California Edison, two or more construction companies, the Visalia Unified School District Superintendent, the Tulare County Office of Education Superintendent, and several others identified by name only. Why most of them need to be informed about a class action lawsuit against Flock is puzzling.
The City of Visalia has closed out this public records request, telling me “no other records matching your request exist or are in the possession of the City of Visalia”.
P.S. – Since Visalia is using grant money for the first four years of this contract, there has been no ongoing expense for the city. They will eventually have 22 cameras up, which could result in a $66,000 a year cost to maintain the system, once those grants expire. Your tax dollars are and will be paying to surveil you every time you drive by a Flock camera. Smile, won’t you?
In April of 2026, I made a public records request of the Visalia Police Department. One of the things I asked for in that request was the logs of every outside agency that accessed the data collected by Visalia’s police department. I didn’t expect the sheer size of the results. I received audit logs for 18 months, running to tens of thousands of pages. I’m going to look at the latest (and biggest) of those files here.
From May 1, 2026 through June 1, 2026, there were 507,696 “hits” on the Flock data collected by Visalia PD. I’ve tallied the results to see who is searching license plate files (and other search terms) in Visalia. (Visalia accessed it’s own data 1,634 times in that month)
The biggest searcher was the California Highway Patrol, at 46,693 inquiries in just that one month’s time. Riverside County Sheriff’s Office was next, at 42,957.
There’s no way they thought vehicles they were “checking” for were in Visalia over 40,000 times each. It looks very much as if they simply have “all” selected for any search they do. Other agencies on down the list seem to be a bit more circumspect in their searches, but still cast wide nets when they do a Flock search.
Here’s a .txt file with the list, followed by an Excel list.
May 2026 audit
Beginning Search Time: May 1, 2026, 07:00:00 AM UTC Ending Search Time: June 1, 2026, 06:59:59 AM UTC Unique organizations: 309 Records tallied: 507,696
Org Name Tally
Rank
Agency / Organization
Count
1
California Highway Patrol
46,693
2
Riverside County CA SO
42,957
3
San Francisco CA PD
28,422
4
Los Angeles CA PD
19,367
5
Orange County SO CA
19,114
6
Los Angeles County CA SD
17,766
7
San Jose CA PD
15,670
8
San Bernardino County CA SO
12,167
9
Oakland CA PD
11,855
10
San Diego County CA SD
9,855
11
Fremont CA PD
7,241
12
City of Riverside CA PD
7,054
13
Sonoma County CA SO
7,054
14
Ontario CA PD
6,786
15
NCRIC
6,742
16
Irvine CA PD
6,585
17
Fontana CA PD
5,588
18
Ventura County CA SO
5,543
19
Santa Clara CA PD
5,472
20
Contra Costa County CA SO
5,191
21
Elk Grove CA PD
4,942
22
Daly City CA PD
4,939
23
San Joaquin County CA SO
4,724
24
Kern County CA SO
4,660
25
Santa Rosa CA PD
4,550
26
Stockton CA PD
4,516
27
San Bernardino CA PD
3,851
28
Solano County CA SO
3,792
29
Chula Vista CA PD
3,725
30
Bakersfield CA PD
3,560
31
Vacaville CA PD
3,402
32
Sunnyvale CA PD
3,218
33
Corona CA PD
3,185
34
Placer County CA SO
3,028
35
Salinas CA PD
3,014
36
Hayward CA PD
2,878
37
Murrieta CA PD
2,854
38
Pasadena CA PD
2,761
39
Chino CA PD
2,691
40
Concord CA PD
2,613
41
Sacramento CA PD
2,569
42
Newport Beach PD CA
2,510
43
California Department of Corrections
2,476
44
Buena Park CA PD
2,463
45
Livermore CA PD
2,434
46
Napa County CA SO
2,422
47
Costa Mesa CA PD
2,408
48
Anaheim CA PD
2,324
49
San Mateo CA PD
2,259
50
Santa Maria CA PD
2,245
51
Marin County CA SO
2,239
52
Sacramento County CA SO
2,142
53
Orange CA PD
2,139
54
Fairfield CA PD
2,120
55
National City CA PD
2,038
56
Alhambra CA PD
1,984
57
Montclair CA PD
1,956
58
Petaluma CA PD
1,939
59
Santa Barbara County CA SO
1,891
60
Cypress CA PD
1,805
61
Morgan Hill CA PD
1,787
62
Garden Grove CA PD
1,699
63
Rialto PD CA
1,693
64
San Leandro CA PD
1,665
65
Fullerton CA PD
1,646
66
Visalia CA PD
1,634
67
Turlock CA PD
1,608
68
Santa Ana CA PD
1,465
69
Tracy CA PD
1,440
70
West Sacramento CA PD
1,433
71
Union City CA PD
1,391
72
Monterey County CA SO
1,389
73
Rocklin CA PD
1,384
74
Manteca CA PD
1,367
75
Simi Valley CA PD
1,364
76
Greenfield CA PD
1,323
77
Burbank CA PD
1,289
78
Butte County CA SO
1,287
79
Ventura CA PD
1,275
80
Citrus Heights CA PD
1,242
81
Gilroy CA PD
1,237
82
Upland CA PD
1,227
83
Redwood City CA PD
1,191
84
Downey PD CA
1,166
85
Hanford CA PD
1,153
86
El Cajon CA PD
1,149
87
Tulare County CA SO
1,136
88
Hercules CA PD
1,136
89
Riverside County CA District Attorney
1,121
90
Brentwood CA PD
1,115
91
Oceanside CA PD
1,112
92
Vallejo CA PD
1,099
93
Merced County CA SO
1,079
94
San Bruno CA PD
1,054
95
Desert Hot Springs CA PD
1,049
96
Cal Fire
1,042
97
Placentia CA PD
1,028
98
Marina CA PD
990
99
Glendora (CA) PD
982
100
Imperial City CA PD
932
There are 209 additional unique organizations with counts ranging from 899 down to 1. You can see the entire list in the Excel file.
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!
Is Visalia PD following it’s own License Plate Reader policy regarding Flock cameras?
September 6, 2026
Jim Reeves commentary, geek, News ai, ALPR, Flock, Flock Camera, Flock License Plate Reader, License Plate Reader, News, tchnology, visalia, visalia police department, VPD Leave a comment
The Visalia Police Department Policy manual includes the following section (online as of 5 pm Pacific, 9/6/2026):
The devil’s in the details, as they say, and boy are there some details here! Let’s take a look.
428.3
“…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.”
“Homeland Security”. California law prohibits the release of ALPR data generated in California to Federal agencies.
California Civil Code § 1798.90.51: Mandates that an ALPR operator or end-user must not share ALPR data with agencies or entities that are not state or local law enforcement agencies operating strictly under California state law.
California Civil Code § 1798.90.55: Prohibits public agencies from selling, sharing, or transferring ALPR information, limiting valid dissemination solely to authorized local/state public agencies operating within California for defined law enforcement purposes.
As long as they’re operating only based on California law, and not in conjunction with any Federal or out-of-state agency, they could, theoretically, use ALPR data for a perceived “homeland security” threat. But if they call in the Feds, they can’t give any of the ALPR data that they developed from their investigation to them.
Here’s the real devil, in my opinion, though:
428.7
(a) The agency makes a written request for the ALPR data that includes:
(b) The request is reviewed by the Operations Support Division Captain or the authorized
designee and approved before the request is fulfilled.
(c) The approved request is retained on file.
On 9/6/2026, there were 258 agencies listed on the Visalia Police Department’s Flock Transparency page as “Sharing Network Data With – Organizations granted access to Visalia CA PD data.”
From May 1, 2026 through June 1, 2026, there were 507,696 “hits” on Visalia PD’s Flock data set. California Highway Patrol was the biggest user, with 46,693 inquiries. That’s just one month’s worth of data access. (Visalia PD accessed the data only 1,634 times in that month, for comparison.)
Somehow, I doubt Visalia Police Department received 507,696 written requests for information which included the name of the agency, the requesting officer’s name, and the purpose for obtaining the information, which was then processed and approved before the data was released.
Now, I’m not a lawyer. I’ve never played one on TV. Hell, I didn’t even stay in a Holiday Inn Express last night. But it seems to me that the rule book isn’t being followed. The data is being accessed randomly by any agency on the “granted” list unsupervised. None of the required review or approvals are being done. Visalia PD has simply opened it’s data to anyone on that list. (To be sure, it’s a pretty common way to operate, as far as I can determine, statewide. Agencies all over the state are allowing the same access. The policy manual is one that is from a template, used by many agencies, and modified to reflect Visalia-specific regulation. One wonders how well it’s read before operations begin.)
I’m not universally against license plate reader systems. They have legitimate uses in the law enforcement world. What I don’t like is agencies, and especially the Visalia Police Department, giving control of these systems to an outside organization. The data is taken by cameras not owned by Visalia, the data is stored on servers not under the physical control of Visalia, and the programs used to access that data are proprietary property of Flock. The only real security on the data is Flock saying, “trust us, bro”. News reports the past few years tell us we can’t.
There are plenty of other ‘devils’ playing in this ongoing drama with Flock. Their use of the data, regardless of their claims that the customers own and control it and they won’t sell it, even though there are three places in the contract where the following is stated: “Customer hereby grants Flock a non-exclusive, worldwide, perpetual, royalty-free right to use and distribute such Anonymized Data to improve and enhance the Services and for other development, diagnostic and corrective purposes, and other Flock offerings.”
They also will use the data, anonymized (whatever that means. How do you anonymize data but still do this) to teach their AI program: “including the training of machine learning algorithms.”
Automated License Plate Readers are the camel’s nose. The rest of the camel is all the things they will (not can, will) do with the data we pay them to collect. The nose is in the tent. Maybe the camel has his entire head inside.
Did you ever watch the TV show, “Person of Interest”? Mr. Finch was trying to create an AI that could hunt terrorists. He succeeded. A joke of the show was that before he could create that machine, he had to create the availability of data, so he created social media. Now everyone provided the data he needed to train his AI. If you followed the show, you know how well all of that turned out.
We have some decisions to make. And some decisions already made to overturn. At the very least, change the policy manual to reflect how things are actually done.
Or we can just trust the government to always do the right thing, and protect us from bad actors. We’ve seen how well that’s worked out in the past, haven’t we?
My previous Flock-related posts:
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