HomeMy WebLinkAbout07-10-2018 Item 17 - Public Hearing to Authorize Automated License Plate Recognition Use Meeting Date: 7/10/2018
FROM: Daryl Grigsby, Director of Public Works
Prepared By: Scott Lee, Parking Services Manager
SUBJECT: AUTHORIZE USE OF AUTOMATED LICENSE PLATE RECOGNITION
(ALPR)
RECOMMENDATION
1. Hold a public hearing to receive testimony on the proposed use of Automated License Plate
Recognition (ALPR) for enforcement and data collection purposes; and
2. Approve the use of Automated License Plate Recognition (ALPR) technology in accordance
with all State law and City policies included in Attachment A and Attachment B.
DISCUSSION
Intelligent transportation systems (ITS) have become essential in providing day-to-day
operations to assist the general public in many facets of transport ation systems. These include 1)
traffic signal system integrations, 2) autonomous & connected vehicle advancements, 3)
operator choice applications systems information such as transit and parking services and their
availability. Additionally, law enforcement utilize s ALPR technology in assisting in certain law
enforcement activities that are of community benefit.
ITS is assisting both the general public and the transportation providers with new ways and
methods of doing business in order to be more efficient and transparent . The use of technology
such as Automated License Plate Recognition (ALPR) will be one of many technologies to
assist in parking data collection, parking enforcement , and law enforcement detection within the
City. Other technologies include enhancements to our Parking Access and Revenue Control
System (PARCS) which contro ls our parking structure gates.
The primary objective of ALPR will be to assist Parking Services in the identification of
vehicles to determine whether the vehicle has exceeded the allowed parking time permitted at
its current location or has the proper residential permit for a given area. As residential permit
districts have expanded, and additional time restrictions have been put in place throughout the
City, enforcement has become more difficult . Complaints regarding parking, particularly in
areas around Cal Poly University, have increased particularly since the university restricted
freshmen from bringing vehicle s to campus. Parking density on streets around the campus has
increased and effective enforcement is limited due to the repeated need to circul ate the
neighborhoods and identify parking violations.
The secondary purpose of ALPR will be, in partnership with the Police Department , to reduce
harm to the community by providing data to help locate stolen vehicles, wanted/high risk
persons, and at risk/missing persons. This report recommends adoption of policies regard ing
each of these applications of ALPR technology for these purposes and separates out
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responsibilities between the Public Works and Police Departments in their application .
The use of ALPR is anticipated to assist Parking staff in identifying parking violations and will
be an essential tool to assist in performing daily duties. Secondarily, AL PR will also assist in
the data collection necessary to update and maintain the Park + model c urrently used by the
City and give more immediate occupancy data for staff, the community and Council on parking
related issues.
ALPR Details
License plate recognition systems use image processing technology to identify vehicles through
their license plates and use cameras to capture images of the front and/or rear of a vehicle . In
addition, GPS coordinates identify the vehicle’s location. It is important to note that this system
will gather and process vehicle parking data far more efficiently than the manual collection
processes currently utilized by Parking Services. In essence, Parking Services will use this
technology as a new and more effective way of doing business y – a major premise of the City’s
Fiscal Health Response Plan. As an example, park ing occupancy studies that are done manually
now would be semi-automated with this technology, assisting and accelerating in compiling
data for parking assessments.
ALPR will allow parking enforcement officers to more effectively enforce the parking laws of
the City and respond more quickly to public requests for enforcement, particularly in areas
surrounding Cal Poly. Vehicle license plate information will be collected, processed, and stored
electronically and will be used for parking enforcement, occupancy, and trend analysis. The
information will only be retained in the system for the time -period needed and then will
automatically be deleted. Actual vehicle ownership information will not be determined as part
of this process.
While ALPR is intended primarily for enforcement purposes, this technology will also automate
the collection efforts and improve accuracy of the data used to update the pilot Kimley-Horn
Park+ model currently being used by Parking Services. The Park+ model is under development
to help the City understand the parking impacts of new development and model utilization rates
and how dynamic pricing can affect parking availability. Data can also be gathered and modeled
to help determine if an area should have parking restrictions added (i.e. meters, time limits, etc.)
and will allow these determinations to be made faster and with more complete information.
Use of ALPR will be in accordance with all State requirements including SB 34, which
establishes requirements of jurisdictions that u se ALPR as a tool. This bill requires an agency
provide an opportunity for the public to comment at a regularly scheduled public meeting before
implementing an ALPR program o r the proposed use of the ALPR system. Attachment 1
includes the proposed policy o n the use of APLR for Parking Services within the City. SB 34
also prohibit s the City from selling, sharing, or transferring ALPR information, except to another
public agency for very specific purposes and the City will adhere to that requirement .
The City Council approved the RFP for ALPR in July 2017, and the City Manager authorized
the award of the contract in March 2018.
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NEXT STEPS
Should Council approve, Parking Services will begin to utilize the ALPR technology in
accordance with California Stat utes and City policies after staff completes required training.
Police department utilization of the technology will be phased in over time once the system has
been implemented and troubleshooted.
CONCURRENCES
Public Works Transportation, Community Development Department, and the SLO Police
Department all concur with this recommendation.
ENVIRIONMENTAL REVIEW
The recommended actions are not subject to the California Environmental Quality Act.
FISCAL IMPACT
The use of ALPR technology will likely result in increased operational efficiencies in the way
the City does parking business, particularly in data collection for operational assessments as well
as enforcement activities. It is expected that an increase in revenue may result as part of utilizing
this tool for enforcement purposes. Additional operating expenses will be incurred primarily
through fees associated with processing citations and monthly cost s of operating and maintaining
the system. These expenses are anticipated to be low enough to be absorbed within the existing
Parking Fund budget. In addition, o perational efficiencies may result from enhanced
enforcement and a potential temporary increase in citations. It is anticipated that as enforcement
becomes more effective, violations will return to standard levels.
ALTERNATIVES
The City Council may choose to not approve the usage of ALPR technology and instruct Staff to
continue to manually enforce all parking regulations and manually collect data for updating the
Park + model and seek other alt ernatives. The Parking Manager and staff do not recommend this
alternative as this option is time consuming and does not improve the overall capabilities or
efficiencies of the division and the system that have been purchased and installed on Parking
Enforcement Vehicles.
Attachments:
a - Parking ALPR Policy 06-29-2018
b - SLOPD ALPR Policy 06-29-2018
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Drafted 06-13-2018 Automated License Plate Recognition (ALPR) - 1
San Luis Obispo Parking Division
Policy Manual
Automated License Plate Recognition (ALPRs)
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 Recognition (ALPR) technology.
2. POLICY
The policy of the San Luis Obispo Public Works Department’s Parking Services Division is to utilize ALPR
technology to capture and store digital license 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.
3. ADMINISTRATION
The ALPR technology, also known as License Plate Recognition (LPR), allows for the automated detection
of license plates. It is used by the Parking Services Division to convert data associated with vehicle
license plates for official Parking Services Division purposes, including identifying vehicles eligible for tow
due to overdue citations, and for electronically “chalking” vehicles to enforce time limited parking
spaces. It may also be used to identify stolen or wanted vehicles, and be shared with the San Luis
Obispo Police Department in accordance with their ALPR policy.
All installation and maintenance of ALPR equipment, as well as ALPR data retention and access, shall be
managed by the Parking Manager. The Parking Manager will assign staff mem bers under his/her
direction to administer the day-to-day operation of the ALPR equipment and data.
3.1. ALPR ADMINISTRATOR
The Parking Manager 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 (Civil Code §
1798.90.51; Civil Code § 1798.90.53):
(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.
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Drafted 06-13-2018 Automated License Plate Recognition (ALPR) - 2
(e) The title and name of the current designee in overseeing the ALPR operation.
(f) Working with the City’s Information Technology Division (IT) and 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.
4. 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 Parking Division business.
(b) An ALPR may be used in conjunction with any routine Parking Division operation, including parking
enforcement activities.
(c) No member of this department shall operate ALPR equipment or access ALPR data without first
completing department-approved training.
(d) No ALPR operator may access department, state or federal data unless otherwise authorized to do
so.
(e) For scofflaw vehicles, the enforcement officer shall verify registration information and past due
citation status prior to immobilization or impound of vehicles that is based solely on an ALPR alert.
5. DATA COLLECTION AND RETENTION
The Parking Manager 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 division procedures.
All ALPR data downloaded to the server should be stored for a minimum of one year in accordance with
the City’s established records retention schedule. Thereafter, ALPR data will be purged. Any ALPR data
shared with law enforcement that becomes related to evidence in a criminal or civil action or data that
is subject to a discovery request or other lawful action will be downloaded from the server onto
portable media and booked into evidence with the San Luis Obispo Police Department.
6. ACCOUNTABILITY
All data will be closely safeguarded and protected by both procedural and technological means. The
Parking Division 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)
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Drafted 06-13-2018 Automated License Plate Recognition (ALPR) - 3
(b) Members approved to access ALPR data under these guidelines are permitted to access the data for
legitimate Parking Division purposes only, such as when the data relates to the investigation of a
parking violation.
(c) ALPR systems audits should be conducted on a regular basis.
7. RELEASING ALPR DATA
The ALPR data may only be shared with the San Luis Obispo Police Department, and may be released to
other law enforcement or prosecutorial agencies for official law enforcement purposes or as otherwise
permitted by law per San Luis Obispo Police Department policy.
Requests for ALPR data by non-law enforcement or non-prosecutorial agencies will be processed as
provided in the Records Maintenance and Release Policy (Civil Code § 1798.90.55).
8. TRAINING
The Parking Manager should ensure that members receive approved training for those authorized to use
or access the ALPR system (Civil Code § 1798.90.51; Civil Code § 1798.90.53).
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San Luis Obispo Police Department
San Luis Obispo PD CA Policy Manual
Automated License Plate Readers (ALPRs)
San Luis Obispo Police Department
San Luis Obispo PD CA Policy Manual
Automated License Plate Readers (ALPRs)
469.1 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.
469.2 POLICY
The policy of the San Luis Obispo 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 San Luis Obispo Public Works Department has adopted a parallel but separate policy for
their use of ALPR including the administration of all the Public Works equipment, operations,
data collection and retention, accountability, release of ALPR data and training.
469.3 ADMINISTRATION
The ALPR technology, also known as License Plate Recognition (LPR), allows for the automated
detection of license plates. It is used by the San Luis Obispo 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 Police Department APLR equipment, as well as Police
Department data retention and access, shall be managed by the Police Department’s
Administration Bureau Commander. For all issues related to law enforcement and data
collection the Departme nt’s Administration Bureau Commander will assign staff members under
his/her direction to administer the day-to-day operation of their ALPR equipment and data.
469.3.1 ALPR ADMINISTRATOR
The Administration Bureau Commander 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 (Civil Code § 1798.90.51; Civil Code § 1798.90.53):
(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.
Policy
469
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San Luis Obispo Police Department
San Luis Obispo PD CA Policy Manual
Automated License Plate Readers (ALPRs)
(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.
469.4 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 do so.
(f) If practicable, the officer should verify an ALPR response through the California Law
Enforcement Telecommunications System (CLETS) before taking enforcement action
that is based solely on an ALPR alert.
469.5 DATA COLLECTION AND RETENTION
The Administration Bureau Commander 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
(Government Code § 34090.6) and in accordance with the established records retention
schedule. Thereafter, ALPR data should be purged unless it has become, or it is reasonable to
believe it will become, evidence in a criminal or civil action or is subject to a discovery request
or other lawful action to produce records. In those circumstances the applicable data should be
downloaded from the server onto portable media and booked into evidence.
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San Luis Obispo Police Department
San Luis Obispo PD CA Policy Manual
Automated License Plate Readers (ALPRs)
469.6 ACCOUNTABILITY
All data will be closely safeguarded and protected by both procedural and technological means.
The San Luis Obispo 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 on a regular basis.
For security or data breaches, see the Records Release and Maintenance Policy.
469.7 RELEASING ALPR DATA
The ALPR data may be shared only with other law enforcement or prosecutorial agencies
for official law enforcement purposes or as otherwise permitted by law, using the following
procedures:
(a) The agency makes a written request for the ALPR data that includes:
1. The name of the agency.
2. The name of the person requesting.
3. The intended purpose of obtaining the information.
(b) The request is reviewed by the Administration Bureau Commander or the authorized
designee and approved before the request is fulfilled.
(c) The approved request is retained on file.
Requests for ALPR data by non-law enforcement or non-prosecutorial agencies will be processed
as provided in the Records Maintenance and Release Policy (Civil Code § 1798.90.55).
469.8 TRAINING
The Training Manager 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).
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7/10/2018
1
Public Hearing on use of Automated
License Plate Recognition (ALPR)
City Council July 10, 2018
Recommendation
Hold a public Hearing to receive testimony on the
proposed use of Automated License Plate
Recognition (ALPR) for enforcement and data
collection purposes; and
Approve the use of ALPR technology in accordance
with State law and City policies.
Staff Presentation - Item 17
7/10/2018
2
ALPR Highlights and History
LPS systems use image processing technology to
identify vehicles through their license plate;
More efficient than manual collection processes;
Captures publicly available information on vehicle,
not on the registered owner or driver;
Council approved RFP July 2017, City Manager
approved award in March 2018 and installation now
completed;
Parking Services and SLOPD as required to comply
with SB 34.
SB34 Highlights
SB34 requires an ALPR operator to:
Maintain reasonable security procedures and practices;
Implement a usage and privacy policy; and
Require that ALPR information is only used for the
authorized purposes described in the policy
ALPR information access shall Maintain a record of
the access to include:
Date and time
License plate queried
User name of person accessing the information
The purpose for accessing the information
Staff Presentation - Item 17
7/10/2018
3
City Usage of ALPR
The initial usage of ALPR will be by Parking Services
for:
Data collection and
parking regulation enforcement
Does not change what city staff currently doing, but:
Makes more operationally efficient (FHRP);
Provides opportunity to implement digital permits;
Allows staff to survey larger areas more timely; and
Provides refreshed data for forecasting parking demand
model (Park +);
Recommendation
Hold a public Hearing to receive testimony on the
proposed use of Automated License Plate
Recognition (ALPR) for enforcement and data
collection purposes; and
Approve the use of ALPR technology in accordance
with State law and City policies.
Staff Presentation - Item 17
7/10/2018
4
Questions
Other California City Policies
https://www.eff.org/pages/california-automated-license-plate-
reader-policies
Staff Presentation - Item 17