Thank you to the members of Mount Vernon City Council for the opportunity to submit written public comment on proposed legislation to let the city’s current contract with Flock Safety expire and to establish a 12-month moratorium on the installation of new automatic license plate readers (ALPRs).

The ACLU of Ohio’s position is the only way to address the serious threats to privacy posed by ALPRs is to ban their use altogether. Simply put, no sufficient regulations, restrictions, or safeguards exist that can fully address the concerns posed by mass surveillance technology like this.

Accordingly, our organization’s best recommendation for Council is not to contract with Flock Safety or any other ALPR vendor following the conclusion of the yearlong moratorium and to ban ALPRs entirely instead of enacting a pause. That said, upon request we can provide recommendations for harm reductive restrictions on the use of ALPRs and data-sharing.

We further ask Council to consider requiring an audit of Mount Vernon’s use of Flock ALPRs thus far, particularly given the documented misuse and abuse of ALPRs that we have seen in Columbus and across the state as a result of independent audits. Mount Vernon residents deserve the opportunity to submit comment regarding the proposed moratorium and this issue more broadly, as well.

Lastly, we urge this body not to wait for the state legislature to enact legislation regarding the use of ALPRs. Municipalities can and should use their home rule authority to address the urgent civil liberties concerns of their residents instead of waiting on the state legislative process to unfold. This is especially true given that the 136th General Assembly is set to adjourn in just over three months, meaning any pending legislation will need to be reintroduced next January before going through the legislative process.

Thank you again for this opportunity, and we stand ready to assist Council on this vital issue in any way we can.