On the agenda: Milford meeting — ALPR (Aug 27)

City of Milford, Connecticut

- Founded in 1639 -

Peter C. Smith 70 West River Street
City Clerk Milford, CT 06460-3364
AGENDA
BOARD OF ALDERMEN
SPECIAL MEETING

THURSDAY, AUGUST 27, 2026 @ 7:30 P.M.
Parsons Government Center Auditorium
70 W River Street
Milford, CT 06460
Pledge of Allegiance to the Flag.
1: Roll Call

2. Executive Session. A two-thirds (2/3) vote of those present and voting is required for any
item to be considered in executive session.

(a) Discuss pending litigation — City of Milford and Milford Police Department,
SBLR Case # MPP-359980

3. Public Comment
4. New Business
(a) Board of Aldermen approval is requested for the attached Resolution Re: A
Moratorium on the use of Automated Traffic Enforcement Safety Devices (ATESD),
a Pause on the Installation of Additional ATESD, and Review of the City’s ATESD
Program.
(b) Board of Aldermen approval is requested for the attached Resolution Re: The Use,
Deployment, Retention, Oversight and Codification of the City’s Automated License
Plate Reader (ALPR) Program.

DS: Adjournment.

I respectfully submit the fol! considergfion and action:

‘ter C. Smith, City
Dated at Milford, CT this 26th day of August
ANY INDIVIDUAL WITH A DISABILITY WHO NEEDS SPECIAL ASSISTANCE TO PARTICIPATE IN THE
MEETING SHOULD CONTACT THE DIRECTOR OF COMMUNITY DEVELOPMENT AT 203-783-3230,
FIVE DAYS PRIOR TO THE MEETING OR AS SOON AS POSSIBLE.

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RESOLUTION RE: A MORATORIUM ON THE USE OF AUTOMATED TRAFFIC ENFORCEMENT
SAFETY DEVICES (ATESD), A PAUSE ON THE INSTALLATION OF ADDITIONAL ATESD, AND
REVIEW OF THE CITY'S ATESD PROGRAM

WHEREAS, C.G:S. § 14-307c authorizes a municipality to use automated traffic enforcement safety
devices ("ATESDs") at locations within school zones, pedestrian safety zones and other locations
within the municipality, provided that the municipality adopts an ordinance in accordance with the
statute and the locations of such devices are identified in a plan approved by the Connecticut
Department of Transportation pursuant to C.G.S. § 14-307e; and

WHEREAS, C.G.S. § 14-307c also requires that an ordinance adopted pursuant to that section
provide for the citation hearing procedures established by C.G.S. § 7-152c and specifies the
procedures governing the issuance and mailing of ATESD citations; and

WHEREAS, on November 7, 2024, the Board of Aldermen voted to adopt Ordinance Section 14-60,
et. seq. “Use of automated traffic safety enforcement devices” and on March 3, 2025, approved the
City of Milford ATESD Plan (the “Plan”), which was thereafter submitted to and approved by the
Connecticut Department of Transportation; and

WHEREAS, Section 14-60 of the Milford Code of Ordinances currently authorizes the use of ATESDs
at locations within school zones, pedestrian safety zones and other locations within the City identified
in the Plan, subject to the public hearing and approval requirements established therein; and

WHEREAS, Sections 14-60 through 14-71 of the Milford Code of Ordinances presently establish a
regulatory framework governing the City's ATESD program, including the use and operation of
ATESDs, the issuance and mailing of citations, fines, citation hearings, appeals, defenses and the
disclosure, retention and destruction of information and data; and

WHEREAS, residents of the City have expressed concerns and raised questions regarding the City's
use and administration of ATESDs, including the appropriate locations and hours for speed-camera
enforcement, the amount of fines imposed, the escalation of fines for subsequent violations, the
procedures available to persons wishing to contest citations, and the receipt of citations by persons
who lease motor vehicles; and

WHEREAS, ATESD technology serves a fundamental public-safety purpose, particularly in areas
where speeding creates a heightened risk to students, pedestrians and other vulnerable road users,
but also recognizes the importance of ensuring that the City's use of such technology is appropriately
limited, transparent, proportionate and consistent with the expectations of the Milford community; and

WHEREAS, a moratorium on the operation of existing ATESDs and the installation of additional
ATESDs will provide an appropriate period during which the Board, City officials and members of the
community may review the City's ATESD program, the Plan, the City's ATESD ordinance and the
concerns raised regarding the use and administration of ATESDs; and

WHEREAS, if the City continues to utilize ATESDs following such review, their use should be more
narrowly focused on speed enforcement in school zones during specified hours and should include

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fines and procedures that are proportionate to the nature of the violations and provide appropriate
opportunities for persons to contest citations.

NOW, THEREFORE, BE IT RESOLVED, that the Board of Aldermen of the City of Milford hereby
imposes a moratorium, commencing on the date following approval of this Resolution, on the
operation and use of all currently installed ATESDs and on the installation of any additional ATESDs
within the City of Milford; and

BE IT FURTHER RESOLVED, that during the moratorium, a Public Safety Technology Review
Committee established by the Mayor shall review the City's Comprehensive Traffic Safety Plan and
Sections 14-60 through 14-71 of the Milford Code of Ordinances and shall make recommendations to
the Ordinance Committee of the Board of Aldermen concerning the use, operation and administration

of ATESDs within the City; and

BE IT FURTHER RESOLVED, based upon the recommendations of the Public Safety Technology
Review Committee, the Ordinance Committee shall consider amendments to Sections 14-60 through
14-71, as appropriate, to ensure that the ATESD program provides clear and transparent
requirements concerning the locations and hours of operation of speed cameras, the issuance and
mailing of citations, identification of the person legally responsible for a leased motor vehicle, citation
hearings and appeals, review of recorded images, privacy and data-retention requirements, and other
safeguards necessary to ensure compliance with C.G.S. §§ 14-307c through 14-307h and other

applicable law; and

BE IT FURTHER RESOLVED, that nothing in this Resolution shall be construed to amend, repeal,
suspend or otherwise modify Sections 14-60 through 14-71 of the Milford Code of Ordinances, the
City's Comprehensive Traffic Safety Plan, or any approval issued by the Connecticut Department of
Transportation, and that any substantive changes to the City's ATESD program shall be accomplished
through such ordinance, Plan and approval processes as may be required by applicable law; and

BE IT FURTHER RESOLVED, that upon completion of its review, the Ordinance Committee shall
report its recommendations to the Board of Aldermen, including any proposed amendments to
Sections 14-60 through 14-71 and, if appropriate, any proposed amendments to the City's
Comprehensive Traffic Safety Plan requiring approval pursuant to C.G.S. § 14-307e and Section 14-
60 of the Milford Code of Ordinances.

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RESOLUTION RE: THE USE, DEPLOYMENT, RETENTION, OVERSIGHT AND CODIFICATION OF
THE CITY'S AUTOMATED LICENSE PLATE READER (ALPR) PROGRAM

WHEREAS, the Milford Police Department ("MPD") currently operates a network of fixed automated
license plate readers (ALPR) for law enforcement purposes; and

WHEREAS, the City of Milford ("City") recognizes that technology can provide valuable tools to
promote public safety, assist law enforcement investigations, identify stolen vehicles, locate missing
or endangered persons, and address other public-safety concerns; and

WHEREAS, the City also recognizes that ALPR technology collects information concerning motor
vehicles at particular locations and times and that the collection, retention, access to and use of such
information implicates legitimate privacy, civil-liberty, transparency, accountability and public-trust
concerns; and

WHEREAS, the use of ALPR technology requires a balance between public-safety objectives and
reasonable limitations designed to minimize unnecessary collection, retention, access to and use of
ALPR information; and

WHEREAS, the MPD's ALPR policy and practices contain safeguards, which include, but are not
limited to, two-factor authentication, unique credentials and assigned user roles, limited access to
search functions, supervisory approval, user training, human verification of ALPR hits before police
action, an ALPR Administrator, weekly audits and a transparency portal; and

WHEREAS, the MPD's ALPR policy also directs the avoidance of sensitive locations, including places
of worship, hospitals, methadone clinics and political party offices; and

WHEREAS, the MPD has identified and incorporated policy changes including a seven-day data-
retention period, notification concerning a confirmed data breach, a triennial review of ALPR
effectiveness, consideration of new developments affecting ALPR technology and law, as well as
removal of ALPRs when appropriate; and

WHEREAS , limiting the City's fixed ALPR network to appropriate points of entry will permit the MPD
to retain the investigative and public-safety benefits of ALPR technology while reducing the potential
for routine collection of information concerning vehicle movements within residential neighborhoods
and other areas of the City.

NOW, THEREFORE, BE IT RESOLVED, that the Board of Aldermen of the City of Milford hereby
resolves the following:

e Reduction of Fixed ALPRs

The Milford Police Department shall reduce its fixed ALPR network so that fixed ALPRs are deployed
solely at points of entry into the City of Milford.

e Seven-Day Data Retention

The MPD shall maintain a maximum ALPR data-retention period of seven (7) days. ALPR data shall
be automatically deleted following the seven-day period unless the information has been lawfully

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preserved in connection with a specific criminal investigation, prosecution, warrant, lawful
preservation request or other circumstance expressly authorized by applicable law and the City's
ALPR ordinance.

e Access Restrictions

Access to the City's ALPR system shall be limited to authorized personnel with unique user
credentials, requiring two-factor authentication. All searches shall be logged and subject to audit.

e ALPR Administrator

The MPD shall designate an ALPR Administrator responsible for administration and oversight of the
City's ALPR program, including user authorization, training, access controls, audit review, retention
and deletion compliance, vendor coordination, complaint review and preparation of required reports.
The ALPR Administrator shall conduct or cause to be conducted weekly audits of ALPR system
access and searches to identify unauthorized, excessive or otherwise inappropriate use.

e Data Breach Notification

The MPD shall establish procedures requiring prompt notification to appropriate City officials and
affected persons, when required by law, upon confirmation of unauthorized access to or a breach of
ALPR information.

e Triennial Review

At least once every three (3) years, the MPD shall conduct a comprehensive review of the
effectiveness, necessity, deployment, privacy implications, retention period, security and continued
operation of the City's ALPR program. The review shall consider investigative value, searches,
investigative leads, arrests or recoveries assisted by ALPR information, complaints, audit findings,
security incidents, changes in technology or law, community concerns and whether individual ALPR
locations remain justified. The results shall be provided to the Public Safety Technology Review
Committee, Police Commission and Board of Aldermen.

e Codification by Ordinance

The Board of Aldermen hereby directs the Ordinance Committee, in consultation with the City
Attorney, Mayor, Police Department and Board of Police Commissioners, to prepare and present
proposed legislation to codify the substantive provisions of the Milford Police Department's General
Order Chapter 1.80, as well as the points outlined above, into the Milford Code of Ordinances.

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