Riverside County’s encroachment permit record for its Flock Safety camera deployment is a case study in what happens when a county rubber-stamps a surveillance system and forgets to do the paperwork. Or the oversight. Or the legal prerequisites. Or, for 13 months, the permits.
In 2021, the Riverside County Transportation Department issued the first of three encroachment permits to the Riverside County Sheriff’s Department for the installation of Flock Safety cameras on county roads. By October 2023, the Board of Supervisors had unanimously approved a $6.9 million contract to expand the program to 538 cameras.
Four and a half years later, the Riverside County Sheriff’s Department’s Flock Transparency Portal shows the sheriff uses 1,718 “LPR and other cameras.”
A CPRA request to the Transportation Department produced three permits, a handful of emails, and a sworn declaration that may be more interesting than the permits themselves.
The Permits
Riverside County Ordinance 499 governs encroachments within county highway right-of-way. Any structure placed in the road right-of-way — including 13-foot surveillance poles with cameras and solar panels — requires a written permit from the Director of Transportation.
Three such permits were issued:
ENC21120546 (December 10, 2021 – September 1, 2023)
Originally authorized two cameras. Expanded through riders to cover 33 named locations and a blanket permission to add more via individual location notifications (RD Form 136).
ENC23110539 (November 14, 2023 – November 14, 2024)
An annual blanket permit covering “various county road rights of way.” This permit was explicitly styled as an extension of the first.
ENC25061408 (December 5, 2025 – December 5, 2026)
Another annual blanket permit, the current one. It was issued with a single RD Form 136 notification on file — one camera, in Anza — and four total documents in the folder.
No Permit, No Problem
The second permit expired on November 14, 2024. The third was not issued until December 5, 2025.[1]
During those 13 months, the cameras did not come down. The $6.9 million contract continued and Flock’s operations apparently continued without interruption under Chad Bianco’s watch.
Ordinance 499 Section 6 prohibits anyone from “constructing, installing, operating, or maintaining” any structure in the county right-of-way without a permit. That’s not limited to construction — it covers the cameras just sitting there running.
The permits themselves reinforce this. The authorized work is not just installation — each permit grants permission to “install, operate and maintain” the cameras. Each is “to be strictly construed and no work other than that specifically mentioned above authorized hereby.”
When the permit expires, so does the authorization to operate and maintain. The first permit’s void date was extended twice via riders — acts that only make sense if the date is an operative constraint. And in December 2025, the county issued a replacement permit with identical scope and authorization language. If the prior permit was still valid, the replacement was redundant.
The second permit’s own conditions made the obligation explicit. Condition M12 on ENC23110539 states: “Upon expiration of this permit, the permittee shall remove the temporary poles and cable.”[2] The current permit repeats this language and adds: “It is the Permittees responsibility to maintain a valid permit.” The permittee did neither.
Nothing was removed. No extension was obtained. No replacement was issued for thirteen months.
The CPRA request covered all encroachment permits issued between January 2020 and March 2026. The county produced exactly three. The county certified under oath that no other encroachment permit, extension, or authorization exists.
No Application, No Problem
The county requires each permit application to be “in the name of the person, agency, entity, or authorized agent owning the encroachment and controlling the construction of the work.” It adds that the county “would require documentation of the Utility Owner’s authorization of a third party seeking a Permit on behalf of the Utility Owner.”
The applications list “Flock Safety” as applicant and owner — correctly, since Flock owns and installs the cameras. Three different Flock employees signed applications over the life of the program: Danny Campos, Will Warren, and Derek Porcella.
But the permits were not issued to Flock. They were issued to “Riverside County Sheriff Department C/O FLOCK SAFETY.” The Sheriff’s Department is the permittee on all three permits — holding the obligations, the liability, the strict construction clause — despite never having applied for them. There is no application from the Sheriff’s Department on file. No one at the Sheriff’s Department signed anything.
Flock applied. The Sheriff’s Department got the permits. And no authorization exists connecting the two. The county certified under oath that there are no letters of agency, powers of attorney, or similar documents from Flock authorizing the Sheriff’s Department — or anyone — to hold encroachment permits on Flock’s behalf. Nor are there any documents from the Sheriff’s Department authorizing Flock to apply on its behalf.
The county seemingly decided on its own that a permit applied for by “Applicant/Owner: Flock Safety” should be issued to the Sheriff’s Department. And Flock apparently decided that it could treat that permit as its own and forge ahead with installation.
And this didn’t happen once. The third permit application was byte-for-byte identical to the second one. The exact same PDF was filed under both permit numbers. Same date (November 7, 2023), same agent (Derek Porcella), same Flock Safety mailing address in Atlanta, same description of work, same signature.
And the same outcome: the new permit was also issued to the Sheriff’s Department, not the applicant.
No Authority, No Problem
This is the part that likely matters most, legally.
Riverside County Ordinance 499 Section 6 states that permits “will be issued for only Utility purposes” on county highways. The ordinance defines “Utility” as water, sewer, irrigation, gas, petroleum, cable TV, electric, and communications facilities. Surveillance cameras are none of these.
For non-utility encroachments, the Director of Transportation may issue a permit if satisfied of three things: (1) the use is in the public interest, (2) there will be no substantial injury to the county highway or impairment of its use, and (3) the use is reasonably necessary for the functions of the applicant.
Flock’s cameras are commercial surveillance products owned and operated by a private company. The Sheriff’s Department has a software service contract to access Flock’s data — both inside and outside Riverside County.
The Director’s finding that these cameras satisfy the three-prong test in Section 6 would be the legal prerequisite for every permit in the chain. Without it, the Director had no authority to issue any of them.
No such finding accompanied any permit application.
Whether such a finding could survive scrutiny is a separate question. Is a private company’s occupation of public right-of-way to operate a for-profit surveillance network “in the public interest”? Is it “reasonably necessary” for Flock’s functions that its cameras sit on county roads rather than, say, private property with the owner’s consent?
No Locations, No Problem
Riverside County has contracted for over 500 Flock cameras. Not all of those are on county roads. Some are on city streets, some on Caltrans state highway right-of-way, some on private property. The permit documents include handwritten annotations identifying specific cameras as “NON COUNTY/city,” “CALTRANS,” and “City St/Grand Terrace.”
Someone at the Transportation Department reviewed the camera deployment list, saw cameras on roads the county doesn’t control, and marked them accordingly. But no formal record of that analysis was ever created.
I asked for any records reflecting which of the 500+ cameras are within county highway right-of-way, or any determination that specific cameras did not require a permit. Again, the county certifies that no such records exist.
When the county’s records custodian was asked about the gap between 500+ contracted cameras and the roughly 80 installations documented in the permits, the only response was informal and vague: “some locations may not have been permitted as they could be private or non county maintained roads.”
That’s it. No spreadsheet, no memo, no analysis. The county issued blanket permits for “various county roads” — possibly subject to the typical Flock “deployment plan” — but never really determined which roads it was talking about.
No Traffic Plans, No Problem
Every encroachment permit in the production requires a traffic control plan under Condition C05 — a safety document showing how workers and traffic will be protected when someone is installing equipment in a roadway. The current permit, ENC25061408, goes further and requires the TCP to be signed by a Professional Engineer.
The county produced one set of traffic control plans: for the Spencer’s Crossing project, eight cameras, prepared in February 2023 under the first permit.
No other traffic control plans exist.
That’s a 98% noncompliance rate.
No Fees, No Problem
Section 15 of the ordinance requires that permit fees be paid “at or after the time application is filed, but in any event before the Permit is issued.” The fee fields on every application in the entire production — all three permits, every application, every rider — are blank.
Section 16 exempts public agencies from permit processing fees if they have “lawful authority” to use the right-of-way for the permitted purpose.
Flock applied in its own name. But the permits were issued to the Sheriff’s Department — a public agency — triggering the fee exemption. A private surveillance company applied, a public agency was listed as permittee, no fees were charged, and no one documented why.
No Records, No Problem
None of the above rests on inference or supposition. Each point traces back to a single document: a Declaration of Custodian of Records executed March 23, 2026, signed under penalty of perjury by the county’s records custodian.
The Declaration addresses each follow-up item individually and certifies that the county has no responsive records. This is not a case where documents might exist but were missed. This is the county’s official position, under oath, that these records do not exist.
This is not some isolated paperwork hiccup in Riverside County from a well-meaning county official unable to find records that really exist. Across the country, Flock cameras go up on public roads under permits that no one reviews, with safety standards no one enforces, issued to applicants that no one verifies. Flock routinely operates cameras with expired permits or without an active contract. Riverside County is one of many.
The Law in “Law & Order”
Riverside County’s surveillance camera program operated for over four years under three encroachment permits issued to an agency that never applied for them, based on applications from a company that never received them, without the legally required public interest determination, without traffic control plans for the vast majority of installations, without fees, and — for 13 months — without a permit at all.
Each of these permits was issued to the Riverside County Sheriff’s Department. Flock — the owner/operator listed on the permit applications — never received a permit but still installed and continues to operate hundreds of surveillance cameras without a valid permit.
The $6.9 million contract belongs to Sheriff Chad Bianco’s office. The entire Flock deployment — from the first two cameras in 2021 to the 1,718 “LPRs and other cameras” now in Flock’s system under the sheriff’s name — occurred during his tenure.
Ordinance 499 Section 18 provides that any person who operates without a required permit, or who violates permit conditions in a way that jeopardizes person or property, is guilty of a misdemeanor punishable by fine, imprisonment, or both.
The wrong permittee is not a technicality. A 13-month gap is not a technicality. Not paying the fees is not a technicality. These are all separate material flaws resulting in unpermitted occupation of public right-of-way by a corporation, based on a permit issued to a sheriff tasked with enforcing the county ordinance that makes it a crime.
The Order in “Law & Order”
The county does not know, from its own records, which cameras needed permits. It has no mechanism to determine which cameras are on county roads, which are on state highways, and which are on someone else’s property.
The Director of Transportation issued permits to the Sheriff, who had never applied for any, without the required public interest finding, and without traffic control plans for all but one installation. When the second permit expired, no one acted. When a replacement was finally applied for thirteen months later it was with the same application — literally the same file — Flock had used for the prior permit. The new permit was also issued to the Sheriff.
That permit process was handled by a Permitting Manager at Flock with over a decade of experience in right-of-way permitting. None of these issues were discovered when processing the permits or through any audit or investigation in three years. Neither Flock’s permit expert, the Sheriff’s Department, nor the Transportation Department raised a flag.
That process — namedrop Chad Bianco, skip the fees, ignore the regulations — is the law and order he now offers California.
Riverside County was asked to comment, but did not provide a response.
There was also a smaller, ~2.5 month, gap between the first and second permits. That could arguably still fall under the category of “minor administrative hiccup.” ↩︎
M12 refers to “temporary poles and cable.” Whether that applies to Flock’s permanent camera poles or only to construction-related temporary equipment is arguable. The first permit (ENC21120546) used different language — removal “upon the request of the RCTD” — which is discretionary. But ENC23110539 changed the trigger to “upon expiration,” making it automatic. Even if M12 does not apply to Flock’s poles, both the permits’ own scope of work (“install, operate and maintain”) and Section 6 of Ordinance 499 independently prohibit operating or maintaining any structure in the right-of-way without a valid permit. ↩︎