# Citizen Flock FOIA and ASP Withholding Strategy In November–December 2025 a private citizen submitted an Arkansas FOIA to ASP for records on Flock Safety cameras, ALPRs, and similar surveillance technology. The load-bearing content is **internal**: [[Dennis Overton|Lt. Overton]] annotates the request for DPS Attorney [[Ryan Roach]], recommending denial grounds — while candidly flagging that ASP's own "investigative sensitivity" argument would reveal that the data is shared beyond ASP. This documents ASP's FOIA-response posture on ALPR from the inside. > [!note] Requester privacy > The requester is a private individual exercising FOIA rights, not a public actor. Consistent with this wiki's convention (documenting the conduct of power, not the private details of individuals), the requester's name and personal email are not reproduced. The citable conduct here is that of the public officials. ## What's inside ### `RE_ Flock FOIA - ASP.msg` (2025-11-16 → 12-08) The underlying FOIA (submitted to `[email protected]`, 2025-11-16) sought, among other things, *"A list of all locations where Flock Safety cameras, automated license plate readers (ALPRs), or similar surveillance devices are currently installed or have been installed within the past three years, including street addresses, intersections, or GPS coordinates"* and all related *"contracts, agreements, memorandums of understanding, purchase orders"* (Tier-1 corpus, `RE_ Flock FOIA - ASP.msg`). **Overton's interlineated coaching to counsel.** On the location request: > *"This one is an easy denial in my opinion. It can be argued that specific locations can be detrimental to ongoing/active LE investigations, effecting local, state and national investigation from multiple agencies, not just ASP. (Be careful with that language though, as then it is clear that the information is available outside the ASP. Flock is different, because they list their camera locations on their transparency website, and by default, that info is out there, so agencies with Flock must reply."* (Tier-1 corpus, `RE_ Flock FOIA - ASP.msg`). On the contracts request, Overton concedes the openness of fiscal records: *"any document dealing with the expenditure of public funds is likely going to be open to foia…"* (Tier-1 corpus, same file). **Counsel's posture.** [[Ryan Roach|Roach]] frames the triage — *"The first request looks to be a request for information rather than records, but I believe we have records responsive to the final 3 requests"* — and, after Overton's input, *"Im gonna talk with the legal team about all of this and get back with you tomorrow."* (Tier-1 corpus, same file). ## Key takeaways - **ASP's ALPR FOIA-response posture is documented from the inside.** Overton recommends denying camera-location requests on active-investigation grounds while conceding fiscal records are "likely going to be open to foia" (Tier-1 corpus, `RE_ Flock FOIA - ASP.msg`). This is direct evidence of how ASP reasons about what to withhold. - **A candid admission of multi-agency data sharing.** Overton warns that the very argument for withholding locations — that they affect *"local, state and national investigation from multiple agencies, not just ASP"* — would *"make it clear that the information is available outside the ASP"* (Tier-1 corpus, same file). ASP internally recognizes its ALPR data reaches beyond ASP, a point in tension with any narrow "we just run our own cameras" framing (compare [[T006 - ASP ALPR Oversight Disclaimer vs Statewide Coordination Role|T006]]). - **Overton distinguishes Flock's transparency posture.** He notes *"Flock is different, because they list their camera locations on their transparency website… so agencies with Flock must reply"* (Tier-1 corpus, same file) — an acknowledgment that Flock's public transparency site changes the FOIA calculus, which ASP's non-Flock ELSAG deployment avoids. - **Overton is the substantive advisor on ASP ALPR FOIA responses.** As with the [[Federal Public Defender FOIA and the No-LPR-System Position|Federal Public Defender request]], counsel relies on Overton for the operational and strategic input (Tier-1 corpus, same file). - **Later releases materially narrow the practical location-secrecy claim.** The same ASP production released five exact F4 install coordinates and HIDTA-EOC corridor/direction names, while ARDOT L000259 released nineteen exact ASP/AHP MOU points ([[F4 Installs and Site Nomenclature]]; [[Statewide Traffic Control Devices Export]]). This does not reveal the unproduced final disposition of the 2025 request or prove every point was operational, but it means exact ASP/AHP infrastructure coordinates are now documentary facts in the Tier-1 corpus rather than information the wiki must suppress. ## Cross-references - [[Federal Public Defender FOIA and the No-LPR-System Position]] — the parallel ALPR FOIA where the "have vs. use" position was contested. - [[Flock Safety, Inc.]] — the vendor named in the request; its transparency-site posture is invoked by Overton. - [[2026-06-05 Roach Route Map and Item-4 Disclaimer]] — Roach's later handling of Joshua Dunlap's own ASP ALPR FOIA. ## Open questions / follow-ups 1. **What did ASP ultimately release or deny?** This is ASP's *sent* mail; the final disposition is not in the extracted set. 2. **Is this the same posture ASP applied to later ALPR FOIAs** (including the Federal Public Defender request and Joshua Dunlap's 2026 request)? The internal reasoning here is a template worth comparing against actual dispositions.