Why a standard
A jurisdiction that cannot answer these twelve questions is not running a safety program. It is running a revenue program it has not measured.
When a city wants to use race-conscious contracting remedies, courts require it to produce evidence first. That requirement created the disparity study, a standardized instrument with a published methodology that any jurisdiction can be measured against. Automated traffic enforcement has no equivalent. Programs collecting hundreds of millions of dollars operate for years without any structured public evaluation of whether they work, who pays, or what happens to people who cannot.
Every question below is answerable from records a jurisdiction already holds. That is the design principle. This is not a demand for new studies. It is a request that cities look at what they already have and publish it.
We are publishing this standard for anyone to use. We do not sell evaluations and we do not intend to.
The District cannot answer seven of the twelve from published records.
Below is the standard applied to DC. The answers marked "not published" are not accusations. They are the result of asking the District's own datasets and public records for the information and finding it absent.
| Dimension | What DC's records show | Status | |
|---|---|---|---|
| 1 | Consent | Automated enforcement has never appeared on a District ballot. There is no periodic reauthorization requirement. Public record. | Fails |
| 2 | Site-level safety effect | DDOT does not publish before-and-after crash outcomes for any camera site. We computed it ourselves for the 108 speed cameras activated in 2024: crashes within 500 feet fell 12.9 percent from 2023 to 2025, against a citywide decline of 12.6 percent. Derived from DDOT's own crash file. Cameras are sited where crashes were already elevated, so regression to the mean alone should have produced a larger drop. | Not published |
| 3 | Siting justification | No public record documents whether each camera location was selected on crash history or on expected violation volume. Requested. | Not published |
| 4 | Engineering first | The District cannot answer this even in principle from its published records. DDOT maps 2,916 speed humps and raised crosswalks with precise coordinates, but the installation date is recorded for 10 of them. The INSTALL_DATE field is empty for all 2,916. By contrast, all 318 speed, red light and stop sign cameras carry an activation date precise to the day.DC can say exactly when it began issuing tickets at a location. It cannot say what year it made that location physically safer. Without an installation date, no before-and-after evaluation of engineering is possible. | Not recorded |
| 5 | Fine proportionality | Fines are flat. A $100 citation is 0.07 percent of median household income in Ward 3 and 0.21 percent in Ward 8, so the same violation costs a Ward 8 household 2.9 times as much relative to income. After the 30-day penalty, a $240 balance reaches 0.49 percent of Ward 8 median income. DDOT citation data joined to Census ACS by ward. | Fails |
| 6 | Revenue dependency | Camera revenue flows to the general fund. The exact split between any dedicated safety fund and general purposes is not published. Requested from the Office of the Chief Financial Officer. | Partial |
| 7 | Collection and escalation | Collection fell from 80.5 percent in FY2023 to 73.5 in FY2024 to 63.2 in FY2025. The District assessed $380,978,350 in FY2025 and collected $240,588,609, leaving $140,389,741 uncollected in a single year. The share of revenue from late penalties as distinct from base fines is not published. DDOT records obtained under FOIA R011522-072226. | Partial |
| 8 | Enforcement consequences | The District's public boot and tow dataset ends in 2020 and its data feed has been offline since April 2025. There is no published record of boots, tows, or vehicle dispositions during the camera expansion. Requested. | Not published |
| 9 | Geographic incidence | DDOT states its automated enforcement dataset does not contain the ward of the registrant's address, so citations and fines cannot be attributed to where the people paying them live. DDOT's own response to FOIA R011522-072226. Requested from DMV. | Not published |
| 10 | Vendor incentives | No public record establishes whether the camera vendor or the impound auction vendor is compensated per citation or per vehicle. Requested. | Not published |
| 11 | Due process | Across six months of 2025 the District issued 1,521,142 camera citations. Just 12,945 show any adjudication outcome, or 0.85 percent. Of the citations that were adjudicated, 43.7 percent were dismissed. The number of notices returned undeliverable is not published. DC monthly violation files, January through November 2025. See below on what this does and does not mean. | Fails |
| 12 | Data governance | No published policy establishes retention limits for automated enforcement and plate-reader data, or bars its transfer to federal agencies or commercial data brokers. The District's own Police Complaints Board has flagged retention and sharing concerns. Requested. | Not published |
Status definitions. Fails: the District's records answer the question, and the answer does not meet the standard. Partial: partly answerable, with a material component unpublished. Not published: the District does not publish the information, or has stated it does not hold it. Every "requested" note refers to a pending Freedom of Information Act request.
DC records the day a camera starts collecting. It does not record the year a speed hump went in.
318 cameras: activation date for every one. 2,916 speed humps and raised crosswalks: installation date for ten.
We set out to run the same test on engineering that we ran on cameras. Take each speed hump, count crashes within 500 feet in the year before and the year after it was installed, and see whether physical road changes outperform enforcement at the same locations. It is the most useful comparison available, and if engineering wins it settles a great deal.
It cannot be run. DDOT publishes the location of 2,916 traffic calming devices. The INSTALL_DATE field is empty for every single one, and the year is recorded for ten. We checked the rest of the District's traffic calming data for a substitute and there is none: pavement markings and medians carry no date field at all, and the traffic barrier layer records only the year an asset was surveyed, not installed.
We do not think this is deliberate. Asset inventories and capital project records are kept by different teams under different obligations. But the consequence stands on its own: the District has built the records required to audit a revenue program and has not built the records required to evaluate a safety program. You cannot measure what you did not date.
We have asked DDOT for the installation dates. They exist in capital project and work order files even though the public map omits them, which makes this a formatting problem rather than a records problem, and an easy request to grant.
Fewer than one in a hundred people contest. Of those who do, close to half win.
1,521,142 camera citations. 12,945 adjudicated. 5,663 dismissed.
Across January through November 2025, the District issued more than 1.5 million camera citations. Fewer than 13,000 of them, 0.85 percent, show any adjudication outcome at all. Among those that were adjudicated, 43.7 percent were dismissed. In four of the six months we examined, the dismissal rate ran between 47 and 57 percent.
Two readings of that are possible and we want to be careful about which one the data supports.
What we cannot say is that half of all camera tickets are invalid. People who contest are not a random sample. Someone who knows the camera was mis-set, who was not driving, or who has documentation is far more likely to go through the process than someone who simply cannot pay. A high dismissal rate among people who chose to contest does not tell you the dismissal rate for everyone else, and any estimate that multiplies the two together is wrong.
What we can say is that the adjudication process, when used, overturns citations at a substantial rate, and it is almost never used. Whatever explains that gap, it is worth the District finding out. If people are not contesting because they do not know they can, that is a notice problem the city can fix. If they are not contesting because taking a weekday off work to attend a hearing costs more than the ticket, that is a design problem the city can fix. If they are not contesting because they have concluded it will not matter, that is a legitimacy problem, and it is the most serious of the three.
One data point suggests how the District itself values the right. Its Income-Based Fine Reduction Pilot, the only income-based relief the city has offered, required applicants to waive their right to contest in exchange for a 50 percent reduction on a single ticket. A jurisdiction that treats the right to a hearing as currency to be traded for a discount has already formed a view about what that right is worth.
We are asking the District to publish contest rates, dismissal rates, and undeliverable notice counts by ward, and to say plainly what it has done to inform people that adjudication exists.
What we are not doing
We are not issuing a grade. A composite score invites an argument about weighting, and that argument is a distraction. Disparity studies do not produce scores either. They produce a factual record.
The most important column above is not the one marked "fails." It is the one marked "not published." A program that has operated for years, assessed $882.6 million, and cannot say from its own records who pays, whether crashes fell at its own camera sites, or what happens to the people whose cars it takes, has not been evaluated. It has only been operated.
Using this standard
Anyone may apply this to any jurisdiction. If you do, we would like to see the result, including where it contradicts ours. If you find an error in our DC application, tell us and we will correct it publicly.
The underlying records for the DC application are posted: FY2023, FY2024, FY2025, exactly as the District produced them.