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14 <br />One logical place to start would be the "Point in <br />Time" count (or "PIT Count"), a federally required <br />census of the homeless population. However, the PIT <br />Count of the unsheltered population is conducted only <br />once every two years.9 Thus, at most times the PIT <br />Count information will be significantly out of date, <br />especially given that homeless populations fluctuate <br />dramatically. While governments may attempt to <br />adopt enforcement policies based on the most recent <br />PIT Count, it is far from certain that courts will treat <br />the PIT Count as a safe harbor. <br />Any attempt to count the homeless population <br />more frequently —for example, on any day when the <br />local government would wish to enforce its public <br />sleeping or camping ordinances —would be impossibly <br />expensive and difficult. As Judge Smith noted, <br />someone would have to "painstakingly tally the <br />number of homeless individuals block by block, alley <br />by alley, doorway by doorway." Pet.App. 16a (M. <br />Smith, J., dissenting from denial of rehearing en bane). <br />In Los Angeles, for example, this task requires three <br />days even with the participation of thousands of <br />volunteers —and still fails to produce a complete count. <br />Pet.App. 16a. <br />Further, the problems of counting the homeless <br />population are compounded by the fact that, for <br />purposes of the decision below, not every individual <br />sleeping on the streets should be counted. As the <br />B See County of Orange, Everyone Counts: 2019 Point in Time <br />Final Report 13 (July 30, 2019); Pet.App. 36a-37a (noting that the <br />most recent available data for Boise was from 2016, and claiming <br />that the `TIT Count likely underestimate[d] the number of <br />homeless individuals" in the area). <br />