# ARDOT Right-of-Way Permitting for ALPR The Arkansas Department of Transportation's permitting framework for **placing surveillance cameras (specifically automatic license plate readers) in state-highway right-of-way**. Conway PD's Flock deployment of 14 ALPRs in Conway state-right-of-way is a documented instance ([[ARDOT Right-of-Way Permitting — Case 941655 and Permit SP-08-2025-0036]]); UCA Campus PD's separate Flock deployment in Conway city right-of-way is a contrasting case where ARDOT permitting did not apply ([[UCA Franchise Request — UCA Campus PD Flock Deployment in Conway Right-of-Way]]). ## How ARDOT permits ALPR The Conway PD case 941655 illustrates the procedural structure ARDOT applies. Two distinct permits are issued: 1. **Traffic Control Device Permit and Agreement (TCD permit)** — issued by ARDOT's TSMO Division at the state level. For Conway, this is **Permit No. 1948**, issued December 31, 2025, covering *"Installation of 14 ALPRs in Conway, Arkansas. Hwy 60, Sec 0, LM 1.560, LM 1.580, LM 3.303, LM 3.464, 5.148, & LM 5.167; Hwy 64, Sec 9, LM 0.057 (EB & WB), LM 2.333 & LM 2.336; Hwy 65, Sec 9B, LM 0.214 (EB & WB); & Hwy 365, Sec 10, LM 0.829 & LM 0.980."* 2. **District Special Permit** — issued by the relevant ARDOT District Engineer with conditions on traffic-control during installation, indemnification, maintenance, removal, MUTCD compliance, storm-water, etc. For Conway, this is **Special Permit SP-08-2025-0036**, issued February 9, 2026 by District 8 Engineer David Ross, addressed to *"Mayor Bart Castleberry, City of Conway."* The application sequence runs: - The municipality submits a support letter on Mayor's letterhead (for Conway, Castleberry's 2025-02-11 *"Flock Safety Poles"* letter). - The vendor (Flock Safety, via its permitting contact Cody Boudreaux) submits the engineering package to the ARDOT District Permit Officer (Conway: Tabie Richards at District 8). - ARDOT TSMO reviews the engineering specs (route, section, log mile, MUTCD). - ARDOT issues a TCD permit (TSMO Division Head signature) and a District Special Permit (District Engineer signature). - The municipality posts a standing bond (Conway: $5,000) and the Mayor countersigns the TCD permit. ## What the ARDOT permit does and does not cover - **Covers:** the physical placement of the cameras in state-highway right-of-way; traffic-control compliance during installation; the City's ongoing obligation to remove the cameras if ARDOT determines removal is necessary for highway purposes. - **Conditions:** *"the cameras shall only be used for law enforcement purposes."* This is the only substantive scope-limitation in the permit. - **Does NOT cover:** the surveillance program substance — data retention, data sharing, hot-list use, federal-LE access, audit-log practices, public-records-disclosure posture. ARDOT does not regulate the surveillance program; it regulates the device placement. ## The permitted-vs-deployed mismatch For Conway PD, ARDOT permits cover 14 cameras (the cameras that sit in state-highway right-of-way). The CPD's broader deployment (June 2025 snapshot: **26 cameras** — see [[CPD Strategic Reporting to Mayor's Office 2024-2025]]) extends beyond state-highway right-of-way. Cameras at non-state-right-of-way locations (Conway-municipal streets, county roads, or private property) are outside ARDOT's jurisdiction and have their own permitting pathway (or none). The wiki notes the mismatch without resolving where the additional 12 cameras' permits are held. ## The UCA Campus PD contrast The University of Central Arkansas Campus PD's separate Flock deployment (Flock case 01197561) is permitted **city-side** through the City of Conway Mayor's Office, not state-side through ARDOT — because the UCA-proposed locations are on Conway municipal right-of-way, not state-highway right-of-way. See [[UCA Franchise Request — UCA Campus PD Flock Deployment in Conway Right-of-Way]]. This contrast clarifies that the **applicable permitting authority is jurisdictional**, not vendor-specific: - State-highway right-of-way → ARDOT permit. - Municipal right-of-way → City permit (in Conway's case, through the Mayor's Office). - Private property → no public-right-of-way permit required (private agreement with property owner). ## Notes - The 2023 ARDOT engagement under Chief William Tapley ([[2023 Pre-Flock LPR Support Letter to ARDOT]]) was Mayor Castleberry's prior LPR-supportive ARDOT correspondence. Whether the Tapley-era LPR pilot involved an ARDOT permit (TCD or special) or merely a support letter is not visible in this corpus. - ARDOT's permitting framework is statute-derived — Ark. Code Ann. §§ 27-52-104 and 105 give the State Highway Commission authority over traffic-control devices on state highways. The federal-law backstop is Section 109(d), Title 23, U.S. Code. - Archiving ARDOT's permitting framework itself (the rules, not Conway's permit document) remains an open research question.