# 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 proposal for three points in Conway city right-of-way is a contrasting request 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). Lonoke County's Permit 1924 adds a District 6 example. ARDOT issued the permit on 2025-10-06 for six ALPRs across Highways 31, 38, 70, 165, and 294, and both parties signed on 2025-10-07. The associated plan supplies six exact coordinates, but the production contains no separate preconstruction, inspection, acceptance, or as-built record ([[Lonoke County Flock Contract ARDOT Permit and Camera Locations]]). - 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. Benton County's P1873 packet adds a District 9 county example. The TCD permit was issued 2025-05-06 for Highway 12, section 1, log mile 0.218; the District letter dated 2025-05-21 authorizes a Flock camera and records a `$1,000` standing bond. The approved plan gives `36.276600, -94.579146`, looking southeast, for `#07 W HWY 12 @ GENTRY - RELOCATION`. Its completion-return page is blank, so the packet establishes authorization and design location rather than completed installation or acceptance ([[Benton County P1873 Flock Relocation Permit]], pp. 1, 3–6, 11). ## 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 [[University of Central Arkansas Police Department]]'s separate Flock proposal (case 01197561) sought **city-side** permission through the City of Conway Mayor's Office, not state-side permission through ARDOT. The packet supplies three exact proposed municipal-right-of-way points: P#006 Moix/Dave Ward southbound `35.06923350960282, -92.45939698920121`; P#007 Moix/South Donaghey westbound `35.0676478379084, -92.45487526938103`; and P#008 Farris/Dave Ward northbound `35.070623766020645, -92.46323428989541` ([[UCA Franchise Request — UCA Campus PD Flock Deployment in Conway Right-of-Way]], pp. 4-6). No granted City permit or installation record appears in the production. 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). ## Sherwood — a mixed-stage, mixed-jurisdiction deployment Sherwood's July 2026 inventory contains 15 current sites, but ARDOT L000259 supplies issued-permit rows for only P1871 (two locations), P1888, and P1915; P1855 appears in a separate permit packet but not the CSV ([[Statewide Traffic Control Devices Export]]). Other Sherwood sites were expressly removed from ARDOT review because they were outside state right-of-way ([[Sherwood Multi-Site Application Case 261931]]; [[Sherwood Landers Warden and Wildwood Applications]]). The Sherwood files also narrow the Conway-derived description of a clean two-permit sequence. An issued TCD form may still lack a signed local agreement or District special permit; a City completion form is not a final-inspection or final-acceptance record; and an installation notice can postdate a completion form. See [[Sherwood ALPR Permitting and Operational Status]] and [[T009 - Sherwood ALPR Completion and Installation Chronology]]. ## Hot Springs P1977 — executed permit, incomplete operational lifecycle Hot Springs P1977 supplies ten exact `LPR + Video` final-plan points, each labeled as proposed equipment. The municipal copy is applicant-blank, but ARDOT's later R033097 response supplies both TCD signatures, the signed District special permit, and the record that Flock's required `$10,000` bond was received ([[Hot Springs P1977 Flock Camera Plan]]; [[Hot Springs P1977 Countersigned Permits and Execution Chain]]). That resolves [[T019 - Hot Springs P1977 Signed Label vs Incomplete Permit and Deployment Record]] as a signature-copy conflict. No completion, inspection, acceptance, as-built, activation, or current-inventory record appears; see [[T054 - Hot Springs P1977 Executed Authorization vs Missing Closeout and Operational Proof]]. ## Notes - Jonesboro's five packets supply the corpus's clearest examples of the applicant returning ARDOT's completion sheet after work. The sheets say they are returned "[u]pon completion of permitted work" and identify eleven ALPR points under P1881, P1889, P1967, P1969, and P1982. They document the City's completion representation, not an ARDOT inspection, acceptance, or as-built coordinate survey ([[Jonesboro ARDOT ALPR Permit Packets P1881 P1889 P1967 P1969 P1982]]). - Benton County P1873 preserves the opposite closeout state: the included return sheet has no completion date or returned signature, even though the permit and plan are approved ([[Benton County P1873 Flock Relocation Permit]], p. 6). - P1969 demonstrates why lifecycle fields remain source-specific: Jonesboro signed its completion return on 2026-04-16, while `TrafficControlDevices.csv` line 428 still labels the exact point `Pend Sign`. Both records remain visible at [[T038 - Jonesboro P1969 Completion Return vs Pending-Sign Export]]. - 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. - Axon's rule comment requested a bond exemption for agency-owned LPRs; ARDOT declined and said the bond protects right-of-way restoration. The disposition does not state that every LPR installation requires a bond, only that a required bond serves that purpose ([[July 10 2026 Public Comment Dispositions]], `Sheet1!C11:E12`). - The ARDOT traffic-control-device CSV is not treated as a complete statewide ALPR-permit index: Sherwood P1855 is absent and known Sherwood ALPR rows contain no ALPR/Flock keyword ([[Statewide Traffic Control Devices Export]]).