The Iowa DOT has a utility accommodation program. It has regulations governing that program. It has forms with safety standards printed right on them. It even has a process for verifying that permitted installations comply with those standards. What it does not have is any apparent interest in using any of it.
Back in November, I wrote about the Iowa DOT’s lack of a consistent permitting process. Further research shows that the DOT also lacks a verification process and an inspection process. The permits it does issue are approved based on plans that violate the safety standards printed on the application itself.
In the article What Is the Clear Zone and Why Is It Critical to Roadway Safety?, John Carlton, a licensed Professional Engineer, discusses “why the clear zone is important to the safety of roadway users and provide examples of commonly experienced violations that have resulted in personal injury litigation.”
This table is included on DOT’s standard utility accommodation form and shows the clear zone distances (ADT = Average Daily Traffic). The numbers matter: they are the minimum distance between a roadside obstacle and the travel lane that gives a driver a reasonable chance of recovery in a run-off-road event.
The Missing Permits
As noted in the previous article, the information in the permit applications for roadside cameras is sketchy at best. In some cases, they’re sketched-up screenshots of Google Maps by a Sheriff’s Deputy, and signed off on by the Sheriff, with little to no helpful descriptive information.
The plans above were submitted to, and approved by, the Iowa DOT.
The middle image shows the clearest violation: the minimum “acceptable clear zone” area, listed on the very form the permit was submitted on, is 12 feet. The plan shows “10–12 feet.” The DOT approved it anyway.
The Missing Failsafes
But at least there are failsafes. On paper. After construction, the DOT’s regulations require an “as-built” plan to be submitted with a certified engineer’s stamp. If a plan is not submitted, the DOT is authorized to perform an inspection at the permittee’s expense. This would uncover any shoddy work by unqualified site planners and straighten out any problems with approvals.
It turns out that the DOT does not follow its own regulations. Instead, it has replaced regulation with policy. In the words of my formal complaint:
For equipment installed under the utility accommodation program, Iowa Admin. Code 761—115.7(8) (2025) requires the utility owner “to submit to the department an as-built plan in an electronic format in accordance with department specifications.”
Iowa DOT writes that it maintains a policy that “[w]hen not submitted we accept the permitted plans as the asbuilt plan if the permittee did not contact us with a change.”
Iowa DOT confirms that for this installation “no as-builts were submitted,” and explains that “we identify the permitted plans as the as-builts.”
In other words: Iowa DOT does nothing, even when the camera is obviously installed in a way that appears unsafe. If it is somehow compliant, there is no information in any of the DOT’s records that would demonstrate that compliance.
It approves permits proposing non-compliant installations for “utilities” that are owned by private corporations and deliver no service to the public, based on the say-so of police officers and sheriff’s deputies.
To make matters worse, Flock—the contractor listed on many of these permits—is not even a licensed contractor in the State of Iowa.
The DOT’s Response
I brought these issues to the attention of Iowa DOT director Scott Marler.[1]
His responses met expectations:
The Iowa Department of Transportation acknowledges receipt of your request, sent to Director Marler on January 12, 2026.
We understand the importance of establishing a formal policy for license plate readers and have been actively working on this matter since last fall. At that time, we prohibited any additional installations of LPR’s on DOT ROW until the policy is put in place.
We aim to finalize our ALPR policy by the end of February. We appreciate your expertise and insights on this subject and will ensure that our policy team has access to review your contributions.
To which I replied:
Thank you for the response. While I appreciate that the Department is drafting a specific ALPR policy, the core of my concern is not a lack of policy, but a systemic failure to enforce existing Iowa Code and Administrative Rules.
The DOT recently finalized its EO10 review, affirming that the existing regulations—including those governing the Utility Accommodation Program and contractor licensing—are necessary and effective. A new policy cannot retroactively excuse the Department’s decision to ignore those regulations and standards.
Regarding the “prohibition” on new installations, there appears to be a disconnect. Since the date you claim a prohibition was enacted, Flock has expanded its network along the I-380 corridor in Cedar Rapids, including in the I-380 ROW on state-owned land, and in other municipalities.
If the DOT has been working on this issue since last fall, it raises the question of why the Department continues to allow unlicensed contractors to perform work and why these specific permits were not stayed or denied.
By declining to act in a meaningful way while unsafe installations (like the non-compliant “breakaway pole” on Hwy 52) put drivers at risk, the DOT is tacitly approving these hazards. In doing so, the Department assumes significant legal and financial liability for the State should a collision involving this equipment occur and foreseeably result in injury or death.
Note the DOT’s claim that it “prohibited any additional installations” since last fall. Since that date, Flock has expanded its camera network along the I-380 corridor in Cedar Rapids—including on state-owned land in the I-380 right-of-way—and in other municipalities. The moratorium appears to exist only in the DOT’s correspondence.
The DOT’s final response:
We greatly appreciate the time and effort you have invested in bringing these matters to our attention. Please be assured that we are investigating your allegations.
I will be sending in an open records request for the DOT’s new policy at the end of the month for Part III in this series, unless someone beats me to it.
If you’re in Iowa and you crash your car into a roadside camera, be sure to tell your lawyer about this post.
Permit Documents
The table below lists every LPR permit I have obtained from the Iowa DOT. This may be a complete set; it is emphatically not a complete accounting of cameras installed in DOT right-of-way. Many appear to lack permits entirely.
| Date | Permit / Municipality | Route |
|---|---|---|
| 2022-04-08 | IA-136 LPR | IA-136 |
| 2022-04-08 | US-30 LPR | US-30 |
| 2022-08-30 | Altoona PD — TCD Application CCP | — |
| 2022-08-30 | Altoona PD — TCD Application | — |
| 2023-01 | Council Bluffs US-275 — LPR TCD | US-275 |
| 2023-01-17 | Council Bluffs — Admin | — |
| 2023-01-24 | Council Bluffs US-275 — LPR TCD Approved | US-275 |
| 2023-05-08 | Permit | — |
| 2023-05-30 | South Sioux City PD — Woodbury County | — |
| 2023-10-06 | Ankeny PD — LPR Application | — |
| 2023-10-06 | TCD Application | — |
| 2023-12-22 | 85A-2023-034 — Story County | US-30 |
| 2023-12-22 | Story County Flock TCD | — |
| 2024-01 | Pleasant Hill PD | — |
| 2024-01 | Pleasant Hill | US-65 |
| 2024-01-23 | Pleasant Hill | IA-163 |
| 2024 | Indianola — LPR Application | — |
| 2024-05-10 | 483754 — Marshalltown PD | IA-14 |
| 2024-05-10 | 502480 — Newton PD | — |
| 2024-06 | Altoona | — |
| 2024-06-25 | Polk City PD | — |
| 2024-10-25 | 96A-2024-011 — Winneshiek County, Decorah | IA-9 |
| 2024-10-25 | Fayette County, West Plum St | IA-150 |
| 2024-10-25 | Fayette County, E Bradford St | US-18 |
| 2024-11-04 | 33A-2024-014 — Fayette County, Major Rd | IA-150 |
| 2024-11-04 | Fayette County, W Ave | IA-3 |
| 2024-11-15 | Fayette County, S Avenue | IA-3 |
| 2024 | 19A-2024-008 — Fayette County | US-63 |
| 2024 | 19U-2024-009 — Fayette County NHSX | US-63 |
| 2024 | 19U-2024-009 — Fayette County | US-63 |
| 2024 | 22A-2024-016 — Fayette County | US-52 |
| 2024 | 33A-2024-009 — Fayette County | US-18 |
| 2024 | 33A-2024-010 — Fayette County | IA-150 |
| 2024 | 33A-2024-013 — Fayette County | IA-3 |
| 2024 | 33A-2024-014 — Fayette County | IA-150 |
| 2024 | 33A-2024-015 — Fayette County | IA-3 |
| 2024 | 3A-2024-008 — Fayette County | US-18 |
| 2024 | 45U-2024-004 — Fayette County | US-63 |
| 2024 | 96A-2024-011 — Fayette County | IA-9 |
| 2024-12-16 | Sioux City PD | IA-12 |
| 2024-12-16 | Storm Lake PD — PTZ and LPR | — |
| 2024-12-16 | Woodbury County SO | — |
| 2025-02-11 | Wapello County SO | — |
| 2025-02-20 | 91A-2025-006 — Warren County SO | — |
| 2025-02-20 | Carlisle PD | — |
| 2025-05-11 | 29A-2025-001 — Burlington | US-34 |
| 2025 | 33A-2025-002 — Fayette County | IA-150 |
| 2025 | 36A-2025-004 — Fremont County | — |
I have previously brought several matters to the attention of Director Marler. In 2020, I petitioned him to amend rules governing the DOT’s flawed immigration database. He declined, which contributed to the widely-reported discovery of 2,207 non-citizen voters in 2024—a number that turned out to be just 277 because of the very flaw I had identified. ↩︎