Penna Turnpike Commission overbills ~$40M per year on turnpike violation notices, successfully avoids public disclosure

I have been sending Right To Know requests to the PA Turnpike to expose how much they are collecting by overbilling drivers that exit the turnpike with a ticket.

PA law states how much they can charge:

In the event of a lost toll ticket, the patron shall pay the fare from the farthest point of entry on the Turnpike to the actual point of exit. 67 Pa. Code § 601.12(d).

But instead they are ignoring your actual point of exit and charging based on greater of your point of exit or exit from the opposite direction. Assuming drivers are losing tickets traveling East as often as West, this means half of those tolls are overbilled.

BUT HOW MUCH?

I made a request to find out! I asked for only the date, exit location, and toll amount for all tickets. PA Turnpike Commission denied the request saying that knowing the exit location of anonymous cars amounts to "vehicle movement records" and is not eligible for public disclosure. The PA Office of Open Records agreed by citing a case where a requestor asked for vehicle ENTRANCE and EXIT locations, which I think is an actual movement record. Of course I believe that is distinguishable from my case and think it is not a proper comparison.

Read the appeal docket here: https://www.openrecords.pa.gov/Appeals/FinalDetRecord.cfm?docket=2019-1361

There is a golden nugget there though. Deep inside the docket you can publicly see how many such violation notices there are: approximately 2 million per year. This means about 1 million are overbilled (see math above).

HOW MUCH PER VIOLATION: -- Most vehicles are exiting near Philadelphia or Pittsburgh and the toll to exit either from the long way is about $45 or the short way is about $6 a difference about $40. We are assuming all class-1 vehicles. Trucks would cost more. Source: https://www.paturnpike.com/toll/tollmileage.aspx

Result: -- PTC is overbilling approximately $40M per year.