Your Voice Matters: Feedback for TDLR's Towing, Storage and Booting Program

In March 2014, TDLR asked licensees and the public to share their ideas and experiences related to TDLR. People participated through face-to-face meetings around the state, on an online crowdsourcing website, through social media, and by email.

Participants were asked to answer four questions:

We used people’s responses to help us create our strategic plan.

Below you will find participants’ responses concerning TDLR’s Towing, Storage and Booting program.

What does TDLR do well?

  • report people and check up on rules
  • Drivers getting license quicker
  • Inputting testing is so much easier – streamlined (a lot less mistakes)
  • Licensing – speed in which they are issued
  • More transparencies of where you funding comes from and where it goes
  • Strategic plan session – having employees and industry participate
  • TDLR always is so helpful
  • TDLR employees juggle a lot of hats, encourage the industry to treat TDLR the same way they want to be treated
  • TDLR listens to everything and then comes out with a reasonable answer
  • Used auto parts recyclers are very positive about regulation
  • They have been weeding out the dishonest people in the towing industry.
  • Amend the law as it relates to issue meaning it is the same as holding the license in your hand
  • Better communication
  • Better communication between TDLR and other agencies (TOW, VSF and UAPR) – DMV, TxDot, TDI, DPS
  • Complaint and violation stacking issue
  • Consistency
  • Input of CE is very simple and works great
  • Interagency consistency
  • More and better trained staff
  • Reexamine the statutes
  • Reexamining the statutes
  • Streamline the statute so that it addresses consumer protection and safety
  • Streamlining the enforcement process for quicker resolution – allowing legal assistants to do more routine violations – sign height and fence violations – if it doesn’t involve consumer safety
  • TDLR has been very helpful
  • The consistency in rule interpretations with written explanations
  • The TTOC Login has been a great success.
  • Things I would like to see changed on the TDLR website -- 1) add 2 additional links in the dropdown for "Forms, FAQs, Rules, and Statutes"; prior year rules with changes in Red and current year, current year updated as changes happen: 2) Main TOW page - separate sections with headers
  • Update website in a timely manner.

What can TDLR do better?

  • I would think that you should be able just to type in the name of the business and it should pull it up. I don't think there is a box for that, But I might be wrong.
  • A lot of the towing industry feels like TDLR is not respecting and understanding their businesses, instead they feel like staff sees them all as crooks – TDLR needs to get a better understanding of what their business is really like -- Show respect; Be compassionate; Listen without judgment; Bring some of the towing folks into our agency to talk about the industry
  • Add what's new section on Tow web page to click on link to show rule changes and what it does
  • Awareness and education that companies are required to have drug testing - to build a positive relationship - go in to help them not punish
  • Be consistent – information you provide, inspections, and enforcement -- Example of inspection with fence not high enough and inspector said they would be in compliance if fixed in 48 hours and two years later they were fined for it
  • Better job of answering questions and create a process where answers are recorded and share with other divisions – then shared with industry (FAQs, meetings, association reach out, etc.) – emphasis on the process and verification (submitted in writing and answered in writing)
  • Core values (esp. respect) for ALL employees
  • Customer service reps giving out incomplete or inconsistent information - wrong info, too many programs - create script with addresses, education providers, etc. - how about section out CS reps (specialize by program)
  • Each division have a tow subject matter expert because there are too many what ifs
  • Field Operations staff are not educated on Tow because they are covering too many industries
  • Frustrating when it seems questions have been answered and agreed upon and then still come up
  • Need consistency among inspectors re: requirements
  • Needs to be clarity on rules relating to random pools (company by company?; 25%?)
  • On front of Tow landing paragraph - too dense - section out - it is a run-on sentence
  • On the main Tow web page - separate out with headers
  • On the TDLR tow page add two additional links in the drop down bar under the "Forms, FAQ's, Rules & Statutes" one that has the Rules 85 & 86 for the prior year with changes in Red and the other for the current year with changes in Red. The current year changes would be added as they occur. This would be very helpful in keeping towers up to date on changes that might be missed in just reading the rules and picking out amendment dates.
  • Provide consistent and accurate information from the customer service division, compliance, field operations and enforcement -- Second notice
  • Provide responses in writing and publish them via FAQs or knowledge database
  • Put on hold for over 3 hours
  • Reach out to municipalities and let them know they are issued through a third-party vendor and it’s a mailing issue – please accept paper copy
  • Receiving licenses in a timely manner
  • Recent phone call: CS rep was nice but gave wrong information re: process (specifically about certification/continuing education confusion)
  • stacking complaints - example; keep classes of violations the same
  • Stacking of complaints – the towing and VSF complaint approach that TDLR takes should be different that other programs because the opportunity for violations is greater (the motivation for the complaint being filed), severity of the penalty amount
  • TDLR wants to charge consumer less yet the costs of doing business continues to go up
  • TDLR’s current policy of keeping a violation on the books for ten years should be amended -- Class A and Class B violations (more administrative paperwork violations) should stay on the books for one year; More severe violations that deal with safety, the financial aspect of a consumer, the road safety, those serious violations should stay on the books for three years; Safety violations of hooking up and dropping a vehicle should be on the books for five years; Overcharging violations should be on the books for ten years
  • The agency could better utilize the advisory board -- When you’re changing the FAQs it shows up out there and sometimes they are wrong or were not understandable to the industry – focus group, sounding board with advisory board
  • The enforcement plan and philosophy that treats subsequent violations more severe no matter what the class the violation is the example of the person having a class A violation subsequently having a class B violation treated as a second offense (even though different class) then having a class A violation that could be a revocation
  • The new rule that requires an office at each VSF location has created unsafe conditions and issues
  • Towing is so varied (re: companies, sizes, etc.) - it can't be treated cookie cutter - TDLR needs to take a broader perspective and see the unique aspects of towing
  • Towing is very much a mom and pop business and is not a franchise, we’re all struggling and the world thinks we do and TDLR thinks we do, we get a thousand dollar fine thrown at us and it’s a big deal then we find out they are not going to fine for that anymore
  • Update website in a timely manner - e.g. tow tickets still reflect rule from 2011; top ten violations-change to make them current and date when updated
  • Walk a mile in a man’s shoes
  • When the industry believes an issue has been settled TDLR needs to stop going back and reinterpreting the provision – consistency
  • Be fair treat towing company's the same don't have favorites
  • Investigate ****** (towing and storage bait and switch) U.S. 59 Enterprise Inc. I filed a claim and it took over a year and 5 different agents and nothing happened to them. They broke the law, lied and continue to take advantage of people. I trusted The TDLR to enforce the rules and punish such a dishonest businesses from taking advantage of people, but somehow they still get away with it on a daily basis.
  • investigate complaints with out asking for more information by such and such date or no investigation case closed. Protect the citizens from licensed predators, by giving high fines or jail time.
  • It would help the industry if law enforcement agencies were aware of TDLR regulations and could enforce, and ticket, violators. If operators are towing in an unsafe manner, a biannual inspection is unlikely to produce "real time" violations, it is primarily citations based on incidental, accidental, or unintentional paperwork errors, which have very little to do with public safety. Not to belittle the severity of overcharging or doing paperwork incorrectly, but it would seem the primary focus would be on protecting the public, the operators, and the owners. Therefore, relying on the reporting of violations for further investigation seems to be an inefficient manner of regulating the trucks on the road because enforcement is too abstract and random. Law enforcement becoming aware of these regulations would help put an end to companies operating under the radar and would help protect everyone on a daily basis (even those who do spend the extra money and effort to stay in compliance).
  • Only one? I've got three but if I have to stick with one: it would be nice to be able to reach someone on the phone who is actually familiar with the rules and regs for towing and storage. You get different answers every time you call in, if they even have a clue. I find it sad when I'm explaining the rules to them. You can't actually contact TOOLS, who seem to be the only people who are knowledgeable, and the chance of them calling you back is slim to none.
  • Pull over that wreckers an check them up n down ,, there is lots out there that have nothing at all ,, get some wrecker inspectors ,, get that bad ones not that good ones ,,,
  • TDLR claims they are here for us, prove it. change the renewal policy. We still pay for it regardless. And as for the CE course, the courses you can do online or in a class that has an instructor that's clueless is just time consuming for drivers that are only paid commission. No tow = No pay. As for the instructors that I have had the chance to sit in class and listen to, it would really help if they could teach something helpful to new drivers. I've been towing for 30+ years, and when I or someone else with more experience than the person instructing the class has to point out flaws with the way we are supposed to load and unload a car/truck makes them mad, and us wanting to leave because they teach nothing to us. Look over the material that is given for them to teach. To me its a real waste of time and money. Money that can pay bills, not the outrageous prices S.W.T.O. here in Dallas/Forth Worth charge, Rethink your charges, I understand things get expensive at times, but y
  • TDLR needs to be more transparent was an agreed order is issued, such as allowing the public to click on the case number that opens in a pdf file format. It's imperative that investigator not invoke personal opinions in regards to the Texas Towing & Booting Act and cite licensees, instead educating them.
  • TDLR needs to meet OSHA standards on Towing Operator Safety Clothing. " 86.1001. Technical Requirements--Towing Operator Safety Clothing and Identification. " To meet the requirements they need to be wearing ANSI 107, Class 3, it meets OSHA standards. 1. Vehicle/equipment speeds exceed 50 mph. 2. Worker and vehicle operator have high task loads. 3. Wearer must be conspicuous through the full range of body motions at a minimum of a ¼ mile (390 m) and must be identifiable as a person.
  • We pay for all the Necessary permits and license only to Receive huge fines for an Incomplete tow invoice or a tow sign not at proper height.. Etc.
  • "What actions are being taken to catch and Prosecute tow trucks and drivers who operate without any permits, signs, running regular TX truck plates..
    Are you Actively out looking for these type towers, if so how many are or have been caught in the field?.
    I'm asking cause it seems like TDLR only Focus on Enforcing licensed trucks/company's!, are you just allowing local police to find and ticket these Violators with no signage, permits.. Etc."
  • Why not renew every 3 years for IM every 2 for CT and every 4 with a Duel IM/VSF with a 4 hr. CE course.
  • You should at least advise us of what we're doing wrong. When you call TDLR and ask a question you get different answers for the same questions. It's ok for y'all to make mistakes but when we make a simple error we get HUNG!

What changes would you make to TDLR if you were king or queen for a day?

  • I am scared to death every time TDLR comes into my office and I don't feel like that is fair. I have not personally ever been penalized for anything but I am currently fighting some wrongful inspections and I am worried as to what the outcome is going to be. We hear these horror stories all the time of good companies that have to pay massive fines and then we continue to see the crap companies not be caught or penalized for the actions they are taking. I try hard every day to make sure my company is on top of their game as well as my employees. There are so many minute details that it truly makes it hard to not just hire someone to come in weekly and inspect us to make sure we are doing what we are supposed to be doing, especially if you hope to grow at all.
  • when renewing the used automotive employee I you could put multiple employees instead one at a time
  • 2nd notice
  • Add more towing staff -- A regulatory agency should not respond to questions with you are going to have to use your own judgment; Double the staff of what you have now
  • Alternative work weeks for the customer service division, ten hour days to have a day off
  • Amend statute to provide for administrative sanctions and penalties for a 2nd time failing drug test
  • Amend the law as it relates to “issue” being equivalent to holding the license in one’s hand
  • Better communication between TDLR and the other agencies that are involved – DMV, TxDot, TDI, DPS -- Conversation; Because TDLR is the regulatory agency they should take the initiative to communicate and make changes, take the lead; DPS trains every six months, call and ask if TDLR staff member can present
  • Check error reports for towing – looking for consistencies and inconsistencies
  • Common problem: transposing SSN on original app which prevents license being printed and it keeps others from following up to correct
  • Continuing education for VSF – dealing with customers -- Be sensitive to the cost factor; Provide online training with no travel involved; TDLR offer training twice a year in regional areas, three hour trainings
  • DMV & processes for getting titles out has a negative impact on VSF cash flow
  • Drivers should be held responsible for NOT drug testing
  • Each division be trained together so that everyone is on the same page
  • Every compliance and enforcement person to work the window of a VSF
  • Get OAG, TDI, TDLR, to meet and discuss this issue (schedule June meeting, include industry)
  • Give everybody at TDLR a raise
  • Have more specialized program staff -- Customer service have a tow team, bar/cos team, etc., minimum of ten
  • Have the compliance division provide handling emotional conflict training at VSF
  • If we teach the head then the rest of the body will follow
  • Law enforcement holds
  • Licensing system should capture failed drug tests (flagged) – risked-based
  • Lowest profit margin vehicle gets the highest incidents of violations for impounds
  • Make trainee license more prominent and more useable
  • Make VSF form 011 email able
  • Move the delay of 8-hr training course (should be 18 hours) as a prerequisite
  • Property owners to be jointly responsible for what happens on their property
  • Provide a range for the sign requirements (outdoor; font, size, etc.; plus or minus 25%)
  • Provide better info on webpage (table) relating to late renewal provisions (fees, cont. educ. Requirements, etc.) (1 to 90) (91 to longer)
  • Reach out to the industries you regulate and tell them we are going to ask for more and we need your help
  • Security system technology which performs same function as locking vehicle (conflicting requirement with TDLR and auction) – look at risk-based inspections, history of theft, treat accordingly, premise coverage (24hr a day)
  • Statute hindering release of vehicle to the person who was actually in the vehicle
  • Step back and look at what the statutes need to do -- They need to protect the public – physical and financial safety -- What is and what isn’t necessary using a task force of industry and TDLR
  • Streamline the enforcement process with quicker resolution -- Give some authority to the legal assistants, if you’re not dealing with a consumer that has filed a complaint, if it’s a sign or fence it’s a done deal, send out the letter
  • TDLR needs to do a better job of placing consequences on drivers who have failed drug tests (better jobs of consequences for counties not having consequences, better job for the public, puts strength behind TDLR – now it is adversarial)
  • TDLR needs to work with municipalities to help them understand that they can accept the paperwork
  • TDLR should not duplicate Fed laws (evaluate current rules and statutory provisions)
  • TDLR should recognize that industry is asked and told to do things by other agencies and should not be penalized for complying with the other agencies, cities (ordinance or contract), and municipalities
  • TDLR, law enforcement (DPS) & DMV all in alignment
  • The real conflict comes in that Law Enf says the vehicle needs to be unlocked – TDLR needs it locked
  • Train with specialized teams in other divisions
  • Trainee license needs to look like apprenticeship (license person assisting)
  • VSF continues to be abused (the moment this takes place the consumer loses all protections – some insurance companies are giving their authority to other people)
  • after 2 years I do not think we need to keep paying $100.to our renew license I think it can be drop down to$ 25.00 . and renewing our wreckers can get drop down about $150. after 3 years.
  • "Also if TDLR is Attaching fines or liens to Vin# of a tow truck and there's no way to check it before Purchasing a used truck.
    I would like to see something along the lines of impounding the tow trucks running without any permits, much the same as police impounding vehicles caught operating without Insurance!..
    These unlicensed tow trucks would be heals until they have Purchased the proper permits!!..
    Again how many agents dose TDLR have in the field looking for those Unlicensed tow trucks????"
  • And for the ins. give the owners time to get things out of the cars that go a storage lot. and not us the VSF to get the car out . if some one been in a wrecker as the right to go where the car is towed to not to go looking for it because they wont to over ridge ever thing with the VSF. i have had more people get so mad because it was move and was not told about it. i have to tell them that TDLR has gave them the right to the ins to move. i give them TDLR number and then i tell them to call the ins. i think they can have up to ten d
  • Define the rules for towing companies better. Why should a person doing a repo have to wear a reflective vest or shirt.
  • Fairness to the towing industry. Minor infractions costing small business owners thousands of dollars is unfair and unjust.
  • If you are going to attach and enforce administrative penalties to equipment owned by the towing Company, why don't you have an avenue for a new purchaser to limit his liabilities by checking A VIN number through your department prior to purchasing a truck?
  • Leaving regulation open for interpretation of the person reading the reg. Regulations need to clear and decisive. Tow Trucks, Operators and Vehicle Storage Facilities Law 85.710. Release of Vehicles. (3), (G) appropriate identification of any state or federal law enforcement agency representative; " identification of any state or federal law enforcement agency representative" Is that only U.S.A. IDs? There are people living Texas who do not have any U.S.A state IDs or U.S.A. federal IDs. They have IDs from other countries, like people living in Texas from Mexico & their IDs are more than likely fake. http://www.pressherald.com/news/Man_sentenced_to_10_months_for_selling_fake_federal_IDs_in_Maine_.html
  • My father-in-law is over 80 years old and has been in towing and recovery all his life. I am a mother of 9 children in the family towing business. Neither of us have ever been on the wrong side of the law in any way. Seems ridiculous to pay for and be subjected to drug testing every year just for releasing a vehicle. There should be exemptions. The people who are arrested and towed are not drug tested. The police who arrest them are not drug tested. Why single us out?
  • Please re-evaluate the booting regulations! I will change my review to more stars once y'all have cracked down on the booting regulations that allow parking/booting companies (like ***** and *****) to extort people (and many are just innocent passengers). How is it even remotely ethical for private (non-law enforcement) companies to have the authority keep someone's personal property without a court order against them? No other entity can legally do that without going through the proper judgment and collection channels and even then they can't leave you physically immobilize you and leave you stranded in their restaurant or business until you pay! So why was it even allowed for driver's and their innocent passengers (including women, children, the sick, elderly) to be unexpectedly booted, stranded in unsafe locations (at night in many cases), extorted for over $100, and left with no other option for payment (like a "bill me" choice) even if they sincerely do not have the money. Instead their cars are being he
    ld ransom until they somehow come up with this unexpected large payment right then. ALL OF THIS FOR A 1st-TIME $4 VIOLATION! And in my case, the I didn't even know I had committed an offense due to unclear wording and incorrect grammar on the ticket so I was extremely surprised. What if the driver or innocent passengers has an emergency (like a hurt loved one) and needed to leave right away? Or they just had surgery (since this was right outside of the hospital) and needed to immediately get home? I can see a huge lawsuit just waiting to happen! At the very least, the booting companies should implement a "bill me" option and a warning system - like a note saying "This is your 1st violation for 'insert detailed description of offense here'. We have recorded your license plate. On the 2nd offense, you will be booted and will have to pay $100 plus appropriate parking charges for each offense before your vehicle will be released." It is despicable that they are abusing their power, physically forcing people to pa
    y (by booting their car), and taking advantage of women, children, the sick, and elderly who are confused and afraid and don't want to be stranded in a "rape" lot. No other private company can physically immobilize you and strong hand you into paying - especially if the fee is in dispute and there has been no fair trial to determine the legitimacy of their claim.
  • Potential situation: Owner of a vehicle is in the hospital for the 4-5 days following an accident. Insurance receives word the vehicle is in storage and contacts a salvage company to pick up the vehicle. The company can remove the vehicle with a TDLR VSF form, although the owner has not had an opportunity to remove their belongings, has not been made aware of the destination of their vehicle, and may be long gone before they locate who is in possession of the vehicle. The owner of the vehicle pays the insurance company to protect their belongings and their vehicle, although the insurance companies can take possession of their vehicle and make arrangements for its disposal without the owner's approval so they can avoid storage charges. That is not in the best interest of the owner.
  • TDLR should implement and enforce the statutory language in the Texas Towing & Booting Law, instead of taking advice from organizations and the towing industry.
  • The state allows cities & counties to set maximum fees for Incident Management towing (accidents) & Private Property towing (parking lots). Texas & TDLR needs to set a minimum fee for IM Towing & PP Towing, need to set a state wide fee standard. The city I tow in set the IM towing fee at $100 & the PP towing at $75 over 10 years ago & did want to make any adjustments for higher fuels cost & other skyrocketing prices. A maximum fee needs to be set for IM towing & also a minimum fee. Texas has set a maximum fee for PP towing but no minimum fee. I don't think Electrician, Cosmetologists, Air Conditioning, Combative Sports, Water Well Drillers, BAR etc. etc., would like the City & County they are in setting their max pricing.
  • The state allows cities & counties to set maximum fees for towing accidents. The city I tow in set the towing fee at $100 over 10 years ago & didn't want to make adjustments in the 10 years for higher fuels cost & other skyrocketing prices. I don't think Electrician, Cosmetologists, Air Conditioning, Combative Sports, Water Well Drillers, BAR etc. etc., would like the City & County they are in setting their max pricing. A maximum fee needs to be set for IM towing & also a minimum fee. Texas & TDLR needs to set a minimum fee also for IM Towing & PP Towing. Texas needs to set a state wide fee standard if its going to allow cities & counties to set fees. ( IM = Incident Management, PP = Private Property )
  • The VSF011 Form has widely been abused by Insurance companies, and currently reeking havoc on citizens trying to relocate their vehicles. Lots of hearings were held on this matter, lots of testimony from both sides of the issue were brought forward, and lots of examples of abuse were submitted to your board. Some minor adjustments were implemented, nevertheless the problem remains. TDLR lacks the authority to hold Insurance companies to account, therefor they should not have facilitated such form to be used by Insurance companies to begin-with, that continues to be the problem with this form. My suggestion would be to simply go back to the TDLR form (Affidavit of right of possession) and for Insurance companies they can use Notice of Right of Possession for Salvage--A form prescribed by the department and executed by persons licensed under 16 Texas Administrative Code Chapter 86 as agents for an insurance company that has documented authority from the vehicle owner.
  • There should be a "fix it" time period for violations that do not affect the motoring public.
  • These are the most rudest people in the State of Texas have some heart people we our small business that have been in business before some of these people been employed.
  • Why not renew every 3 years for IM every 2 for CT and every 4 with a Duel IM/VSF with a 4 hr. CE course
  • I think it should be every 2 - 5 years that we have to renew them.

Over the next five years, what major changes will affect the way you do business and the services we provide?

  • I think we have made great progress over the last five years. I would like to see us make some rules a little less stringent and I would also like to see the companies that are out there making it hard for everyone else be held accountable more for their actions.
  • in my industry you never know but I think more agencies will be looking into our industry.
  • A lot of people will be out of business – 25% in five years
  • Cars drive themselves
  • CDL federal regulation
  • Federal rules coming down on CDL which will be detrimental (reducing population of CDL drivers)
  • Fewer young drivers
  • Increase in technology in vehicles and education drivers (Tesla training example)
  • Insurance industry continues to get more and more involved with anything that deals with vehicles
  • Just as many towing fatalities (up 25% this year!)
  • Starting to see national companies coming in trying to take over aspects of the towing industry -- Notice letters; Dispatch; Title search
  • The smaller municipalities trying to get on board with developing towing ordinances but they are using elements of ordinances that don’t even apply – example of the switchboard
  • Minimum fees for IM non-consent towing & a minimum of $3 hour for being on call for a tow operator. Some tow operators are kept on call 24 hrs./7 days a week & average less than $2 an hour of pay a week.

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