| TO: TRAO and APTO MEMBERS
FROM: The Ohio Towing and Recovery Legislative Committee (OTRLC)
RE: NOTICE: INFORMATION NEEDED FOR PPI RATE REVIEW
DATE: January 6, 2023
In 2018, The Public Utilities Commission of Ohio (“PUCO”) adopted rules that established maximum rates for towing and storing motor vehicles from a Private Tow-Away Zone, i.e., Private Property Impounds (“PPI”). Recall, the Ohio towing and recovery industry fought and won a difficult battle to increase PPI rates and supported removing the authority to set these rates from the legislature and transferring the rulemaking authority to the PUCO. These rates had not been increased since 1994, and the result of our work saw a 44% increase in both rates.
A significant reason we pushed hard for this change in law and for the new process is because the PUCO is required to review the rates, at a minimum, every five years, and it provides the towing and recovery industry the opportunity to participate in the rate making process and advocate for fair and just rate increases. Specifically, as part of the process, the PUCO is required to consider any adverse impact the rates have on towing and recovery businesses. The PUCO will officially review the current rates in early 2023, but we must start preparations immediately so the industry is prepared to participate in the review process.
The Ohio Towing and Recovery Legislative Committee (“OTRLC”), the joint committee established by APTO and TRAO, is taking the lead to represent the industry and advocate for an increase in both the PPI towing and storage rates. While it is obvious the COVID 19 pandemic, dramatic inflation, and supply chain and workforce issues have had an enormous and adverse impact on your businesses, we must be able to present hard data—through specific examples—to the PUCO in order to justify rate increases. WE NEED YOUR HELP to make the case.
The importance of achieving a PPI rate increase during this review period cannot be overstated. The PPI rates are often used as a measuring stick for all other towing and storage rates established throughout the State of Ohio. If PPI rates remain stagnant, other rates will as well.
Attached to this letter is an Information Request Form. We ask that your company participate in the process by filling out the form with information we believe will be essential to assist our advocacy effort. Your company name and/or any other identifying information will not be included in any OTRLC work product. Your information will be sent directly to our lawyers and lobbying team at Shumaker Advisors and will be kept strictly confidential. Further, all information used in the process will be aggregated and displayed in the same manner. In other words, no information will be associated with any individual company.
The following information will be critical to our advocacy efforts:
1.) The total number of PPI tows your company performed in 2022 (divided by weight class);
2.) The number of PPI tows performed in 2022 that were ordered by law enforcement;
3.) The number of PPI tows performed in 2022 that were ordered by private property owners;
4.) The total number of PPI vehicles released in 2022, and total number of those vehicles that went unclaimed in 2022.
5.) Your percentage increase in the following costs incurred during the 2018 calendar year versus the 2022 calendar year:
a. Average salary or hourly wage;
b. Yearly insurance premiums;
c. Costs to purchase and maintain equipment (including but not limited to wreckers, trucks, trailers, tires, etc.); and
d. Average fuel costs.
6.) If your company purchased or serviced certain equipment in 2018, then purchased or serviced identical or comparable equipment in 2022, please provide invoices or other documents demonstrating the price difference.
Please review the enclosed Information Request Form and complete the survey by January 31, 2023. TO COMPLETE THE SURVEY – EITHER CLICK THE SURVEY LINK BELOW OR DOWNLOAD THE FORM AND RETURN IT BY E-MAIL TO BRIAN COULTER AND JOE HOLLABAUGH, our attorney and lobbyist who will independently compile and aggregate the information:
Brian Coulter, Esq.
Brouse McDowell LPA
bcoulter@brouse.com
(330) 286-7551
Joe Hollabaugh
Shumaker Advisors
jhollabaugh@shumakeradvisors.com
(330) 519-9224
Thank you for your willingness to help the industry and assist our efforts. Your participation in this survey will be a tremendous benefit to the industry and the OTRLC as we advocate for much needed increases to the PPI rates.
Sincerely,
The Ohio Towing and Recovery
Legislative Committee (OTRLC) |
