Ombudsman comments on Portland Bureau of Transportation (PBOT) administrative rule changes

TO:                John Roble, Public Works Service Area Coordinator

FROM:          Tony Green, Deputy Ombudsman

DATE:            December 11, 2025

SUBJECT:      Ombudsman comments on Portland Bureau of Transportation (PBOT) administrative rule changes

The Ombudsman's Office submits these comments for consideration for the proposed updates to TRNs 17.01–17.05 (Private Property Impound Tows). We are proposing a change to introduce proactive enforcement of the statutory requirement that tow companies obtain written authorization prior to removing a vehicle from private property (TRN-17.02). We are also proposing changes to ensure fairness regarding community member complaints (TRN-17.04).

1. PBOT proposes to change TRN-17.02 (1) to clarify that it is illegal to tow a vehicle without "express written authorization identifying the specific vehicle. The facility representative must sign an authorization at the time of the tow request or provide a digital stamp as required by Oregon Revised Statutes (ORS) Sections 98.812 and 98.854."  

   Our investigative work indicates serious concerns about tow companies' compliance with this statutory requirement. Our initial review of City tow data found potential concerns with 40% of the nearly 31,000 private property tows in Portland from 2021 to 2024. In one egregious example, a tow company removed 367 vehicles in the first nine months of 2024 from the parking lot of a franchise coffee shop in Northeast Portland. The manager told us they had not authorized a single tow.

   PBOT's current practice of only responding to individual complaints is unlikely to curb unauthorized towing as an apparently widespread illegal behavior. To ensure compliance with the statutory requirement to obtain written authorization, the Ombudsman proposes the following addition:

• PBOT will require private property impound (PPI) towers to provide proof of written authorization for a representative sampling of tows identified by PBOT each month.

2. PBOT proposes changing TRN-17.04 (15) to reduce the period for community members to file complaints from 180 to 30 days. Community members may not be aware of their right to file a complaint, and under certain circumstances the 30-day deadline may not be fair or equitable (example: the vehicle owner was in the hospital or incarcerated). To address these concerns, we propose the following additions to the rule:

• Tow companies must place a sign in a prominent place in the office and/or include wording on a printed receipt notifying community members of their right to file a complaint.

• PBOT will consider complaints submitted after 30 days if a community member can demonstrate good cause for why they were unable to meet the deadline.