HomeMy WebLinkAbout2017/02/07 Item 11 - Additional Information' Sheree Kansas
Subject: FW: 2-7-2017 Item 11 on Agenda, CVPD Tow Contracts
Attachments: Chula Vista Police Tow Contract 2-7-2017.docx
From: Jessica Hayes
Date: February 7, 2017 at 3:20:00 PM PST
To: Mayor Casillas Salas <msalasachulavistaca gov>, Patricia Aguilar <PAguilaraa,chulavistaca.gov>, Steve
Padilla <sspadilla a chulavistaca.Qov>, John McCann <jmccannachulavistaca.gov>, Mike Diaz
<mdiaz(a.chulavistaca.gov>
Subject: 2-7-2017 Item 11 on Agenda, CVPD Tow Contracts
Dear Mayor and Council Members;
In regards to Item 11, 16-074 on the Agenda for today's Council meeting, respectfully I urge the
Chula Vista City Council to approve towing contracts only to those companies who, as approved
respondents, 1) possess green fleets, 2) possess all requisite equipment as defined by the
California Vehicle Code, 3) whose yards are within City Limits, 4) who do not have to enter into
a Byzantine sub -contract in order to fulfill their duties to the City and CVPD, 5) whose
personnel, drivers, training and employee records and equipment can all be vetted and inspected
at the same location, and 6) who can be fully insured for all equipment and personnel as the
primary contractor for all equipment and personnel because they possess all the equipment as
required by law and employ all requisite trained personnel.
Below and attached are points supporting this request.
Thank you for your time and consideration.
Sincerely,
Jessica Hayes
resident
Chula Vista Police Tow Contract
February 7, 2017
1. GREEN FLEETS ARE A CHULA VISTA MANDATE. At least four of the companies
approved by the Chula Vista Police Department for this contract have entirely green fleets. There
is no compelling overarching interest for the City that relieves the City of its duty to follow- its
own green mandate, especially when the mandate can easily be met among the approved
respondents for the contract. Chula Vista must follow its own mandate in this contract.
2. FEDERAL AND STATE LAW GOVERNS TOWING EQUIPMENT IN
CALIFORNIA. The Federal Motor Vehicle Safety Act (MCSA) under which no state, nor any
of its smaller municipalities, may tell a towing company what equipment to use and the
California Vehicle Code which describes weight, height and length requirements for tow trucks
are the final authority for what must be used in the state. Class D tow trucks are mandated by
State Law for carrying over -height, over -weight and over -length vehicles. A tow contractor
without all of the proper vehicles is by definition not sufficiently, equipped to fully execute a tow
contract for Police business. Only a company that possesses every class of tow vehicle is
qualified. There are four companies approved by the CVPD that possess these vehicles.
Therefore, no overarching or compelling reason exists for the City to use any company other
than those which are fully equipped. To do otherwise when it can be easily avoided
unnecessarily places citizens at risk of a tow company without the proper equipment using an
unauthorized truck.
3. PARKER IMMUNITY. Because the State of California and the Federal Government has
clearly articulated State and Federal law governing equipment in this contract, and because the
City has an absolute duty to follow both Federal and State law, and to protect City assets and
citizens, the City may legally restrict contractors. Therefore, should any lawsuit arise, the
outcome may be the City secures a swift summary judgement because the City's exemption
would be complete.
4. CHULA VISTA TAXPAYERS The City of Chula Vista residents pay for its officers to
perform their duties including generating these tows. Since the City is paying for these tows, it
follows the City should, if possible, collect the taxes for these tows. But any vehicles impounded
in the City of San Diego will have any taxes collected go to the City of San Diego and not to the
City of Chula Vista. Additionally, City Police Officers would be required to leave the City for
any issues arising at an impound yard. Police Officers should not have to leave the City in
performance of their duties when they can easily remain here. Having on -duty officers remain in
the City is a matter of safety which is a compelling reason. This contract should remain with
companies located inside the City of Chula Vista.
5. Subcontracting for proper equipment is a convoluted attempt to circumvent state and
federal law and fails to protect the citizens of Chula Vista. There is no method to examine a
sub -contract for this service. There is no true mechanism for the Police Department to
investigate, inspect or review a sub -contractor or its drivers, nor to insure the drivers have been
properly trained and are up-to-date as requited by law with all of their training. Sub -contractors
are not likely to be present at the primary site when the Police conduct inspections on personnl
and equipment. Sub -contractors will not be placed under the same scrutiny as regular contractors
and yet they will be asked to perform the most complex and dangerous of all tows. This makes
sub -contracting for the City's tow contract inherently and unnecessarily unsafe. There is no
compelling reason for the City to contort itself into bizarre extenuated contracting which can
neither be reviewed by the general public nor allow for full background checks of the drivers or
inspection of the equipment by the police department. There are four companies which qualify
for this contract without the need to sub -contract. There is no reason to place the City at risk. No
sub -contracting should be allowed in this contract.
6. INSURANCE COMPANIES. For any lawsuit, lawyers will not overlook the City's own
communications stating the City knew the City must have Class D tow trucks to fulfill the City's
tow requirements. If the City wanted to be insured for Class D trucks, the City will properly
include Class D trucks as a requirement for every contractor, not just some. A towing company
must have enough insurance to cover every eventuality, but with sub -contracting, the primary
company to the contract does not need to have insurance for the vehicles it does not possess and
therefore may not be covered if an incident occurs with a sub -contractor. Here, there are four
approved respondents who possess these trucks and so will have the necessary insurance as part
of their primary policy for these trucks. This protects the City. There is no reason to not protect
the City. Sub -contracting should not be allowed because there will always be a loophole with a
sub -contractor. Only truly qualified contractors should become signatory to this contract.