Four photographs: the evidentiary record before a private-property tow
House Bill 22-1314, the Towing Bill of Rights, is implemented at 4 CCR 723-6-6508, and it converts a nonconsensual private-property tow from a dispatch decision into a documented one. The rule does not merely require the carrier to be right. It requires the carrier to have proved it was right, in a particular form, before the vehicle moved.
The authorization comes first. Rule 6508(b)(III)(A) requires the property owner authorization form to be filled out in full, signed by the property owner, and given to the towing carrier before the vehicle is removed from the property — and not greater than 24 hours prior to the tow. The Commission prescribes the form and requires its use for all nonconsensual private property tows, residential and commercial. A standing authorization, a blanket letter or a signature obtained a week earlier does not satisfy the rule, which effectively ends the practice of patrolling a lot on a general instruction.
On residential property a second clock runs in front of that one. Rule 6508(d)(III) requires written notice placed on the windshield of the vehicle at least 24 hours before towing it, stating that towing will occur if the improper parking continues, describing the violation, giving the time the vehicle will be towed if it is not moved, and warning that continued violations may result in towing without notice.
Then the photographs, which are the part operators most often underestimate. Rule 6508(e)(II) requires four images of the vehicle — from the front, from the rear, from the driver side and from the passenger side. Rule 6508(e)(II)(E) specifies the technical standard: each image must be rendered in a resolution of at least 2,000 pixels by 2,000 pixels, must contain the date and time the photograph was taken, and must have the vehicle fill at least three-fourths of the photograph, measured side to side. Rule 6508(e)(III) requires a fifth photograph documenting the reason for the tow, held to the same resolution and timestamp standard.
Five compliant photographs per tow, framed to a stated fraction of the image and stamped with date and time, is a real operational load on a high-volume private-property operation — and it is also the single best claims defense a Colorado operator has. A four-view timestamped record of a vehicle’s condition at pickup is precisely the evidence that resolves a pre-existing-damage allegation, which is the most common contested on-hook and garage keeper’s claim in the class. The rule was written as a consumer protection. It functions equally as a loss-control instrument, and an operator whose photographs are genuinely rule-compliant is defending damage claims from a position most operators in other states do not have.