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noted the dearth of caselaw discussing the limits of the safety exception, but took guidance from City of Columbus's focus on whether the legislature's purpose and intent was truly to promote public safety.  (Tillison, at p. 1129, citing City of Columbus, supra, 536 U.S. at p. 442.)  Tillison found an authoritative expression of the Legislature's intent in an August 2003 amendment to section 22658, in which the Legislature provided that in adopting subdivision (l) of section 22658, its intent was to "further the safety of the general public by ensuring that a private property owner or lessee has provided his or her authorization for the removal of a vehicle from his or her property, thereby promoting the safety of those persons involved in ordering the removal of the vehicle as well as those persons removing, towing, and storing the vehicle."  (§ 22658, subd. (m)(2).)  While not dispositive, the Legislature's express delineation of its safety purpose was relevant to the Tillison court's inquiry.  (Tillison, supra, 406 F.3d at p. 1130.)  The court also found helpful to its analysis Servantes, supra, 86 Cal.App.4th 1081, Berry v. Hannigan, supra, 7 Cal.App.4th 587, and other circuit court authority addressing the safety exception.  (Tillison, at p. 1130, citing Galactic Towing, Inc. v. City of Miami Beach (11th Cir. 2003) 341 F.3d 1249, 1253; Cole v. City of Dallas (5th Cir. 2002) 314 F.3d 730; Ace Auto Body & Towing, Ltd. v. City of New York, supra, 171 F.3d 765; Tow Operators Working To Protect Their Right To Operate on the Streets of Kansas City v. City of Kansas City (8th Cir. 2003) 338 F.3d 873, 876.)  The Ninth Circuit adopted the reasoning of the Florida district court in Galactic Towing involving a Miami Beach ordinance similar to subdivision (l) of section 22658; that court held the ordinance was safety related

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