I am absolutely opposed to the eliminate of blanket permits for temporary logging entrance.  I feel the current system serves logger, landowner, the forest products industry and the citizens of Virginia well.  Creating more state bureaucracy, which is time consuming and potential expenses in term of manpower hours by the applicant and the state personnel processing the application is not benefincial to anyone.  Forest landowners, generally do not harvest on a given acre but once or twice in a 30- 35 year period.  During this 30 - 35 year period, they paying real estate taxes yearly, providing clean air and water to all Virginian, and using none to vey little county or state resources.  They should not have to pay a fee to use the public highways to sell the one crop they been producing for 30 to 35 years. 

Permanently established highway entrance points should not require a fee every time a log truck use them.  One large blocks of land, these access points my be used yearly.  It's not right for the state to charge a fee it these for each time the entrance is used.

I can see the value in VDOT involvement in establishing new entrance point from a safety standpoint.  But I also believe landowners should have access to public highway's for harvesting their timber.   

Not only are landowners paying real estate taxes yearly,  but they also paying income taxes on the sell of  their timber resources.  The logger's are paying annual taxes on his equipment, and numerous taxes on his log trucks.  I do not believe landowner's, logger's and the forest products need another tax, even if it is a user fee.  

Eliminating the blanket permit program in favor of single temporary logging entrance permits would be expensive, time consuming, and impracticle for the forest products industry and VDOT.

Our company supervises logging operations in the piedmont of Virginia and North Carolina (North Carolina does not have anything similair), utilizing approximately 100 - 150 entrances per year in VA. This would equate to roughly $10,000 - $15,000 per year in entrance permits, a steep increase to the amount we are paying now.  With high fuel prices and reduced demand and pricing for building products, this is not another expense that we need.  This is purely a tax increase.  On road fuel taxes are already being paid by logging companies and contract haulers. 

All logging entrances are temporary, lasting a few days to a few weeks.  Contruction jobs may last months or years with thousands of vehicles using an entrance.   Are they being treated the same, or is the forest products industry being singled out?  The forest products industry in Virginia is a significant part of the economy of the Commonwealth. The Virginia Forest Products Association website contains the following statement : "It (the Virginia forest products industry) produces over $11.5 billion worth of goods and services on an annual basis, making it one of the largest contributors to the GROSS STATE PRODUCT. In fact, over 6% of Virginia's total GSP is directly attributable to this industry."  All forest products begin at the stump and eventually some of the cost will be pasted along to the individual landowner.

VDOT and the forest products industry does not have the manpower to follow through with the propsed changes.  I am sure this change would require a good bit of paperwork for both parties.  Does VDOT have the manpower to handle this or will they have to increase the number state employees?  Are logging entrances worth the cost of this additonal expense.  I say NO.

We follow the rules of the blanket permit program, however I understand the western part of the state has struggled to comply.  Sounds like VDOT could enforce the laws that are already on the books in that part of the state much easier than complicating the process for everyone statewide.

This is not a good idea.

I feel that the additional bureaucracy which would be created by eliminating blanket entrance permits in favor of single temporary permits is not only unnecessary, but also expensive, time consuming, and unfair to the forest products industry.

The current system is convenient for both forest industry, landowners, and VDOT. Our company has cooperated with VDOT for years under this system, and I feel that it serves everyone well. Moving toward a single permit would burden the forest landowner with basically an additional tax for using Virginia's highways to sell their products, and add yet another tax to the logging contractor who is already dealing with high fuel prices and equipment taxes. Forest industry does not have the luxury of staying on the job for months at a time, and must utilize many entrances throughout the state on a short term basis over the course of a year. I cannot think of another industry which would be as negatively affected financially by this proposed change. In addition to the unfair cost increases for the industry as a whole, I do not believe VDOT would not have the ability to process these many permit requests in a timely and efficient manner.

I understand the VDOT wants to insure public safety and protect the condition of Virginia's roads, but I feel that stricter enforcement of the current system is the best way to accomplish this goal without creating more unnecessary taxes and bureaucratic red tape.

We are a family owned logging business that has operated in Virginia for over 50 years.  The new policy that has been proposed is not logical and would be a burden to loggers and VDOT.  Under this policy, our operation may be stalled or stopped all together if VDOT is not able to keep up with the demand of calls for inspection on entrances.  Most of the sites we log have an existing entrance that has been used as driveways, hunting roads and various other reasons.  Is it fair to make us pay a fee to use an existing road just because we are logging?  Anyone else could use the same road for any other reason without paying this fee.  It seems ludicrous that each time we move to a different location, we must contact VDOT in order to continue working for a living.  I understand that if we have to build a road in order to log a piece of land that VDOT must be called, but I am talking about existing roads. 

What would happen if we need to move to a different location due to weather conditions and VDOT can not inspect the entrance, do we just not work?  Are there going to be increased staff at VDOT to handle this demand?  As a logger, we are required to pay an astronomical amount of taxes already.  Just for trucking, we pay $1400/year for tags, we pay fuel taxes, unemployment tax, federal tax, state tax and many more.  It seems that this is just another way for the government to tax us again.  So, we will be required to pay additional tax and possibly be unable to work because we are at the mercy of another state agency to do their job?  We are asking that you do not pass this new policy and consider the amount of extra work and the affect this will have on small businesses in this state.   Please do not punish us for working hard and continuing supporting our economy by running a business in Virginia.  I would be happy to discuss this with anyone involved in this process.  We are Goodman Lumber Co., Inc. owned by Tommy Goodman.  Thank you for the opportunity to make my comments. 

Virginia American Water welcomes the opportunity to comment on the Virginia Department of Transportation proposed Land Use Permit Manual (24 VAC 30 – 151). 

Virginia American Water, a subsidiary of American Water, provides quality, reliable water and related services to more than 320,000 people in 22 communities across the commonwealth.  The company is an integrated part of the communities it serves and is committed to meeting community needs. However, several sections of the proposed Land Use Permit Manual will have an adverse impact on our customers. 

Following are the concerns of Virginia American Water, which we have outlined by section:

24 VAC 30-151-10:  This section distinguishes between private (for profit) and public (non-profit) utilities.  There is no basis for distinguishing between classes of utilities since each are installing/utilizing the same type of equipment i.e. piping, etc. and using the easement for the same purpose. 

24 VAC 30-151-30:  This section would require a single-use permit every time required maintenance would disrupt a public road in the event of an emergency.  The time required to apply for, and obtain a single-use permit could adversely affect public health and safety if we are not able to response immediately to a leak or another event.  In addition, the costs associated with the permit fees would ultimately be recovered from customers through our rates. Virginia American Water strives to provide high quality dependable water and related services to its customers at an affordable price. 

24 VAC 30-151-340:  We believe this section is discriminatory because there is no basis to differentiate between public or private utilities.  In addition, there is no finite, defined compensation.  Finally, a shared resource arrangement is not adequately defined in the regulation (see 24 VAC 30-151-30.D.2.).

24 VAC 30-151-720:  Surety is required when working within a right of way in the form of a check, cash, letter of credit, insurance bond, etc.  This will increase the cost of projects and ultimately increase the cost of services we provide to our customers.   

24 VAC 30-151-730:  Virginia American Water opposes the annual accommodation fee for limited access highway set forth in this section.  Costs that are born by the utility are passed onto our customers through higher rates, and we strive to provide high quality dependable water to our customers at an affordable price.