In regards to the proposed changes to 3 VAC 5-70-10 B. As a primary carrier of wine shipments to consumers in Virginia, United Parcel Service appreciates the agency changing the requirment regarding the issuance of a transportation permit.

We would like to see language amended or clarified regarding the use of a Bill of Lading. United Parcel Service does not use a Bill of Lading as all delivery information is contained electronically within our driver's handheld delivery device or what we call a Delivery Information Acquisition Device (DIAD). Each package will be individually labeled on the exterior of the package and will display the names and addresses of the consignor and consignee.

Within paragraph B & C of the proposed test, could the language be modified to the following: See bolded underlined text for new language and language we would like to see deleted.

B. Commercial carriers desiring to engage regularly in the transportation of alcoholic beverages within, into, or through this Commonwealth shall, except as hereinafter noted, file application in writing for a transportation permit obtain a transportation permit from the board or otherwise possess acceptable documentation as required by the following provisions.

A transportation permit may be obtained by filing an application in writing upon forms furnished by the board. If satisfied that the proposed transportation is otherwise lawful, the board shall issue a transportation permit. Such permit shall not be transferable and shall authorize the carrier to engage in the regular transportation of alcoholic beverages upon condition that there shall accompany each such transporting vehicle: 1. A a label on the exterior of the package showing the names and addresses of the consignor and consignee, who shall be lawfully entitled to make and to receive the shipment; and 2. Except for express companies and carriers by rail or air, a certified photocopy of the carrier's transportation permit.Such a bill of lading or other memorandum may serve as a transportation permit so long as it is made available for inspection to special agents of the board or any law-enforcement officer upon request.

C. The board may refuse, suspend, or revoke a carrier's transportation permit,including the use of a bill of lading or other memorandum as a transportation permit as provided in subsection B of this section if it shall have reasonable cause to believe that alcoholic beverages have been illegally transported by such carrier or that such carrier has violated any condition of a permit. Before refusing, suspending, or revoking such permit, the board shall accord the carrier involved the same notice, and opportunity to be heard, and follow the same administrative procedures accorded an applicant or licensee under Title 4.1 of the Code of Virginia.

Thank you for your consideration.

Kristal Fiser

United Parcel Service

Director State Government Affairs

Cell 206-418-9006

Office 206-621-6205