January 25, 2008
Mr. Ray I-lodge

Chairman, Virginia Board of Towing and Recovery Operators
Highway Garage
1269 American Legion Road
Fredericksburg, Virgin 22405

Dear Mr. Hodge:

I would like to take this opportunity to discuss some issues concerning the Board of Towing and Recovery Operators (BTRO) and the position of the Vii State Police concerning these issues. As you are aware, I met with Mr. Malt Benka on November 20,2007 to discuss some of the proposed regulations of the Board regarding public safety tows.
We discussed regulations pertaining to training requirements and equipment mandates, specifically, the requirement for both Class A and B towers to have a second wrecker in order to be certified by the Board for public safety towing. At this meeting, Informed Mr. Benka that our position at the time was in support of the two wrecker requirement for both classes, as long as there was an AMPLE window of opportunity for towing businesses to come into compliance, preferably five years but no less than three years at a minimum. In regards to mandatory training, I stated our position was for support of training requirements as long as towing operators had sufficient time up front to come into compliance and that the training was readily available statewide and that it was affordable.
Since that meeting, I have received numerous telephone calls and letters, and have had meetings with other law enforcement officials, towing industry representatives and traffic safety advocates along with consumer service providers, who are very concerned about the proposed regulations and their Impact on the towing industry statewide, ESPECIALLY on small business owners. These contacts have provided me with additional information and insight that has convinced me that there is not overwhelming support for the proposed regulations as I was led to believe initially, particularly for the training and equipment mandates. Therefore, based on this outpouring of concern, the State Police has reconsidered its earlier position regarding these regulations and cannot support the adoption or Implementation of them at this time.
I believe more time is needed in order to fully evaluate and determine the impact of The proposed regulations on the towing industry in Virginia. The Board should be careful not to alienate its many partners by pushing through burdensome and far reach certification and equipment standards that would result in many owners having to get out of the business partially or altogether The Board would be better served initially to proceed slowly, implementing reasonable regulations widely supported throughout the towing industry. As it appears to me, to do otherwise would resuit in failure of the Board to accomplish its intended purpose, which is to regulate the towing lndustry fairly and in a manner which must benefit towing businesses of all sizes, as well as the public.
The Department of State Police looks forward to working with the Board and the towing industry. Please do not hesitate to contact us if we can be of any assistance.

Sincerely,
Superintendent