Question 1: How do you become a member of The Board? I don't want to use sarcasm but I don't know another way to as effectively get my point across: Does anyone remember our history books about the Boston Tea Party? (Taxation without representation) To my understanding, everyone on the board has been appointed. How do we ensure that we as the general tower ensure that we are represented? I agree that towing associations do have many benefits but I don't believe that just because you are not a member that you are not a professional. To my understanding there is a lot larger percentage of towing companies that are not members of local association than are. Thus, if everyone on the board is a member of VATRO, then the overall population of towers, the higher percentage, is not being represented.

Question 2: In one of the previous comments someone asked a question as to why have there not been comments since this board has been taking place over the last three years. I am one of the 700 companies that registered but have only rec'd three documents in the mail from the board. If this has been going on for three years why, if I registered, have I not received any information as to the status or the 'goings on' of the board? Though, based on a document that I did receive, the board went into effect in July of 2006 which would only mean the board has been around for 1 1/2 years. Even still, where are the notices?

Question 3: On the hot topic of training, how is the board going to determine who qualifies to give the training? I, like others it would appear, feel as if the training requirements should be every three to five years and not every year. A lot of us get training as we go but apparently that is not going to be sufficient. Why not make a testing requirement every three to five years and if you cannot pass the standardized test then require the completion of training? I, for one, do not want to bolster Wreckmaster's profit every year. Also, we are required to have huge amounts of insurance, if an insurance company will insure our company and we can pass a standardized test, why should we have to pay even more for additional training on top of what we already pay? It also says that at least one half of the training has to be face to face. Why? It appears that not only do they want to require continuing education, which is helpful, but they want to regulate who gives us that training, how that training has to be conducted, what training is NO good. But, the proposed regulations also say that one hour of continuing education credit shall require the licensee's presence and participation for at least 50 minutes. This does not make any since to me at all and is contradictory to their other requirement of having 50% being face to face.

Questions 4: Is there anyway to make endorsements to the towing license like what the state currently does with the CDL license? IE:, One endorsement for private property towing, one endorsement for public safety towing, one for repos? Depending on the endorsements, it could increase the amount of the license vs charging the $500.00 to anyone for a general license. For those of us that do not tow for the police or private property, we should not have to comply with all of the additional minimum requirements that may be needed to provide different services. If I have a set customer base that is happy with my services, why is the Board going to try and regulate free trade?

Question 5: On one of the previous comments, it is said that the fee structure was based on the number of companies that registered. However, in the 'Draft' of the regulations it is listed at "Businesses and Entities Affected. Approximately 2,200 towing operators and 9,000 to 10,000 drivers are estimated to be affected." If these numbers are listed in the proposed regulations, I don't know how we could be using the 700 number for estimating the fees. Likewise if there are 2,200 @ $500 a year that equals 1,100,000.00 just for the companies and 450,000.00 for driver authorizations. If the board has to operate within 10% exactly how much money are the board members making? Those are just the two basic fees, that does not include all the others the Board would be collecting. Do we as an industry feel that it is appropriate for us to pay over 1 MILLION dollars to regulate our industry per YEAR?

Question 6: Under section 24VAC27-30-100, #4 and #5, these sections state that upon request we are to open our books and records to the board at the boards request and it is all inclusive. I should not have to show my records for my business that I conduct outside of public safety, private property, or repo. It also states that we have to tell them where the records are maintained. Why? How "Big Brother" are we allowing this board to be?

Question 7: On page 2 of the Draft the board supposedly did research on the financial impact to the average company. It makes a comment: "One possible disadvantage to the public might be that a one-truck operation may elect to cease operating in a locality rather than seek licensure. At this point, it is not known, in spite of the board's efforts to identify the affected entities, how many businesses may elect this option." What are the efforts the board made? It also states: There is insufficient data to accurately compare the magnitude of the benefits versus the costs for other changes" How do we not consider that the new regulations will not have much of an impact? Annual fees, $500 license, $10 per truck, $50 for each driver, TRAA certification-$100 level one $260 level two, as noted in the regulations "these operators will incur time costs associated with studying for and taking" these tests, the fingerprinting $50, proposed annual training $200-$1000(plus more for drivers too), fees to provide the customer's with required documents and having them available at all times including 'providing the owner of a stolen vehicle written notice of his right under the law to be reimbursed for towing and storage of his vehicle'. If these amounts are added and looked at collectively, they pose a large impact on companies especially the ones that follow the rules as it is.

Question 8: Where in the regulations does is show or state how the enforcement will be made to those that don't comply other than what the penalty will be? It appears as if those of us that follow the rules will be most impacted.

Question 9: On page three paragraph three it states: "the Board may refuse to issue a license or tow truck driver's authorization document if, based upon all the information available, including the record of prior convictions of the applicant or any individual who is an owner, manager or other person involved in the management or operation of the applicant's business, it finds that the applicant is unfit to engage in providing towing and recovery services" Why does the Board have a right to say someone is "unfit", without having specific items that would make it such? This gives Big Brother way too much room to govern who can do business with such an open statement. Doesn't free trade allow an individual to decide if they should do business with me? I really do understand and agree with a lot of the regulations with regards to public safety tows, private property or even repo, but normal free trade work?

Question 10: Page 4, paragraph 4, if a rouge company operates currently without required insurance why would they bother to even get a license? They already show the disrespect for the law.

Question 11: Why are we being required to update our license every year and drivers update every year? This really seems excessive in regards to money, both what companies have to pay out and what the Board has coming in, in regards to paperwork and the work that goes into having to update the license every year. If you are mechanic and have a State Inspection License, you don't have to update it every year and yet they deal with vehicles as we do along with the new vehicles that come out every year.

Question 12: Page 5, paragraph 2, "There are no localities that should expect a disproportionate impact from these regulations". How was that determined?

Question 13: Page 5, paragraph 6, "Alternative Method that Minimizes Adverse Impact. There are no clear alternative methods that both meet statutory requirements and reduce adverse impact" I have read several options and have submitted some of my own. So, how can that statement be true? Also part of this section is states that the Department of Planning and Budget that it should include "(ii)the projected reporting, recordkeeping, and other administrative costs required for small businesses to comply with the regulation, including the type of professional skills necessary for preparing required reports and other documents." Where is this explained or documented?

Question 14: Page 10 #7, paragraph 1, its states that "Such tow trucks may only be operated by an employee of the dealer or manufacturer for the sole purpose of transporting it to and from the location of sale or demonstration", etc. What about when or if a towing company needs to rent a tow truck if theirs is in the shop? Or a shop wanted to give the company a loner truck if the situation was called for?

Questions 15: Page 10, 24VAC27-30-80, What qualifies as an emergency to transfer an operators license?

Question 16: Page 10, 24VAC27-30-100, It states that if all you are doing is repossessing vehicles, you don't have to label your truck with the company name. How are they going to know that in fact repossession is all that company is doing?

Question 17: Page 11, 24VAC27-30-110#4, it specifies the minimum insurance requirements. Why are the requirements the same for class A and class B? Class A is hauling items worth much more than any class B would be able to. Also, I currently have on-hook coverage greater than what is required but I have it split up between my trucks. Does the 50k limit have to be for each truck, if so it seems high for class B?

Question 18: Page 11, 24VAC27-30-110#9, it states that "Operators shall not provide public safety towing and recover services unless they have met the criteria established by the Board.." How is any company going to be able to comply with this standard July 2008 or even 2009 if the standards have not even been completed? I think, as someone asked before, are we going to have to operate illegally based on these regulations going into effect without having the supporting items being completed as well?

Question 19: Page 12, 24VAC27-30-110#16(i), it states all fees have to be displayed. What about the provider that does not handle public safety, repo, private property?

Question 20: Page 13, 24VAC27-30-130B, "It says anonymous complaints received by the board shall be handled in accordance with board's policy and guidance documents" What are those documents? Is it not true like, someone else mentioned, that we have the right to face our accuser? What is going to be required to substantiate a complaint? What is to prevent false complaints?

Question 21: Page 14, 24VAC27-30-160 #2,#3, "Provide evidence at time of application for a tow truck driver's authorization document that he is employed or about to be employed by a licensed operator and the name and address of that operator." Many drivers have stays in between jobs, why is this information is required? If I have to make sure a driver is licensed, it would be nice to be able to know that he/she already has a license and not that they have to submit a request before they can work for me or anyone else. Why does a driver have to be employed by a company to maintain a towing license? If he does not, why does the license have to have a board-issued license number of the driver's employer?

Question 22: Page 14, 24VAC27-30-160#6.#7, Why do we have to have a signed statement from a driver that they have complied with the requirements if we also have to verify that they have a license? If they have a license, does that not show that they have complied? Linked to the questions also in 21, why does the board need to know what driver is working for what company? If the company has to make sure it's drivers are licensed, it should not be any business of the board which driver is working for which company? Going back to the reference of an automotive State Inspector, they don't have to notify anyone they are changing jobs are their license is good regardless of where they work.

I personally feel that this Board is trying to over control the industry. How do we make it stop? Regulations are good, they provide a level playing field, so to speak, but these regulations are going so far as to affect free trade. My company, by the way, already complies with all of the requirements including the requirements within the Working Papers of 12/20/07, other than having the actual license, which are not available yet.