Based on the currently proposed regs, I would be considered an "Operator".  I have been an "Operator" for ten years. In those ten years, I have never towed a vehicle. The only time I have ever even driven my trucks was to take them in for repair or if I needed to pick them up from somewhere.  In that ten years, my company has rec'd no more than three complaints. We do not undercharge nor overcharge, we carry more than enough insurance, my equipment either new or within three years old has everything on them that are currently listed as the required items under the current working papers for public safety tows, we have won the "ACE" award several times, and my company either by phone or in person provides outstanding customer service. I know I personally do not have the knowledge to go out alone and operate and clear the scene of an accident efficiently. I read the laws, understand them, and enforce them. Now, with all of that being said, should that mean that my company should not qualify for a license after the initial license I will receive because I have been in business since before 2006? I probably would not pass the TRAA level 1 test the next year because I don't drive the trucks, I run the business.  I make sure all of my drivers are qualified to do the job. According to the proposed regs, I would not qualify for a license after year one or I would have to designate someone who could pass the test but I would almost be positive that they would not be able to do anything else, laws, enforcement, etc. I run the company, I manage the company, and I would like to think I am not the only company out here that operates as such.

Taking the above scenario into consideration, “Operators”, should not have to qualify at any point for minimum standards of testing, knowledge, future training, etc. These things should by all means, within limits, be required to obtain a “Driver Authorization Document”. These quys/gals are the ones doing the job. They are the ones that need the training. If, like in most cases, you are an “Operator” and driver, that individual should have to have the training and knowledge that would be required under the “Driver Authorization”, however, it should not be required to qualify as an “Operator”. It appears based on the fee structure that a separate designation between the two is fully made, but under the current regs, the two are often blended together in regards to requirements.  To qualify as an “Operator”, the “Operator” should have to have minimum insurance, trucks labeled, safe equipment, For Hire tags, etc but not the other items that are more important as drivers.

Some additional comments on the proposed regs, page 7 item #6 appears to have a typographical error, it currently states: that the applicant has to certify that he/she HAS been convicted of any criminal offense vs HAS NOT.

Also, on the same page #5, what happens when you are working with a corporation that has multiple stock holders whom are the owner’s of the company?

Thank you for working so hard to make this industry what it should be.