I have several concerns about your Proposed Regulations from the Virginia Board of Towing and Recovery. My first concern is that we are portrayed as a band of outlaws taking advantage of everyone in our path. That can not be further from the truth! We are mostly family men and women trying to be productive members of society. We provide a valuable service for the Police departments and the public.

As in your issues section of your Proposed Regulations you state the primary disadvantage to our industry is that individuals and businesses offering towing and recovery services have never been licensed and regulated. I beg to differ, all of our drivers are licensed by the Virginia Department of Motor Vehicles, our businesses are licensed by the locality in which we preside, and our industry is closely watched by the local Towing Advisory Boards. Our local police department does a fine job keeping local towing companies in check when there is a complaint. In Virginia Beach we have a towing comment survey form that is given to each non-consensual and police tow. The complainant must mail in the form with their contact and tow information. This allows the towing company to present their side of the story when accused of wrongful conduct.

In regards to the issue of fingerprinting, our president of the company must be fingerprinted in order to maintain our position on the police list. Each employee must be submitted to our insurance company before hiring to ensure that each driver has an acceptable driving record. You state that an advantage of these regulations is that it will bring greater consistency of service to the public by insuring that a person that has been convicted of certain crimes will not be exposed to the public. I would like to know how many citizens have been the victims of a crime committed by a tow truck driver. Most people that are broke down or have been in an accident are overwhelmingly happy to see that a driver is there to help them. These men and women work through all types of weather and are often called upon in the middle of the night to help clear accident scenes or to remove vehicles at the request of the police department.  

One major disadvantage to the public, the employees, and the towing company is that this will raise the cost for everyone involved. The prices will have to be increased for the consumer. The increased cost will affect the amount of employees that a company can employ and it will affect the type and amount of equipment that a company can afford. This will affect the “little guy” towers the most. Most of these are families that have done this all their lives. In many cases this is all they know and want to do, for the most part they are not technology advanced and this increased regulation will create a hardship that could lead to their demise. What will happen to the employees and their families? In the economy that we presently have, how many jobs do you think that it acceptable to loose? In my opinion one is to many.

I am also concerned about the education requirements. What constitutes a reputable educator? This industry is not taught by a book; it is years of hard work and long hours that teaches each great driver. What cost will be imposed for this education?

On the subject of the temporary trip permits, I am very skeptical that they can be enforced. Are the Police Departments supposed to look at every tow truck that they come across for the decal? If a tower is indeed caught what is the punishment?