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How to Find Proposed Regulations

There are actually two sets of regulations currently being considered, both of which are required to go into effect on July 1, 2008. The first set is the "General Regulations" that will apply to all tow companies in Virginia and are, except for the minimum licensing fee of $500 every year, not too harmful. Nonetheless, you should look them up, print them, and study them thoroughly.

How to find the proposed regulations that are covered by this comment forum: Go to "Google", (2) type in Va. Register of Regulations 24vac27-30-10, (3) click Show XML. The regulations will then appear and can be printed out. After you have studied them, you should then calculate how they will affect your company. Write your comments out on paper and make sure your thoughts are clear, easy to understand, and do not reglect anger. Proof-read your comments and have someone else read them and share your thoughts with you. Then you should write them out on this forum. Remember, what you say is important and your words should be well chosen because once you "submit" them, they cannot be altered.

The second set of regulations are more properly referred to as "Working Papers and are the ones that cover "PUBLIC SAFETY" towing. These regulations are not technically open for comment yet, but you should look them up, print them, and study them carefully. These are the regulations that will have serious and very dangerous impact on most tow companies in Virginia, and in my opinion have been written with the intent of putting most tow companies out of business.

You can find these documents by (1) looking up the "Va. Regulatory Town Hall", (2) click "Browse by Secretariat", (3) click "Transportation", (4) click "Board for Towing and Recovery Operators", (5) click "Board for Towing and Recovery Operators" again, (6) click "Meetings", (7) click "45 meetings during the last 180 days", (8) scroll down to "30-Jan-08", find "Licensing and Regulatory Affairs Committee", and finally (9) click " Agenda". Your computer will then show the latest "Working Paper" for the most serious proposed rules covering "Public Safety" towing. These are the rules that could kill most tow companies in Virginia. Read them carefully and you will find that very few tow companies will be able to meet the equipment, office, and storage lot regulations. The education or certification requirements will also be hurtful since most tow operators will not be able to meet them. READ the document carefully and make sure you understand every word and sentence. There are a lot of hidden meanings in this document.

The Virginia Board of Towing and Recovery Operators is an official agency of the Commonwealth of Virginia but I think it is actually serving as a puppet for the private organization known as the "Major Incident Heavy Recovery Operators Association" (MIHROA). This organization of less than 15 members has spent thousands of dollars in its quest to devise and have regulations approved that will totally control the towing industry in this state. MIHROA is a private organization that has spent a fortune on lobbying and has become an "Ex Officio" member of BTRO. In my opinion, this results in a situation in which the contact person for MIHROA is taking part in formulating MIHROA proposals which are then lobbied before himself as Chairman of the state board which has managed to make MIHROA a member of the board. This is like a judge serving as a prosecutor and defense attorney plus the jury. BTRO rarely answers questions posed to it by citizens during open public meetings and it also does not answer many of the written letters sent to it. The lobbyist hired by MIHROA is shown on BATRO's "Minutes for the "Education Committee Meeting" (Nov. 7, 2007) as the actual "Ex-Officio" member. I question whether it is reasonable for a lobbiest hired by a private organization to serve as a member of a state board that he lobbied to create and also help that board formulate policies and regulations in behalf of the private organization that hired him. Of course, these are just my opinions.

NOTE: My source for determing who the "Contact Person" for MIHROA is comes from vpap.org.