Statement: Permit Fees & Small Business Impact

Good morning. My name is [Your Name], and I've been a pilot car operator in [Your City, State] for [X] years.

I'm here today to discuss permit fees and their impact on small pilot car businesses.

Permit fees have been rising steadily, and each increase is passed down the chain — from the carrier, to the broker, to the pilot car operator. When permit costs go up, the margin for pilot car services shrinks. Operators like me are often expected to absorb those cost increases because our rates are set by the carrier or broker, not by us.

But this isn't just about our bottom line. When permit fees become unpredictable — when they vary widely from state to state, when surcharges are added without notice, when processing times stretch into days — it creates a cascade of problems. Loads get delayed. Routes get changed at the last minute. Operators are forced to reposition on short notice, burning fuel and time that nobody is compensating us for.

I want to be clear: we are not opposed to permit fees. We understand that the agencies need revenue to maintain infrastructure, process permits, and staff their offices. But we are asking for two things.

First, predictability. Permit fee schedules should be published, consistent, and updated on a known calendar — not changed mid-season without notice. Operators and carriers plan routes months in advance. Surprise fee changes make that planning impossible.

Second, proportionality. A pilot car operator is a small business. We don't have the margin to absorb cost increases the way a large carrier might. When permit fees increase, we ask that this body consider the downstream impact on the small businesses — the pilot car operators — who are essential to safely completing the transport those permits authorize.

We also ask that this body consider a streamlined, single-window permit system. Right now, an operator working a multi-state route may deal with three, four, or five different permitting systems, each with its own fees, its own portal, and its own processing timeline. A unified or interoperable permit system would reduce administrative burden, lower costs, and get loads moving faster.

Thank you for the opportunity to comment.