2.        “…the impact of these changes on the income of the regulated population should not be of a great significance compared to level of income.”  Fact is, most small wrestling shows are lucky to break even, much less make a profit when all is said and done.  Most performers make little or nothing per show if they are paid at all.  This is not including money for gasoline, food and lodging if needed.  This may not be “significant” to the promoters and performers of WWE, but it sure is to other several hundred licensed wrestlers and promoters in Virginia.  Regardless of the actual dollar amount, a 100% wrestler license fee and a 67% increase for both event and promoter license is entirely too high.  It took the state of Virginia years to raise the sales tax one-half of one percent.

3.        “The fee increase will support ongoing direct costs of ensuring the safety of the participants in boxing and wrestling events.”  The only things I could come up with that the Department does in this regard are to stop matches in the event of blood and to require each participant to pass a physical exam, which, I might add, the licensee pays for out-of-pocket himself.

4.        In one of the most interesting statements in the report it states on page 6, “Revenue for the Boxing and Wrestling Program is heavily dependent on major WWE events.  Projecting how many of these events will occur annually is unreliable.”  Small wonder that the department believes the wrestling community can absorb any cost increase.   I take that to mean that since WWE only runs events in the state a few times a year that it is up to the small promoter to make up the difference.  Continued increases in rates will do nothing but ensure that WWE events are the only ones the Department has to regulate.  How convenient.  So the message this seems to be sending is that the small business is not worth the trouble since they are not generating the funds to keep the Department in the black, so they need to disappear.

5.        I find it appalling that there are no alternative plans listed under the section marked “Alternatives.”  The Department’s sole argument appears to be that the law absolutely, unequivocally demands that fees be raised no matter what the impact to those it affects.

6.        The Estimated Economic Impact portion of the report states that DPOR expects “the board’s ending cash balance for 2004-06 will be negative $28,109.”  Does this mean the board will constantly be asking for an increase every two years “to approximately match expenses” rather than change the structure of the way the program operates to prevent the necessity of said increases?

7.        “Also, the proposed fees do remain small enough that the number of events held and individuals seeking licensure are unlikely to be reduced.”  Not likely.  I would imagine the individual wrestler licenses will not be affect to a great degree, but I would anticipate a decrease in the number of wrestling events.  The extra $200 a year may be more than many promoters can take, not to mention the uncalled for increases in the event fee.  It seems no real research was done in this regard; just stating it with no evidence to back it up does a disservice to us as citizens and taxpayers.

To sum up, in the past I have tried to keep an open mind regarding the existence of regulation of professional wrestling in Virginia.  I never had a major problem with the requirements for physicals or even individual licenses.  I have seen some really low quality product in unregulated states in the past.  However, the marketplace usually takes care of this in time.  At this point the need for the very existence of a state sanctioned body for the regulation of professional wrestling is questionable at best.  It is obvious that the Board is staffed by individuals with little to no comprehension of, and an obvious lack of respect for, the very thing they oversee.  They are attempting to over-regulate an industry that, while admittedly small in scope, is still just as valid as any other business, perilously close to the point of extinction.  This is well beyond the scope of the Board’s powers if not the reason for its existence.  I can only conclude that at this point that any value it serves to the citizens of the Commonwealth is grossly outweighed by the adverse effects it would have on the business community it regulates.

Thank you

David Layne

Unlicensed concerned citizen