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Robert Frydrych

Roanoke Va.

Locksmith

                           Economic Impact Analysis Nov. 7, 2009 Ref; 6 VAC 20-171

Page 3 of D.C.J.S. response

D.C.J.S. reports that the legislature recently required registration of locksmiths in order to protect the public “from incompetent or unqualified persons” who were in the locksmith trade. To the extent that regulation achieves this goal, the public will benefit from locksmiths being required to register. Locksmiths who choose to become registered will benefit from likely decrease in the number of individuals who practice this trade in direct competition with them. It is not entirely clear that these benefits outweigh the cost, both direct and indirect, that will be accrued by licensed locksmith businesses and registered locksmiths. Direct costs include fees for licensure and/or registration and fees for classes. Indirect costs include the value of time spent attending classes and studying for and taking exams. In particular, the costs of business licensure may prove too onerous for some single proprietor locksmiths. The number of individuals who work as locksmith is very likely to fall on account of licensure requirements.

The use of the word onerous when referring to signally owned businesses was very appropriate, because it points to the fact that this law has become a burden to the majority of the locksmiths in this trade because most are one or two person shops. The burden has not come from the intent of the law but from the D.C.J.S regulations that has not created a completely separate category of regulations for the industry

The reference to locksmiths being incompetent or unqualified tradesmen and the public needs to be protected from them and this regulation will do that is preposterous. The fact is that D.C.J.S. has now made it easy for unqualified persons to obtain a license than it was before the law was past. We now have for the sake of money given classes on how to bump a lock to enter homes and property and they can now advertise that they are locksmiths, this is incompetent and unqualified and licensed by the same state agency sworn to protect the public.

                The law should not be helping big business to get bigger at the cost of reducing small business that can operate at a lower cost to the consumer.           

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