I am making the following comments for the working registrants in the industry! The industry feels that some of the proposed changes to the regulations are not taking into account, the concerns of the many registrants that are acually working. Examples;

6VAC20-171-20 Fees. The changing fee for Firearms Endorsement from $10.00 yearly to $30.00 yearly is an expense that is not supported by the armed industry. The manual processing fee of $20.00 for processing is also not supported by the industry.

6VAC20-171-110 #3 The completion of 2 hours professional development for each category of instruction puts an additional strain on instructors that also work in the industry. This puts instructors that teach in addition to their responsibilties in their jobs into a stressful situation doing what will be mandated by DCJS and the industry may lose some very good instructors. This seems to be a problem if passed.

6VAC20-171-220 The industry seems to have a real problem with the change in regulations that if someone is arrested they would have to notify DCJS of that arrest. The industry has no problem with after being convicted or pleading guilty or no contest, but other than that this is going way to far! 

6VAC20-171-135 Firearms endorsement being limited to retraining 90 days prior to their endorsement expiration is a concern to a lot of armed registraints and their schedules Each registraint knows when their endorsement expires and the industry seems to feel that anytime within the 12 months prior to expiration they should be allowed to retrain.

6VAC20-171-380 Shotgun qualification and requalification change has the armed registraints disturbed by the increase.  It is not only the mass increase to the rounds to qualify but also the the shotgun registraints have said that they want to keep their shotgun endorsement, but they do not think they will if this increase passes.