Please consider the following general recommendations for incorporation into the proposed Regulations in all sections which apply:  (continued)

  >  Entry-level training - the new Private Security Orientation (10E) - seems like a nice idea, however, it undermines the foundation of the training.  10E purports to include:

      Introduction to Private Security

      Applicable sections of the Code of Virginia,  9.1 - 138 - 150

      Regulations Relating to Private Security Services.

  All this to be covered in 2 hours.  It sends a message that the Code and Regs are not very important.  This segment should be presented to the specific category of students so that it emphasizes the points of the Code and Regs that are most pertinent to them.  It should focus on the issues that will keep them legal and in compliance.

  >  Firearms Training - the proposed changes to the entry-level and firearms retraining are drastic - and would require excessive time and cost.  The current curricula should remain in place.

  >  The Department is proposing additional tasks for staff at a time when positions are being lost or unfilled, resources are lacking, and there would be a need for greater enforcement.  Please reconsider,

    Additional recommendations for incorporation into specific sections of the Proposed Regulations are being sent via e-mail to Lisa McGee, Section Chief, Office of Regulatory Affairs.  I look forward to collaborating with you to develop a comprehensive solution that enables compliance while also mitigating legitimate concerns.

                                                                                              Respectfully submitted,

                                                                                                              Martha M. Clancy