Please consider the following:

Firearms Training Requirements

6VAC20-171-365. General firearms training requirements.

1.    Registered individuals who have worked as armored car personnel, private investigators, etc., and who have a firearms endorsement may decide to add armed security officer or PPS to their registration.  Currently, they only need to take 01E and 05E or 09E. Under proposed regulations, they must take another 24-hour firearms course. This is an inefficient way to administer training by other than incremental steps. .

2.    Having several firearms courses will create confusion among registered personnel, scheduling nightmares for training schools, greater cost increases, and add to the potential for non-compliance

Suggestions:

1.    Leave the firearms training requirements as they are currently.  Given the current economic conditions, is there a need for such ambitious changes?

       But, if changes must be made, I suggest a

2.    16-hour 07E for all registered personnel.  While conservators of the peace and bail bond/bail enforcement officers are not covered under these particular regulations, this would allow them to be in compliance with their own regulations.

3.    8 hour Intermediate firearms course for armed security officers and personal protection specialists.  (Choose a course code other than 075E, as this creates confusion with 07E/05E)

4.    The Intermediate class would be a continuation of 07E, stressing issues not covered there.

5.    Entry-level and Intermediate level students demonstrate the same skill at the range. Range qualification could take place after the Intermediate course, with all students from 07E and Intermediate shooting the same course of fire one time. This results in far more efficient use of instructors and range time, which is now at a premium when available.

6.    14-hour 09E Advanced firearms course for personal protection specialists may be taken at any point after 07E and Intermediate courses are completed. 

7     Same number of hours for the three courses as proposed, but the 07E course could be taught with greater efficiency and far less confusion over two days.  Those needing intermediate training could take it the day after the 07E, and students from both classes could continue on to range qualification at the same time. 

8.    This would allow for consistency throughout all regulated categories, keep costs for classroom, instructor and range time down, and eliminate the huge amount of confusion in general affecting both the industry and regulatory activity.