Virginia Regulatory Town Hall
Agency
Department of Criminal Justice Services
 
Board
Department of Criminal Justice Services
 
chapter
Regulations Relating to Private Security Services [6 VAC 20 ‑ 171]
Action Comprehensive Review Private Security Services Regulations
Stage Proposed
Comment Period Ended on 10/24/2012
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10/24/12  11:29 pm
Commenter: John Kochensparger

Opposition to Additional Fees
 

Essentially, we have been in this regulatory review process since Mark Warner was governor.  Every governor since Mr. Warner has dipped into our resources to balance the overall state budget, thereby shorting the "public safety," the basis for our regulation, by preventing DCJS Private Security from performing the services we require.  Since the governor takes a percentage of our money, the fee increases which DCJS is proposing seems to be ill advised.  Though it may permit more monies for their operations to help them offset the governor's seizure of funds, it also increases the money the governor can draught for other purposes.

Specifically, I single out the Manual Processing Fee and the Instructor Certification Category Fee

Let's revisit the manual processing fee once "ROCS" is reconstructed to better facilitate online submittals.

In my opinion, the Instructor Category Fee is very petite.  To me, this suggests micro management, a time when DCJS was being very bureaucratic and mid-mangers were trying to justify their positions, perhaps even trying to generate revenue.  Though there is precedent on the added category fee for business, individual registrant do not pay a category fee.

 

Respectfully submitted, John

 

CommentID: 24378