|Action||Comprehensive Review and Update of the Training Standards Relating to Special Conservators of the Peace|
|Comment Period||Ends 3/2/2022|
I am currently an Armed Special Conservator of the Peace at the Virginia Museum of Fine Arts, and have been for eight years. I am also a Watch Commander and supervise other SCOP officers. Prior to this I was a sworn police officer with the Richmond Police Department for 30 years. In that role I had to qualify yearly on a law enforcement firearm course. I did this and had excellent scores on these courses. Upon transitioning to the SCOP program, I had to qualify on an approved Private Security Services firearms course. I did this and again produced excellent scores. Based on my experience, I am certainly aware of the firearm proficiency needs of police officers, AND of individuals working in the private security industry. I can assure you that these needs are not the same. Individuals employed as SCOP officers work solely in a security role, which is limited in exposure and jurisdiction. The current private security firearms training and qualification course is extensive and appropriate for the role of SCOP officers. In my opinion, converting them to a law enforcement firearms training program is unnecessary. It will increase the cost of the program and impact our staffing due to increased training times, without producing measurable positive results from this enhanced firearms training. I would request that the firearm training requirements for Armed Special Conservators of the Peace be retained as they currently exist under Private Security Services (DCJS).