Agencies | Governor
Virginia Regulatory Town Hall
Department of Criminal Justice Services
Criminal Justice Services Board
Regulations Relating to Special Conservator of the Peace [6 VAC 20 ‑ 230]
Action Comprehensive Review and Update of the Training Standards Relating to Special Conservators of the Peace
Comment Period Ends 3/2/2022
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2/16/22  2:38 pm
Commenter: Virginia Museum of Fine Arts

Proposed regulatory changes as it relates to 9411

I am Cpt. Orlando L. Irving, currently employed as a Registered Armed Special Conservator of the Peace (SCOP) at the Virginia Museum of Fine Arts.  I've been with the museum 10 of the last 12 years.  My position here is the Safety and Security Coordinator, designated Compliance Agent and Firearms Instructor.  I have previously completed the Entry Level Firearms Course some years ago, and I have successfully completed the annual requalification session based on the Private Security Services (PSS) regulations for handgun course every since.

I personally feel that I am very confident in the quality of my training, in so much that, I have regularly training DCJS registrants using my instructor certifications on both the PSS and SCOP areas of training.  I am very familiar with DCJS training in that I am also an Armed Security Officer registrant and a certified General Instructor.

At the VMFA, which is a state agency, we operate as a security function and we are not a law enforcement entity, even though we are appointed and sworn.  The current PSS course of fire is more than adequate for the security service we provide as SCOPs.  "Forcing" us as a security function to comply with law enforcement standards, would place an inordinate burden on our agency, and other SCOP entities with similar functions.  As a trainer, I'm all for the increased training, although in this case, there would be a significant cost accrued for very expensive ammo, training time would increase consequentially, and training venues for tactical firearms training are very limited.  Based on these factors and the years of training required to elevate from a security firearms qualification to a law enforcement qualification level, I am not in favor of changing the firearms training requirements.  Doing so would adversely affect the SCOP program, and effectively render it unattainable.  I am requesting that the SCOP officers continue to utilize the PSS course of fire and the current handgun training course.    

CommentID: 119255