I'd like to begin by stating my professional background.  I was in law enforcement for 36 years (the last six as a Chief of Police). Upon retiring from law enforcement, I was appointed the Manager of Security Services at the Virginia Museum of Fine Arts, a position I held until November, 2018, when I retired. Beginning in 2014, I was asked by DCJS to participate on several task forces whose purpose was to examine the current Special Conservator of the Peace program in Virginia. It seems that the Virginia Association of Chiefs of Police was very upset about several components of the program.  Over the next two years, many changes to the program were submitted to the General Assembly, and ultimately approved.  These changes involved new registration procedures, new application procedures for Court Orders of Appointment, new background investigation requirements, and ultimately, changes to the training required to be a SCOP. The General Assembly approved increasing the minimum number of hours of training (both legal training and firearms training).  The next step was to determine exactly what the new curriculum would be.  DCJS established a Curriculum Review Committee.  I was asked to participate on this committee, along with TWO other members of the private security industry.  Numerous individuals from the law enforcement community were selected to serve on the committee.  During the remainder of 2015, and all of 2016, the committee met on numerous occasions to develop the new curriculum.  Reaching consensus on the legal curriculum was fairly easy.  In most cases, we just recommended increasing the subject area hours.  We then proceeded to the new Firearms requirements.  During this process, there was a robust discussion.  The members from the law enforcement community were emphatic that SCOP officers must qualify on a Law Enforcement Firearms program.  They based this on the fact SCOP's could use the term POLICE on their patches, badges and vehicles.  They had been advocating at the General Assembly for the past two years for the removal of this benefit, but had not been successful.  By the overwhelming influence of their numbers on the committee, they were able to change the firearm regulations for SCOP officers to that of Law Enforcement Officers. The new recommendations now went to the Training Committee of the Criminal Justice Services Board, and ultimately to the Board.  At their meeting on May 10, 2018, the Chair expressed her desire for input from the Private Security Services Advisory Board.  At that time I was a member of the PSSAB, representing the SCOP industry in Virginia.  At our June 6, 2018 meeting, we voted to voice our objection to the proposed Firearms Regulations, to the CJSB.  They chose not to address any of those concerns.  

Now, the interesting part.  These new proposed regulations were then supposed to enter the regulatory development phase.  It took over THREE years for this to be accomplished. A quick approval process was begun in December, 2021.  Those approvals bring us to where we are today - the public comment period.

I will limit my comments solely to the necessity to change the Firearms Regulations to that of law enforcement.  It should be noted that the 2018 session of the General Assembly removed the authority of SCOP officers to use the term POLICE on their badges, patches or vehicles.  This alone removed, or invalidated, the law enforcement communities' justification in changing the Firearms Regulations from Private Security training to Law Enforcement training.  The Special Conservator of the Peace program is managed by the Private Security Services Section of DCJS.  It is a "security" program, not a law enforcement program.  Some at DCJS and the CJSB have stated the SCOPs need increased firearms training because they have the authority to make arrests.  I cannot find even a causal connection between these two issues.  In fact, certain Armed Security Officers (with only 8 hours of training) can affect arrests.  They only need to comply with Private Security firearms training.  Finally, the actual impact of these regulatory changes on the SCOP industry will be significant.  To comply with both components of the changes (legal & firearms) will require extensive classroom and range training time.  Many private security businesses and individual entities will find it impossible to comply.  There will be significant increases in expenses to purchase additional ammunition, secure ranges that can accommodate the new qualification courses, and pay overtime to backfill positions while officers attend this training.

Finally, I am respectfully requesting that the firearm regulations for Special Conservators of the Peace remain within the Private Security Services regulations.  I see no detriment to this, nor will it decrease the safety and protection to the public.  During all of our deliberations over years, not one incident of poor firearms proficiency or lack of appropriate training was presented to the any of the committees by DCJS.  I served in both the Law Enforcement & Private Security industries for many years.  I am accutely aware of, and respect, the training needed for police officers and security officers. SCOP Officers do not need law enforcement firearms training.