A piece of legislation currently submitted to the Virginia House of Delegates has been brought to my attention that would alter the current language of  54.1-828, 54.829.1 and 54.1-830.  I believe the proposed language contained in HB 1228, 54.1-829.1 Paragraph C, Lines (i) and (iii)  specifically, will induce a negative impact upon small businesses across the Commonwealth, including my own.  54.1-829.1 C, (i) seeks to increase the criteria for existing, approved sanctioning bodies and any other bodies that may make application in the future by requiring each body to (i) "provide documented evidence it has acted as a business for the immediately preceding five years as certified by the State Corporation Commission"  and (iii) Have demonstrated experience as a sanctioning organization for at least six different eventsper year over such five year period representing at least three different promoters". No sanctioning body, including currently approved bodies, with the exception of one could meet the requiremnt set forth by the proposed alteration of 54.1-829.1 C (i) and (iii). Currently approved sanctioning body UCAS fails to meet the proposed requirement (UCAS, 2015, less than 6 events, less than 3 promoters, SCC file year 2013) as does currently approved sanctioning body VCSS (2015, over 6 events, less than 3 promoters, SCC file year  2011). The only current body with ability to meet such a requirement would be GCA (2015 over 6 events, more than 3 promoters, SCC file 2007). Also, I believe no other body having existed in the state over the course of the preceding 5 years could meet the requirement (UFO, WKA). I believe the proposed language will in effect prohibit the creation of new sanctioning bodies if/when the mixed martial arts industry should grow to have demand for additional bodies. I believe the language also in effect prohibits experienced sanctioning bodies from outside of the Commonwealth from the ability to be approved to operate within the Commonwealth. (ex: IKF, USMTA, ISCF).  I further believe one sanctioning body could not meet the current demand of promotional companies operating in the Commonwealth.  For the reasons I have stated above, the proposed language in HB 1228 54.1-829.1 C (i) and (iii) would create a unlawful monopoly as defined by the Virginia Antitrust Act 1974 c.545 59.1-9.6. 

Should the proposals within HB 1228 be enacted, I believe would create a burdensome,and costly environment and hinder my ability to continue to conduct my events in a efficient and profitable manner within the Commonwealth. I also believe this will become the circumstance for many promotions throughout the Commonwealth. As my own and others host less events more infrequently, it will have a adverse and negative impact on small businesses and local economies that depend of the revenue generated by mixed martial arts events through purchases of items such as gasoline, lodging, food, retail products, business to business services, equipment and venue rentals, security and emergency medical services coverage. 

I believe it will also inhibit the ability of amateur athletes to gain sufficient access to opportunities to test their skill sets and gain practical experience in preparation for the professional ranks. This circumstance could aslo create a side effect by reducing the number of professional athletes within the Commonwealth, negatively impacting promoters of professional bouts within the Commonwealth to host events. Less amateur and professional events will cause athletes to seek opportunities outside of the Commonwealth, drawing even more revenue away from local economies.

I am thankful for the safety requirements established by new regulation enacted October 1, 2015. If I were to wish to add anything to existing regulation it would be requiring sanctioning officials to fill out and sign a affidavit of disclosure, identifying any conflicts of interest that may become present during a event (ex; referee and/or judge, should not be permited to officiate/corner the bout of a team mate, etc). I would also like to see athletes be required to submit a pre-fight medical questionaire as a additonal safety measure the day of the event prior to their contest. 

I respectfully submit these comments and Thank You for your committment to our Commonwealth and Industry.