I would like to thank DCJS members that listened to the input provided at the three meetings set up to discuss these extremely important changes, subsequently making revisions to the posted regulations.

The regulations, as amended and listed on the DCJS website under "Updated Regulatory Language", better articulate the practices that are currently in place.  

However, I do have a couple of points that may need clarification:

• Satellite Facility - 
  • Currently, the definition excludes:
    •  "firing ranges, driver training sites and physical fitness or defensive tactics sites which may be located away from the certified academy facility.  Commercial conferences and training facilities such as hotels and motels, which are used for mandated training, are specifically excluded from this definition."
  • This language was removed from the proposed definition, and therefore where do these locations fit in the definitions?  Proposed Satellite Facility or External Training Location definitions don't seem to properly fit because these sites are not always "temporary", or they do not always have have "academy staff" present, and some of these locations are used for basic training, not just in-service.  I would like to see language added to address this deletion that is consistent with existing language that does provide clarity.
• 6VAC20-20-90
  • states the "agency administrator" must sign the B-13.  Is there any reason a designee or training administrator/coordinator, as designated by the agency administrator, cannot be authorized to sign this document?
•  6VAC20-90-70 and 6VAC20-90-80- Academy Certification and Re-certification:
  • Proposed language establishes two different standards for a certification and recertification.  Should they not both read "be assessed for compliance with the academy certification standards" - to maintain consistency in the evaluation standard?

Thank you for your time.