Virginia Regulatory Town Hall
Department of General Services
Department of General Services
Regulations Banning Concealed Firearms in Offices Occupied by Executive Branch Agencies [1 VAC 30 ‑ 105]
Action Promulgation of new regulation banning concealed firearms in executive branch agency offices
Stage Proposed
Comment Period Ended on 10/21/2016
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10/21/16  10:49 am
Commenter: David Dick, Private Citizen

Does DPB contradict itself in its Economic Impact Analysis?

The Department of Planning and Budget’s (DPB) Economic Impact Analysis (EIA) states that “To date, data on gun violence rates in government office buildings reflects statistically low incident rates given that many individuals pass in and out of state office buildings each day.”  No footnote cites the source of the data upon which DPB relied.

In the same paragraph DPB further states that: “In addition, there is no available data of past incidents of guns entering or being brandished within affected executive branch buildings in Virginia.” 

“Statistically low,” and there “is no available data?”  “Statistically low” clearly implies that DPB examined existing relevant data that revealed a low number of incidents.  “[N]o available data” states that there is no data to examine to reach the “statistically low” opinion. 

Either there is existing relevant data or there is no existing relevant data.  DPB is obligated to cite the source of the information it relied upon to construct its EIA.

The conflicting analysis clearly demonstrates that DPB has NOT performed the Economic Impact Analysis required by statute.

The document must be amended to cite the existing data analyzed or state that they could find no existing relevant data upon which to base their “statistically low” opinion. 

Once the Public has access to an amended EIA, the Proposed Regulation comment period must be held again to allow full public consideration of an EIA that complies with statute and, then, comment on the proposed regulation.

CommentID: 55417