I am currently an Armed Special Conservator of the Peace, and have been for 12 years. I am a Watch Commander for the Security Services Department at the Virginia Museum of Fine Arts. We have a very robust SCOP program at VMFA, and it has served us well for many years.  Upon entry into this program I had to attend and successfully complete the Entry Level SCOP course and Firearms Qualification.  I have also attended annual In-Service and had to requalify with a firearm.  The Firearms Course was the required DCJS course mandated by the Private Security Services Section. This firearms course was professionally administered by qualified Instructors and has served us well. Unfortunately, the proposed changes to the firearms regulations will require all SCOP officers to now qualify on a law enforcement course.  This problem with this change is that we are a purely security function.  We do not operate in any way like a law enforcement agency and are not exposed to the daily hazards that police officers are.  The SCOP program is also administered and managed by the PRIVATE SECURITY SERVICES SECTION of DCJS, not the law enforcement section.  Also, changing to this new requirement will be costly in terms of ammunition costs and additional ranges fees (if we can even secure adequate range times), and scheduling demands by having to re-train all of our officers.  Based on the reasons listed above, I am opposed to the new firearms regulations for SCOP officers and request that the regulations remain as they now are.