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.

I am currently employed as an Armed Special Conservator of the Peace at the Virginia Museum of Fine Arts in the Security Services Department.  I am also a Watch Commander and supervise other officers. Prior to this I was an armed police officer for six years.  I have had to complete both a law enforcement firearms course along with a private security firearms qualification course.  I am accutely aware of the firearms training requirements and the need for them for both industries.  I have successfully qualified with a firearm for the past 11 years, conforming to the established private security services regulations established by the Department of Criminal Justice Services. I am absolutely aware that police officers require a higher level of proficiency with weapons than do members of the private security community. However, the firearms course that we utilize in private security is intense and certainly prepares us for our role as a security function.  As one who has participated in BOTH firearms programs, I do not believe that it is feasible or necessary to require SCOP officers to now qualify under a law enforcement firearm course.  These requirements are excessive, will impose additional expense to our agency, and challenge our current staffing to provide this enhanced training.  As such, I am oppossed to the current proposed regulatory changes to the SCOP Firearms regulations and request that this part of the regulatory process be reverted back to the standard Private Security Services training requirements.

I am currently an Armed Special Conservator of the Peace at the Virginia Museum of Fine Arts, and have been for eight years.  I am also a Watch Commander and supervise other SCOP officers.  Prior to this I was a sworn police officer with the Richmond Police Department for 30 years.  In that role I had to qualify yearly on a law enforcement firearm course.  I did this and had excellent scores on these courses.  Upon transitioning to the SCOP program, I had to qualify on an approved Private Security Services firearms course.  I did this and again produced excellent scores.  Based on my experience, I am certainly aware of the firearm proficiency needs of police officers, AND of individuals working in the private security industry.  I can assure you that these needs are not the same.  Individuals employed as SCOP officers work solely in a security role, which is limited in exposure and jurisdiction. The current private security firearms training and qualification course is extensive and appropriate for the role of SCOP officers.  In my opinion, converting them to a law enforcement firearms training program is unnecessary.  It will increase the cost of the program and impact our staffing due to increased training times, without producing measurable positive results from this enhanced firearms training.  I would request that the firearm training requirements for Armed Special Conservators of the Peace be retained as they currently exist under Private Security Services (DCJS).

I am a DCJS certified instructor for SCOP and for Firearms. Have been for over 23 years. If DCJS is trying to get rid of the SCOP program, then I think these proposed changes will accomplish that. I feel the program has been abused in the past (the word Police and Blue lights, etc,.) but they are some of the most trained personnel you have on the streets in Virginia (not counting the Police). Is Law Enforcement trying to force-fill their depleted ranks with former SCOP's? Why would any SCOP stay a SCOP after qualifying for the Police? Why the changes? I haven't heard of a SCOP shooting anybody. But, if you must make a change, I suggest the Armed SCOP qualify twice in a year before they get a card. Let them have a Letter until the second qualification then issue a card. This will still be cheaper for the SCOP but will hopefully keep proficiency levels up. Or maybe add 09E as the "second" firearm requirement.     

My name is Stacy Sumner and I am the Manager of Security Services at the Virginia Museum of Fine Arts. I have been with the VMFA for 12 years and a SCOP Officer for 10 of those years. Our SCOP program provides security to the facility 24 hours a day, 365 days a year. The VMFA is one of the top 10 fine arts museums in the nation, which further proves the vital need for the highest level of security. We are a state funded facility with budget restrictions like any other state funded agency. With these new regulations, the impact on our budget and staffing would be devastating. With additional costs for ammunition and range fees for two different firearm ranges, and also the strain on our staffing to require every officer to meet these new training requirements, these new regulations would be unrealistic to match and ones that simply cannot be accomplished with normal or even exceptional effort. I am not in favor of changing the firearms training requirements and I strongly recommend that our SCOP Officers continue to utilize the Private Security firearms courses.

I am Cpt. Orlando L. Irving, currently employed as a Registered Armed Special Conservator of the Peace (SCOP) at the Virginia Museum of Fine Arts.  I've been with the museum 10 of the last 12 years.  My position here is the Safety and Security Coordinator, designated Compliance Agent and Firearms Instructor.  I have previously completed the Entry Level Firearms Course some years ago, and I have successfully completed the annual requalification session based on the Private Security Services (PSS) regulations for handgun course every since.

I personally feel that I am very confident in the quality of my training, in so much that, I have regularly training DCJS registrants using my instructor certifications on both the PSS and SCOP areas of training.  I am very familiar with DCJS training in that I am also an Armed Security Officer registrant and a certified General Instructor.

At the VMFA, which is a state agency, we operate as a security function and we are not a law enforcement entity, even though we are appointed and sworn.  The current PSS course of fire is more than adequate for the security service we provide as SCOPs.  "Forcing" us as a security function to comply with law enforcement standards, would place an inordinate burden on our agency, and other SCOP entities with similar functions.  As a trainer, I'm all for the increased training, although in this case, there would be a significant cost accrued for very expensive ammo, training time would increase consequentially, and training venues for tactical firearms training are very limited.  Based on these factors and the years of training required to elevate from a security firearms qualification to a law enforcement qualification level, I am not in favor of changing the firearms training requirements.  Doing so would adversely affect the SCOP program, and effectively render it unattainable.  I am requesting that the SCOP officers continue to utilize the PSS course of fire and the current handgun training course.    

My name is Edward Andrews and I have been registered as a SCOP Officer with the VMFA since April of 2021. I believe that my successful completion of an Entry Level Firearms Course based on private security regulations was more than sufficient for my duties at the VMFA since I provide a security function and not a law enforcement function. With the training I received, I am confident in my ability to use a firearm if necessary, and therefore not in favor of changing the firearms training requirements. I would prefer to see SCOP Officers continue to qualify on private security courses. Thank you for your time and consideration.

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.

The Dept of Behavioral Health utilizes a hybrid approach to security and law enforcement on our facility campuses.  We partner with the VSP, local law enforcement, employ SCOP and security staff as well as embedded hybrid care/security staff into each patient area.

We operate a DCJS Certified Training Academy to assure our staff are trained to the highest standards and in a quality manner across our system using DCJS audited materials and policy.

To dramatically increase training requirements adds time which will equate to more positions to train our systems staff, it adds days of travel to our centralized training academy and a plethora of small costs.  As mentioned by other state agencies, our jobs in state agencies is not to be a "street cop".  In our case, its patient care - the safety of individuals committed to state hospitals and training centers.  We also have a dual mission to protect our staff from workplace violence.  We call in the most skilled units of VSP and a nationally certified local law enforcement partner when the "right tool" is needed to perform those extreme risk duties.  We have an excellent relationship with law enforcement professionals to handle the toughest and most dangerous situations like active shooter, etc.

We will follow the regulations if adopted, and we will perform them to the letter.  However, is this action evoking the intended results or is it innocently adding burdens to partner agencies across the Commonwealth in a manner bringing unintended cost and consequences?

   I am a special conservator of the peace (SCOP) with VMFA. I’ve been registered as an SCOP for nearly one year now. I am a Security technician, I have studied the criminal justice system, I’ve held arrest authority for many years prior to Joining VMFA, I have been a security officer  for over 6 years.I have successfully completed the entry-level firearms course that, I am now due to re-qualify for with a handgun as a  security professional. I believe that the fire arms training provided by DCJS certified instructors at the vmfa provides us with high abilities that fit our role as SCOPs’.  

    I am confident in my abilities if necessary to engage with all safety precautions and proficiency while using a firearm. I enjoy providing security at the VMFA knowing that the public can enjoy themselves in a safe secure environment. As security professionals we observe, report and support local law-enforcement if necessary at their request. I am not in favor of changing the fire arms training requirements. The private security firearms course requirements should remain as the standard requirement for the SCOP program. Whether if it’s title changes or qualification changes the character of the security professional is a prerequisite and with that discretion results right or wrong in the color of law.

I am a retired City of Richmond Police Detective of 28+ years service, followed by 8+ yrs. service to Sheriff of Richmond City. Following that I entered into service as a SCOP/Police Officer with the Richmond Metropolitan Transportation Authority part time, as well as a SCOP/Police Officer part time with the Security Section of the Virginia Museum of Fine Arts. In all these jobs starting in 1978 Graduation from Richmond Basic Police Academy I performed my jobs with profession .I was required to qualify yearly with my service weapons issued by these jobs as well as attend 40 hr mandated service every two years which I attended with due diligence. Since the SCOP program has unnecessarily been stripped of its Police authority, Training has continued successfully under the private security format and firearms training level which in my experience of over forty years of service and training it seems that the people on this have no real idea how hard the instructors efficiently train the VMFA Officers. It would be a waste of time and training funds to require what is already more than sufficient for standard private security officers, which is what SCOP has been reduced to, thanks to the Sheriffs, Police Chiefs and the DCJS. So, I disagree with any decision to change what training already provides better than adequate representative SCOP Officers fulfilling their private security requirements for the VMFA and the State of Virginia. Don't waste the money on bullets and our time with family and keep our training on a steady track and professionalism.

I have been a SCOP officer at VMFA for approximately 4.5 years. Prior to that I retired on a compensable disability pension due to line of duty injuries sustained at the Richmond Police Department. I was there for approximately 10 years including an assignment with ATF on the Project Exile Task Force. I was there for about 16 months. Based on all my training and experience with law enforcement I see absolutely no reason to make any changes regarding the SCOP training. It is unnecessary  and would be a waste of time, money, and resources. Why try to fix something that isn't broken?