( By Dean Wiley March 16, 2024 – updated March 17 12:15AM )
Too Long Didn’t Read version
The Private Protective Services Board (PPSB) is “Proposing a change” to the Administrative Code that will require (exactly) FIVE DAYS notice “to the Director” before a “Unarmed Guard Class.”
The “Public Comment Period” about this change ends on April 11, 2024. Any one that has “thoughts” about this one way or the other should:
Send an email to PPSB Director Paul Sherwin as follows:
TO: paul.sherwin@ncdps.gov
SUBJECT: Proposed Changes to 0707
BODY:
I am [for or against] the proposed change to “notification for in person classes”.
[any other information or reasoning]
Signed:
Your Name (real names only please)
[ If you are a ‘regulated by PPSB person’ and want to give them that information, add it to your ‘signature block’ ]
Original Long Version Below (with a few ‘updates’)
As soon as the NCDOJ’s CJS Division got “shut down” about “pre-delivery reports” of notification of when and where classes were to be held: The North Carolina Private Protective Services Board (PPSB) decides to take a stab at it (in the back, in the dark, illegally ‘masked’ in a lie about terminology clarification).
see: http://imfscorp.com/july-2023-efforts-against-nc-cch-proposed-changes/
Here’s the “Proposed Rule Change” to Administrative Code 14B NCAC 16 (Rule) .0707 Training Requirements for Unarmed Security Guards Notice of Text and Public Hearing 14B NCAC 16.0707 (retrieved 03.16.2024 7:45A unchanged from original Jan? upload).
The “Public Comment Period” ends April 11, 2024
The “notice” (above) says that a Public Hearing was to be held February 20, 2024 at 2:00PM. This, too, is “in error” in violation of NC General Statute [§] 150B. The hearing can not be held two months before the close of “Public Comment”.
Here is my latest and last written “comment and objection” to the PPSB acknowledged by Director Paul Sherwin as “received”: 2024_0307_PPSB_150B_Comment_0707_ProposedChanges
( Word docx format if you want to modify it and submit it yourself: 2024_0307_PPSB_150B_Comment_0707_ProposedChanges )
TO: All Trainers; All Licensees; All potential “PPSB Regulated” people, especially those that “may” one day want to become a Certified Trainer
Send in your comments – IN WRITING! – and/or send in a WRITTEN DEMAND to be heard “by voice” before or during the April PPSB “meetings” (law/rules committee or full). If you don’t: you won’t have “legs to stand on” (exhaust the administrative process) after they “sneak” this five day (exactly) notification requirement through for your 16-Hour Basic or “Unarmed” courses.
= = =
( More ‘history’ and details from emails later )
Question: Why ‘fight’ this when you have always sent “Pre- and Post- Delivery (Notification) Reports” for your Armed Courses?
Answers:
- Notification was required for ‘gun’ classes when I signed up to be a Firearms Trainer. I “went into it” fully knowing.
- Notification has never been required for Basic or UnArmed classes/courses.
- Notification for Basic classes/courses has never been discussed as an “unofficial” idea seeking public – including in-industry “private people and business effected in a burdensome way” – input.
- The Board (members that are also ‘committee members’ of CJS Division) seeks to “intrude and interfere” in Private Commerce for (I truly believe) utterly immoral, illegal, unlawful, and/or “just stupid” reasons**.
** Licensee Board members “stealing” names of Trainers and other Licensees and/or Companies’ employees and other “industrial espionage”. Government intrusion and interference (tyranny) for “the sake of it; because we can.” Stupid = (as stated in my Comment and Objection letter above) The inclusion of “in-person” class notification may be a “typo.” - The Board is not now – and never will be – “invited or allowed” to “audit” my/our classes because my/our classes adhere to the letters of the law and code and ‘use’ their materials – with much more time spent pointing out “flaws” (dangerous mis-informations/mistakes, nonsense, typos, impractical/unrealistic “guidance”, misstatements of law [see power of arrest, assistance to LE, stricken 1989]) that all of the Board (many years, members and staff) don’t seem to notice or care about. My/our classes are delivered from a “We have to know this stuff because the Board will ‘quiz’ us on it” but “We have to be able to use the time to also ‘teach’ some real-world practical PRIVATE business realities” not from a “Good enough for government work as a government ‘instructor'” mentality.
- The Board “may not” intrude upon “private business” in some misguided idea of “surprise audits”. (See NCCCH “nipped in the bud” above) I “pay for” the seats in my classes (room rent, sometimes per seat/person), and the Government CAN NOT “just show up” and cost me/us extra money. Even if they “could” – We would require them to PAY for their ‘seat’ in the class and sign a “personal” (not government agency” GUARANTEE that they won’t use the “real, correct information” received in our class to “fix” the above “errors” in their materials and/or “improve their position or pay or status at the PPSB as an employee without crediting and paying appropriate contract fees and royalties.” We already do – and always have – PAID (for) THEM to make this mess. They are not going to “steal” in the name of “audit” a way to “look less incompetent and apathetic.”
( Again, more later, I have to go to a Train-The-Trainer ‘meeting’ for UAGTs. 8:19AM 3.16.2024 )