I just sent this to my Delegate
As the next Legislative Session is about to get underway there are several Firearm issues I would like to bring to your attention even before there are Bills for these.
1. We need to pass legislation that also preempts all State Agencies, including Educational Institution, from approving and passing their own regulations or Administrative Code in regards to firearm possession and lawful carry. For example, are you aware that UVA just passed just passed 8VAC85-20-30 with and effective date of Dec 5, 2011. This change was never posted in the Virginia Regulatory Town Hall System to allow for public comment, they claim exemption from the Administrative Process Act in accordance with § 2.2-4002 A 6 of the Code of Virginia, which exempts educational institutions operated by the Commonwealth.
2. We also need to take away from “§ 15.2-915. Control of firearms; applicability to authorities and local governmental agencies.” their ability to prohibit their employees from appropriately securing in their vehicles, lawfully owned firearms, that these employees keep for lawful uses before and after their work hours. As you know, commuting hours are much longer than what they use to be, and stops are made both before and after work hours where a firearm may be needed for an individual’s safety or other lawful purposes, i.e., range time, hunting, etc.
As the various bills get announced I will be contacting you to give you my opinion and input. I am also looking forward to seeing you on Lobby Day, we always have such good conversations.
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Here is the reference that UVA is claiming that makes it so they don't need public comment,
http://leg1.state.va.us/cgi-bin/legp504.exe?000+cod+2.2-4002 which states in part:
"§ 2.2-4002. Exemptions from chapter generally.
A. Although required to comply with § 2.2-4103 of the Virginia Register Act (§ 2.2-4100 et seq.), the following agencies shall be exempted from the provisions of this chapter, except to the extent that they are specifically made subject to §§ 2.2-4024, 2.2-4030 and 2.2-4031:
1. The General Assembly.
2. Courts, any agency of the Supreme Court, and any agency that by the Constitution is expressly granted any of the powers of a court of record.
3. The Department of Game and Inland Fisheries in promulgating regulations regarding the management of wildlife and for all case decisions rendered pursuant to any provisions of Chapters 2 (§ 29.1-200 et seq.), 3 (§ 29.1-300 et seq.), 4 (§ 29.1-400 et seq.), 5 (§ 29.1-500 et seq.), and 7 (§ 29.1-700 et seq.) of Title 29.1.
4. The Virginia Housing Development Authority.
5. Municipal corporations, counties, and all local, regional or multijurisdictional authorities created under this Code, including those with federal authorities.
6. Educational institutions operated by the Commonwealth, provided that, with respect to § 2.2-4031, such educational institutions shall be exempt from the publication requirements only with respect to regulations that pertain to (i) their academic affairs, (ii) the selection, tenure, promotion and disciplining of faculty and employees, (iii) the selection of students, and (iv) rules of conduct and disciplining of students. ..."
As you can see their regulation exceeds their authority since it also bans carrying of firearms by the general public inside school facilities, this is especially true when the school runs a Hospital that is open to the public for any and all care, i.e. VCU and UVA Hospitals.