You get "arbitrary" standards, a one size fits all if you leave it to the goverment to decide on an exercise, live fire or otherwise.
So you go to the range. So you shoot 25 shots. What does that tell you about what someone will do under stress? Or does it tell you that even a beginning shooter can hit the target if they take their time (something you can't do in a defensive encounter).
And then should we have them shoot at 25 feet? 15 feet? Or a ridiculous 25 yards like Nevada? Sure if someone is 25 yards away and shooting at you, you might have to shoot back as you head for cover, but it gets harder to justify an "immediate fear" at 25 yards if someone is not shooting at you.
So just what would satisfy a bureaucrat? They might come up with some standard that THEY think will satisfy some need THEY have. But it won't be good for us as instructors.
Our Utah courses are fashioned on the Utah minimum training requirements but go much further in terms of conflict resolution, situational awareness, firearm selection (my son is a Gunsmith and has an excellent presentation here) and a discussion of perceptual distortions that can take place under stress. We expect that our students can shoot and will be responsible enough to improve their shooting skills.
If our students want to take a shooting class, we offer a 1 day defensive handgun class where they can burn up 250 rounds in an IPSC style range setting and under timed conditions.
In Minnesota, our carry law does not actually call for live fire. It calls for an "actual shooting qualification exercise". Some MN instructors were creative and had been using air guns, pellet guns etc. to perform a shooting exercise where no ranges existed. This enabled people in areas without ranges or public land to qualify and get their permits.
But our MN BCA clarified their position that they wanted to see "real firearms" used in shooting qualification exercises, when they issued a December 2006 letter sent to certified organizations. If those instructors kept using pellet guns, then the organizations which certified those instructors, would loose their state certification.
Even with the MN BCA clarification, MN law does not call for a prescribed course of fire. An instructor could have a student shoot one shot and meet the MN BCA requirement and satisfy the law.
Our MN course has our Minnesota students shoot 10 rounds at 15 feet and they need to exhibit safe gun handling and loading and reloading while doing so and they of course must hit the target. This is NOT a shooting course. For to do so and to do so correctly in our opinion would take at least another four hours and 250 rounds per shooter (that's our Defensive Handgun Course).
The bottom line is that we choose the course of fire and it is our "qualification exercise and not the Governments. With the utmost respect for the fine people at the Utah BCI, I am still of the opinion that there is not one societal need that the government has ever satisfied better than the private sector. I suspect many of those folks at the BCI would actually agree with that statement.
Be careful of what you ask for. You might get it and more.
Regards,
GS