I would like you to address a highly problematic aspect of the Proposed Standards for Licensed Child Day Centers, specifically in regard to the requirements for staff orientation and ongoing training. I am the mother of a preschooler currently enrolled in a cooperative program (Rock Spring Cooperative School in Arlington, VA) and the new training requirements for parent-volunteers are so burdensome that they will doom the traditional cooperative preschool model. This saddens me tremendously for two reasons. First, the cooperative model has been the perfect setting for both my children’s early education, and I could not imagine them in a different kind of school. Second, as a parent, I have the right to decide which type of education my child needs. This requirement effectively voids this right because of what it will do to the cooperative model.

It is simply not feasible to ask parents of young children to undergo 16 hours of orientation training and 20 hours of annual training, and the fact that you do not propose a different number for cooperative schools troubles me because it suggests that, either, a) you are unsympathetic to the cooperative model, or b) you are unaware that they exist at all.

I would ask that the total number of training hours (both orientation and ongoing, collectively) for cooperative preschool parents be limited to the current 4 hours. Please remove the language "who are not considered staff" from section 22VAC40-185-245C describing the required annual training for cooperative preschool parents. Please include an exception for cooperative preschool parents in the new orientation training section 22VAC40-185-240.

Cooperative preschools have been a valued early education option in Virginia for decades. Our school, Rock Spring Cooperative Preschool, was established in 1943. The traditional cooperative preschool model has many benefits for children and families including low tuition (because the parents serve as unpaid classroom aides) and deep, meaningful parental involvement in children's early education (widely acknowledged as beneficial for children's development).

In order to comply with the new regulations, cooperative preschools would have to hire aides so that parents would not be counted in staff ratios. This would not only reduce the significance of parents' roles in the classroom but would also raise tuition so significantly that many families could be left without any affordable preschool options.

I respectfully urge you to implement the above changes to the proposed regulations in order to preserve the viability of traditional cooperative preschools.