Please review and consider the general changes placed bfore early childhood education programs/daycares but more specifically, cooperative preschools. Cooperative preschools involve families in the early childhood education of the children, a significant part of a child's foundation in learning. Parents, as assistants, with such a role in early childhood education have the opportunity to learn how significant these early learning years are.  Families also learn how to support such development at home. Much research has shown how family involvement in a child's education is key to student success. The cooperative preschool model is a true model of how to foster such involvement. My experience at Dulin Cooperative Preschool has shown me how this works in practice, as well as keeping my whole family engaged in our children's early learing years. 

The proposed new training requirements for parents who volunteer at cooperative preschools are so burdensome that they will doom the traditional cooperative preschool model. It is not feasible to ask parents of young children to undergo 16 hours of orientation training and 20 hours of annual training.

I request 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. 

In addition, the requirement for substitute teachers (who are considered lead teachers and not currently differentiated in the current or proposed standards) to maintain the same number of training hours (20-36 in the prosposed standards), puts an undue burdern on the substitutes, who may only work for 12-15 hours in a given school year. I respectfully ask that training hours requirements within the standards for substitute teachers be seperate from lead teachers and be required on a sliding scale, according to hours worked. 

Cooperative preschools have been a valued early education option in Virginia for decades. Dulin Cooperative Preschool, was established in 1967. 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 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. 

As an early childhood educator, lead teacher in a cooperative preschool, ECE professor, and, most importantly mother of two young children, I can't emphasize enough that the requested changes to the proposed regulations are made in order to preserve the viability of the traditional cooperative preschool. 

Please feel free to contact me for further conversation.