saira Smith

Hello, thank you for reading my comment.  My son was a student at Rock Spring Cooperative Preschool and now I am employed there.

On behalf of Rock Spring Cooperative Preschool I am requesting changes to the Proposed Standards for Licensed Child Day Centers, specifically in regard to the requirements for staff orientation and ongoing training.

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.

We 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.

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

Thank you,