Reading through the changes made to existing licensing standards, it is disappointing to see the VA DOE growing more rigid in their regulations. I can understand the impulse to tighten the reigns when you fear for the safety of young children, but acting out of fear does not serve our children. As a passionate Early Childhood Educator, I know that my number one job is to keep the children in my care safe: physically and emotionally. But keeping them safe and wrapping them in bubble wrap are two very different things. When we lead with fear, we undermine the inherent competence of our children, we communicate to them that they cannot be trusted, that they are vessels for our superior knowledge. Ultimately, we stifle their growth. The children in my care are curious, empathetic, vibrant, growing humans and these proposed standards will diminish that. Will make them smaller. 

In 8VAC20-781-260 F. you have added a clause that reads, "without separation by a physical barrier" to the language around sight and sound supervision. If I am already expected to be able to keep each of my students in sight and sound supervision, adding more restrictive language to the standard reinforces the idea that my students up until the age of 10, cannot be trusted to keep themselves safe and return to me without me hovering right behind them. What is the purpose of this clause? What kind of environment do you imagine I am teaching in? What kind of environment will you regulate me into teaching in with this language? Children need their adults to trust that they can go out to explore, in that trust they see themselves as the competent, capable humans they are, it expands their capacity to learn and build greater self confidence. I would prefer to see a loosening of the language around sight and sound supervision, a regulation that differentiates between an infant and an eight year old. But in lieu of language that allows my students the small freedoms we know they can handle, I would petition that you strike the new language from 8VAC20-781-260 F.

The addition of standard 8VAC20-721-420 D, regarding the laundering of soft materials provided by the center, will create an undue burden on facilities. Keeping the soft materials clean that are used in our centers is obviously important. Requiring everyone to launder their: stuffed animals, cloth dolls, dress up clothes, floor pillows and removable covers once a week will have the unintended impact of removing the majority of those materials from our classrooms. The center I work at has two sets of washing machines and dryers and we are already doing multiple loads of laundry every day. It is unrealistic that we could continue to provide our children with the myriad soft spaces, cozy corners, dress up clothes, baby dolls, cushions for fort building, scarves and fabrics for exploring self expression, soft materials used for self regulation, etc. that we currently provide. Imagine for a minute how devastated our children would be to come back to school and see these materials greatly diminished. In 8VAC20-721-420 B you require that we provide "an adequate supply" of various materials, but this subsequent requirement makes that incredibly unrealistic. What is a classroom without children exploring perspective taking with a diverse closet of dress up clothes? What is Early Childhood without the construction of soft forts? My students experience so much joy, explore and do so much learning, through the use of soft materials and this standard will take that from them. I would urge you to remove this language.

The final regulation that I want to address in this comment is 8VAC20-781-610 L. The previous language said, "No child shall be allowed to eat or drink while walking around." Now the language reads, "Children shall remain seated while eating or drinking and shall not eat while riding in vehicles." This language change might seem innocuous, but I invite you to join me on the playground with my students. Our students, like most young children, play hard. When we are outside they are moving. Playing tag, working on building and sand moving projects, dancing and leaping and climbing. They need regular opportunities to re-hydrate. This language would require them to sit down for even the shortest water break. What do you think will happen? Teachers on the playground will be required to start policing our students to ensure they sit while they drink their water. After enough redirections, what I can only imagine will happen is that my students will pause to drink water less frequently. Frustrated by their teachers inane instruction to sit for the four seconds it will take them to drink water, they will simply stop to drink less. The language of the previous regulation is adequate to avoid unsafe eating and drinking situations. I beg you to strike this new language. It serves no one and will harm the children in my care. 

I believe that the VA DOE and the majority of Early Childhood Educators want to keep our children safe while providing stimulating, engaging, delightful, fulfilling environments in which children are trusted, loved and learning all the time. I really believe that some of the edits to the Standards for Licensed Child Day Centers currently proposed will diminish the environments we are able to provide for our children and undermine their own inherent competence. Please consider the voices of Educators who are in the classroom every day. We are the ones who will be on the front lines of these changes. And we can see what they spell for the quality of ECE we will be able to provide. I would love to hear from y'all.