671-370-A-2- We are opposed to the regulation requiring 50 square feet per occupant in a classroom.  Our building was built in 1989 in conformance with existing building codes and local regulations and was built specifically for the purpose of serving the population that we serve. Our classrooms do not meet this new standard.  In spite of that we feel that the building serves our purposes extremely well and in fact many parents and visitors (including VDOE personnel) comment on how attractive and functional our building is. I am not aware of any comments that the classrooms are not of adequate size; to the contrary their size was specifically considered as we designed the building as one of the ways to improve classroom management. In addition much of our education requires individual and small group sessions such that in addition to the classrooms there are many small work areas. These areas are not calculated in the classroom square footage but are an available resource for when a student may need additional space.

Imposing a cookie cutter requirement limits our ability to design facilities to meet the specific needs of special populations and for special services. It is a misguided requirement that will create financial hardships for providers and could result in reduced services for students with disabilities.

We are not aware of evidence demonstrating students with disabilities will benefit from having this much available space in the classroom.  Please remove this space requirement from the regulations.