I am contacting you to voice my opposition to several of the proposals to amend current Virginia childcare center standards, as the proposed standards will create an administrative and financial burden with little or no benefit to the child, parents, childcare centers, or the VA Department of Social Services.

1) Group Size pg 22 Table 1 Maximum Group Size Requirements:  VA childcare centers have already been subject to age group size reductions in the past, which resulted in reduced acessibility; abrupt, unplanned moves or transitions to a different childcare facility; increased tuition or childcare costs; and other negative consequences for VA families and their children.  By proposing the requirement to triple the ratio for pre-K age groups, this will only cause hardship for VA families, their children, and childcare centers without the option to expand their facility in a densely populated, high-rent area.  Economic, child development and community statistics should be carefully examined before enacting this amended standard that will result in little or no benefit to the child. 

2) Director Qualifications, pg 13.  The current standards are sufficient enough.  Adding additional educational and certification requirements in lieu of decades of experience has been proven to reduce the pool of talented applicants with demonstrated skillsets in nuturing and guiding young children in a positive, caring and safe environment.  Adding additional degree requirements does not equate to better resuts. 

3) Teacher Age Restrictions, pg 15.  High-school students under the age of 18 have been a critical part in childcare center's success for decades.  These students are vetted, pass background checks, participate in school-sponsored job programs at childcare centers, and are usually interested in pursuing a college degree in child education or other related programs.   They are attentive, caring and responsible young adults capable of caring for younger children in  structured, accountable, and reportable environments.  The authors of the proposed amendments must forget the amount of responsibility placed on them at a much younger age (13-15) as neighborhood after-school or evening babysitters.  The authors are underestimating the capabilities young adults possess and their level of responsibility.  This proposed amendment is extremely overarching, a heavy regulatory mistake, misguided, and robs both the young adult of experience for their college application and resume, and the benefits younger children receive when under the care of a responsible and attentive young adult.  For one example, young adults as caregivers are much more likely to engage in physical play, creatively suggest or motivate role-playing and games, and they take great interest in the lives and developing minds of the young children they care for, oftentimes coming to visit the childcare centers after their employment ends to visit the children they cared for.  By reqiuring a licensed or full-time member of the staff to supervise the High-school students under 18 years of age, the effect will most likely be reduced employment opportunities for this demographic and increased childcare or tuition costs to keep a senior employee on the clock for longer hours throughout each school day.

All of these proposed amendments to the regulations will: increase childcare costs in NoVA, one of the most expensive regions in the country for such costs; reduce the availability or access to facilities when there is already a low/no availability issue in our region; and, most importantly, have little or no benefit to the families and children contrary to the reasoning provided by the authors of the proposed amendments to the current standards.