While I appreciate and support the proposed standards attempt to align with federal standards to keep children  safe and offer affordable, quality care, they do not take into consideration the unique educational model of Cooperative Preschools, and should be adjusted to do so or risk eliminating the cooperative model completely. I am a former parent of two children who thrived in a cooperative preschool, and a current employee at the same cooperative preschool. I belived so stongly in the cooperative model, that I stayed after my own chidren graduated. Cooperative Preschools work and produce better prepared children and stronger educated parents who are involved in thier child's education for years to come. Parents in cooperative preschools may become PTA leaders and school board leaders of the future because they are accustomed to taking an active role in thier child's education. Please save this model! 

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. 

I respectfully urge you to implement the above changes to the proposed regulations in order to preserve the viability of traditional cooperative preschools. I also request an extension on any planned implementation of these proposed standards for at least a year, so that all facilities may have time to budget and plan accordingly, if they are able to continue providing child care services. 

Respectfully, 

Jennifer Keefer, Dulin Cooperative Preschool, Administrative Director