I want to advocate against the proposed standard "8VAC20-781-230 G. Infants and toddlers shall have a separate outdoor play area or shall not occupy the outdoor play area at the same time as preschool and school-age children." I appreciate that the language has changed since a previous draft and two-year-olds can be outside with either infants and toddlers or preschool and school-age children. However, as a teacher I find this proposal to be unnecessarily restrictive, with likely unintended consequences.

At our school, while there are separate outdoor times for 0-3 year olds and 3-8 year olds, there is often overlap during the transitional time. That overlap allows siblings to play together for a little bit, for friends who recently moved up to spend some time with those who haven't yet, and it allows teachers to transition slower and calmer when they aren't mandated to be in a specific place at a specific time. Or, sometimes one or two infants and their teacher will join a group of older students eating lunch outside. When there are multiple age groups in one space, the ratio for the youngest child must be followed for everyone, so all children should be properly supervised during mixed-age outdoor play. Additionally, it is entirely possible to create an outdoor space that is both safe for infants and engaging for older children, as evidenced by our school.

I think that this proposed standard will lead to children getting less time outside, because teachers will fear violating licensing and avoid that overlap, and it will also lead to children spending more time in transitions and waiting which is not developmentally appropriate. I encourage you to get rid of this proposed standard entirely.