8VAC20-781-210, inspection and report of water supply and sewage is appropriate prior to initial licensure.  It is burdensome and unnecessary to require annually.

8VAC20-781-230, (D)3, wording should allow use of string/laces for beading, weaving and other preschool age-appropriate activities under the supervision of an adult.  Wording should allow preschool and kindergarten aged children to wear shoes with laces. Preschool children can safely and should be taught to tie their shoes in preschool.  

8VAC20-781-240, (G) 2 year old children should be allowed to be on a playground with preschool aged children.  What happens when some children in the 2 year old class have birthdays and turn 3?  Is that center in violation if they don't immediately move that child to an older group?  That isn't quality care; keeping classroom communities together is important. Getting outside is also so incredibly important to children's development; in urban areas, providing outdoor space and getting children outdoors regularly is already extremely challenging.  Forcing centers who serve 2  yr olds and up to  limit time outdoors for each group due to never allowing those 2 yr old children outside with other groups is a greater harm than being outdoors with older children.  If properly supervised, that can be a wonderful mixed age group experience for all.  At a minimum, please consider changing the wording to children younger than 2 1/2 years.  That would be consistent with other requirements that are different for toddlers and under 2 1/2 vs. preschool requirements.