As a parent I would like to ask for a reconsideration of 8VAC20-781-240 Areas (G): “Infants, toddlers, and twos 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.” One of the primary reasons why I chose my children’s current child development center is because it offered a mixed age school experience and plenty of outdoor play time for every child, from 3 months to 8 years of age. It allowed my children, whose ages span a five-year period, to be together at school every day, and to support and care for each other (as well as each other’s friends of various ages), out on the playground exploring the world--from the very beginning of their education. They've developed amazing collaborative, creative skills as a team, and I attribute much of their growth to all that they've learned playing together outdoors under the watchful eyes of their dedicated teachers.

It’s well known that most American children who are in school or preschool spend far less time outdoors than is good for them (particularly in terms of their eye development)—this restrictive policy would likely exacerbate matters by making administration of play spaces more challenging, likely reducing outdoor time. Alternatively it might even encourage more centers to only accept children aged 3 and above, to keep things simpler.

This would be a shame, since based on our extremely positive experience with our child development center, it seems clear that infants, toddlers, and twos can be kept safe on the playground in a mixed age environment. Although safety is essential, instead of mandating separation as a proxy for safety, I would prefer that regulators strike 8VAC20-781-240 Areas (G) and instead add a policy requirement to 8VAC20-781-40 A 4 regarding playground safety plans: policies for how, if, and when different ages may engage together on the playground; how younger children will be kept safe; and how ratios appropriate to the youngest child will be maintained for the group. Parents should then be trusted to make their own decisions about whether or not a school is a good fit for their children informed by the spaces that are available for learning and play, and the policies that are in place to govern their use.