The new training requirements (16 hours of orientation training, 20 hours of annual training) being proposed for Licensed Child Day Centers are detrimental to the cooperative preschool model.  Parent co-opers of preschoolers will not realistically be able to complete these hours and it will in effect doom cooperative preschools.  I respectfully ask that you keep the total training hours (orientation + annual) at 4 hours for cooperative preschool parents.  Please remove the language "who are not considered staff" from section 22VAC40-185-245C, and include an exception for cooperative preschool parents in section 22VAC40-185-240.

As a parent of cooperative preschoolers, I can't say enough good things about the value of parents regularly participating in the early education setting.  Please keep the cooperative preschool model viable in Virginia.

Thank you,

Elisabeth Bracken