I am writing as a parent of a current student at Overlee Cooperative Preschool and as a parent of two graduates of Overlee Cooperative Preschool in Arlington, Virginia.  I have been involved with the preschool since my daughter first attended in 2012 and have been continuously involved since.  I am requesting changes to the Proposed Standards for Licensed Child Day Centers, specifically in regard to the requirements for staff orientation and ongoing training. 

As one of the oldest Cooperative preschools in Northern Virginia,  Overlee Preschool was founded in 1945 and has been a place for parents to actively participate in their children’s early education by working directly in our classrooms as teachers’ aides. The new requirements for staff orientation (22VAC40-185-240) and ongoing training (22VAC40-185-245) would impose an undue burden on our parents by expecting them to complete 16 hours of orientation and 20 hours per year of ongoing training. Our parents volunteer on average only 50 hours a year in the classroom. Parents who are volunteering their time are simply not going to be able to complete the same orientation and training requirements as our paid classroom teachers.  

We 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. 

Parents working in classrooms at Overlee Cooperative Preschool complete all of the background checks outlined in Background Checks for Child Welfare Agencies. They work under the direct supervision of well qualified and trained classroom teachers.

Admittedly, I am a single father and my responsibilities at work have limited my recent ability to co-op at the preschool (my former spouse carries the bulk of that responsibility).  However, the changes that are being proposed would cripple my ability to co-op in the future, which I hope to do for the 2018-2019 year.  If these changes are imposed, I may need to find a new preschool to send my son, who will be in his final year at Overlee.  I can't imagine doing that after my family has had seven (7) amazing years at Overlee preschool.  In fact, I think that these changes could have a disproportionate impact on single parent households and I think the warm and caring nature of a cooperative preschool can only help and bolster a children's learning experience, particularly if they are growing up in a situation where both parents are no longer living in the same household.  I am respectfully requesting that you make the changes so that Overlee and similar cooperative preschools and the parents that are essential to the functioning of those schools are not impacted adversely by this change. 

Thank you for your consideration of this comment.

Respectfully submitted,

Haydn Richards, Esq.