I request that the Proposed Amended Standards be rejected because they would seriously and negatively impact cooperative preschools.  I further request that, instead, the below changes to the proposed regulations to cooperative preschools be implemented to preserve the unique nature of these schools.

I am a parent whose child attended a beloved cooperative preschool for three years.  I cannot overemphasize how valuable the cooperative preschool experience was to our entire family.  Not only were we part of a wonderful community of parents and teachers, but my spouse and I were able to participate in the classroom on a regular basis. 

We received training from the preschool before and during the school year and felt more than prepared to act as an assistant in the classroom under the supervision of the teachers.  In fact, that training has helped me to continue my volunteering in the public school system with elementary school children.  I believe that parental engagement in a child’s education is a key factor to not only the child’s success but the success of the school.  Our cooperative preschool recognizes this and encourages such participation not only in the preschool but afterwards as well.

Parent cooperative preschools, which have existed for over 100 years, are placed in jeopardy in Virginia by the Proposed Amended Standards.  Current Standards for Licensed Child Day Centers recognize the critical role of parent volunteers in the parent cooperative preschool model by including for cooperative parents an exception requiring limited  training annually. This exception recognizes the unique role that parents hold in a cooperative preschool, as well as the intrinsic value of an early childhood education model premised on parent involvement.

The Proposed Amended Standards as drafted, however, undermine rather than support the cooperative preschool model by requiring cooperative parents to either:

(1) Complete the 36 training hours (16 orientation, 20 ongoing) required of professional staff, or 
(2) Remain in constant sight and sound supervision of a staff member.

These two alternatives fail to recognize that:

•Cooperative parents undergo the same background checks as staff;
•Cooperative parents assist professional staff in the classroom 1-2 days/month, for a total of 3-6 hours/month (thus required training hours could exceed the number of hours in class for the entire year);
•Cooperative parents serve a unique position in the classroom, where they remain under the guidance and supervision of professional staff but may at times not be in sight and sound supervision of staff.

These changes are unduly burdensome both to the cooperative parents who seek meaningful engagement in their children’s educations and to the small cooperative preschools that rely on parent engagement to survive.

To preserve the parent cooperative preschool in Virginia, the Proposed Amended Standards should be revised to allow cooperative preschool parents to work in the classroom without sight and sound supervision of a staff member provided that the parent:

(1)Satisfactorily completes the same background checks required of professional staff; and
(2)Completes a total of 4 hours of orientation and ongoing training annually.