I am writing in to express my concerns about the new proposed training and orientaion requiremens for parents at cooperative preschools. Currently parents at cooperative preschools are given an exemption to the training hours and expected to compelte 4 hours - this draft regulations would increase those to 36(!) which would be impossible for parents of young children. Cooperative Preschools are often the most affordable preschool options in the community not to mention they have very high levels of parents engagement and involvement in child's earliest education. Please consider keeping the exemption for preschool parents so cooperative preschools don't have to change their models. 

We ask 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.

Cooperative preschools have been a valued early education option in Virginia for decades. Our school, Dulin Cooperative, was established in 1967. The traditional cooperative preschool model has many benefits for children and families including low tuition (because the parents serve as unpaid classroom aides) and deep, meaningful parental involvement in children's early education (widely acknowledged as beneficial for children's development).

In order to comply with the new regulations, cooperative preschools would have to hire aides so that parents would not be counted in staff ratios. This would would not only reduce the significance of parents' roles in the classroom, but would also raise tuition so significantly that many families could be left without any affordable preschool options. 

We respectfully urge you to implement the above changes to the proposed regulations in order to preserve the viability of traditional cooperative preschools. Thank you for your time.