Hello esteemed board members,

A big DITTO from me regarding all comments noting the undue hardship the proposed rule may place on cooperative preschools in Virginia.  I support and applaud the suggested remedy, removing the language "who are not considered staff" from 22VAC40-185-245 paragraph C.  I also support explicit exemptions for parent participants at cooperative preschools to the orientation and ongoing training requirements imposed by 22VAC40-185-240 and 22VAC40-185-245.

Currently, parent participants at cooperative preschools are counted as staff for purposes of meeting the required staff-to-child ratio, but such parent participants need complete no more than four hours of training per year.  The proposed language keeps the minimum training requirement, but appears inadvertently to remove parent participants from the staff-to-child ratio calculation by explicitly describing them as "not considered staff".  Following this description, cooperative preschools will be forced to either a) significantly raise tuition to hire additional staff in order to maintain the ratio or b) unrealistically require parent participants to officially become staff and to complete all staff requirements.  Many parents will be unable to accommodate either option.  Either outcome, therefore, would deprive children of the high-quality, affordable early education that cooperative preschools provide, force many cooperative preschools to close, and possibly destroy the cooperative preschool education model in Virginia.

My family's school, Annandale Cooperative Preschool, was founded 70 years ago, just after World War II.  It is a place for parents to actively participate in their children's education by working directly in classrooms as teachers' aides.  Parents working in classrooms complete all of the background checks outlined in Background Checks for Child Welfare Agencies (22VAC40-191).  They work under the direct supervision of well-qualified classroom teachers in an award-winning, NAEYC-accredited program.  Like other cooperative preschools, if the proposed rule goes into effect unchanged, our school may be forced to close its doors or to radically change its approach.

Our personal experiences with cooperative education have been wholly positive.  Our children grow every day they are in attendance.  We as a family are brought closer to other member families through shared experiences in the classrooms, while at the same time we gain new appreciation for the rigors and difficulties of teaching.  It is also a lot of fun.  In my opinion, successful early education cannot follow a purely consumer model; parent involvement is necessary.  Cooperative preschools like ours are one highly effective way of fostering engagement and developing partnerships among teachers and parents.

Cooperative preschools represent unique and rewarding opportunities for parents to participate in their children's early education at an affordable cost.  They encourage parent involvement in the first stages of early education, and the benefits last many years.  They follow a unique, valuable model that should not be jeopardized without cause.  Please correct the language of the proposed rule so that these worthy educational programs are not put at risk.

Thank you sincerely!

Orin Wilcox