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The table below shows comments received at this web site about the following rule:

Outdoor Programs
DEL is anticipating rule making to implement a legislatively-mandated pilot project to explore the possibility of licensing out-door, nature-based early learning and child care programs. During the pilot, DEL will also explore options for developing a quality rating and improvement system.

DEL uses these comments, and other input during the rule making process, to help us write and adopt the permanent rules. For proposed rules only, DEL will prepare one response to all of the comments received, in what is called a “concise explanatory statement” required by RCW 34.05.325. The department sends the concise explanatory statement to everyone who commented or testified on the proposed rule, and to anyone who asks for it.

Agree/Disagree: Agree

Comment: My children have attended outdoor, nature-based preschool and have benefited immensely. The state would be well served to recognize the value of these programs and embrace them as valid programs. I believe that would go a long way towards making these type of programs accessible to more families. I think it is disheartening that most of the "Disagree" comments are from whiny indoor childcare providers who feel aggrieved at the hands of DEL. They are trying to be the tail wagging the dog and should not be the basis for rulemaking going forward. Outdoor schools are awesome and should be embraced. And to the comment that claims this "would be extremely diffullt because of so many inclement days": when it rains, my kids put on a coat are are just fine.

Date Submitted: 6/30/2018 8:28:40 PM

Agree/Disagree: Agree

Comment: Providing nature-based preschools with the support and oversight of DEL is what's best for early learners and their families.

Date Submitted: 6/30/2018 2:55:04 PM

Agree/Disagree: Disagree

Comment: We are childcare providers NOT family therapist. Next year our teachers will all be required to have there degrees in psychotherapy...This is so far outside the scope of what the WAC's were created for to begin with..remember its about the health and safety of children. Please stop with this non-sense!

Date Submitted: 6/27/2018 11:13:13 PM

Agree/Disagree: Disagree

Comment: I support outdoor programs but DEL has their hands full and the current WAC's are sufficient

Date Submitted: 6/27/2018 10:23:08 PM

Agree/Disagree: Agree

Comment: Exploring an outdoor Early Learning pilot is something good to pursue.

Date Submitted: 6/27/2018 8:25:19 PM

Agree/Disagree: Agree

Comment: Children need more time outside and this sounds like a great idea. However, with the current WAC's there is no way a quality program could be created that meets the needs of the children. Maybe revision of the WAC's to allow the proper equipment to meet children's needs.

Date Submitted: 6/27/2018 7:33:18 PM

Agree/Disagree: Agree

Comment: Licensed nature schools are common in other states and countries. These programs adhere to same standards as Head Start and ECEAP. A pilot program is welcome!

Date Submitted: 6/25/2018 4:18:10 PM

Agree/Disagree: Disagree

Comment: Creating a separate quality rating system for these types of programs is crucial because they will not be able to meet the current ERS requirements if most of their time is spent outdoors.

Date Submitted: 6/25/2018 2:19:28 PM

Agree/Disagree: Agree

Comment: I Love the idea of an outdoor preschool program, but the state is so restrictive all ready on outdoor anything I do not see how this program as Great as it could be can withstand the States Rules and Regulations. Is so restrictive that it can't work.

Date Submitted: 6/25/2018 9:07:35 AM

Agree/Disagree: Neutral

Comment: This Proposal sounds good but would be extremely difficult in Washington Stater because of so many inclement days and not realistic.

Date Submitted: 6/19/2018 5:07:30 PM

Agree/Disagree: Disagree

Comment: Its very important to have outdoor playtime... children learn more through play in any given opportunity inside or outside... My main concern is it should not be mandated to providers AS every home is different and center is different. same rule and policy can not be apply and mandated for home and center- I hope DEL consider this point for ALL rule making

Date Submitted: 6/13/2018 1:56:58 PM

Agree/Disagree: Neutral

Comment: Del is a joke. It’s not necessary to police us. The parents have that right and responsibility

Date Submitted: 6/13/2018 10:01:58 AM

Agree/Disagree: Disagree

Comment: There are so many rules and restrictions that a licensed childcare facility has to abide by how is it even remotely possible for these rules to be overlooked or enforced by a licencor.

Date Submitted: 6/12/2018 3:00:22 PM

Agree/Disagree: Neutral

Comment: I run an outdoor preschool program, and I don’t see any way to do this fairly. There’s no way to loosen the regulations enough to make sense for an outdoor program, and there is no way to make it fair to the traditional programs who worked so hard to meet the strict WAC guidelines.

Date Submitted: 6/12/2018 1:08:14 PM

Agree/Disagree: Agree

Comment: As a member of the pilot program, I am so grateful that the DEL is licensing outdoor preschools in the state of Washington. More than ever before, kids are staying inside and/or living in areas with limited access to the natural world. Richard Louv, author of Last Child in the Woods, shows how this disconnection from nature is contributing to the rapidly rising rates of childhood depression, anxiety, ADHD, and obesity, and additionally is a factor in juvenile delinquency. Louv indicates that direct exposure to nature is essential for healthy childhood development and for the physical and emotional health of children and adults. Environment-based educational programs have shown to enhance children's problem-solving, critical thinking, and decision-making skills. Studies validate our observations that children who spend time in nature with trusted mentors have more curiosity, self motivation and become more successful learners. By licensing outdoor preschools in the state of Washington we are increasing the accessibility of these programs to a wider audience who may not otherwise have been able to take advantage of the opportunities available. Licensing will help our families be able to access subsidies and tuition assistance available to other preschools in the state, helping to make outdoor preschools affordable for more people. In addition, it has allowed us as an organization to take a deeper look into how we can strengthen our already comprehensive policies and procedures to keep children, staff and families safe and protected in the outdoor environment.

Date Submitted: 6/12/2018 1:02:17 PM

Agree/Disagree: Agree

Comment: Definitely, this should have a quality rating for it by itself.

Date Submitted: 6/12/2018 11:47:24 AM

Agree/Disagree: Disagree

Comment: Licensors have cited both family homes and center programs for years for such tiny things as "dust in a dustpan." How could outdoor spaces even be licensed, much less to a comparable level of oppressive and obsessive enforcement? Will there be waivers of WAC and will all programs be able to access those same waivers? If the purpose is to create more ECEAP and WCCC openings, it would be better accomplished by reducing the administrative burdens and increased costs caused by over regulation.

Date Submitted: 6/9/2018 11:48:59 AM

Agree/Disagree: Disagree

Comment: I recently opened a licensed childcare center and it was an extremely large investment financially. I had to adjust my whole building and add tons of sinks (a separate craft sink, FIVE separate sinks in the kitchen!) in order to meet the stringent wac standards and then it had to sit vacant for THREE MONTHS while I paid rent and interest on my investment before the DEL would allow me to operate (to allow them time to inspect and approve). I find it extremely frustrating that the outdoor preschools don’t have to go through these processes and be held to the same strict standards. I do not think they should be permitted.

Date Submitted: 6/8/2018 2:40:30 PM

Agree/Disagree: Neutral

Comment: I believe that licensing outdoor preschools is vital for the health of all of children. When the outdoor preschools can prove that children are doing better than children on playgrounds that are unnaturally built than perhaps the DEL can relax the WAC for the rest of the children. All children are being denied to the opportunity of risk to jump, climb, swing and play that is needed for strong brain development. I just hope the licensing does not destroy the wonderful , natural chances to run, jump and children deserve to enjoy.

Date Submitted: 6/8/2018 2:08:41 PM

Agree/Disagree: Neutral

Comment: I believe if you are offering a school like setting of any sort it should be licensed and regulated. This is not only fair but it is for the safety of all children

Date Submitted: 6/8/2018 1:36:00 PM

Agree/Disagree: Neutral

Comment: Nature based programs are at increasing risk. Children do not have enough exposure to the food growing/production cycle. We are becoming urbanized to the detriment of our sensory processing development and natural awareness and global conservation.

Date Submitted: 6/8/2018 1:13:20 PM

Agree/Disagree: Disagree

Comment: I intentionally stopped the practice of allowing my daycare children to brush their teeth at my home daycare when the new tooth-brushing regulations came into play. (I have been licensed 19 years). It is a dis-service to the children, but there is literally not enough time in the morning to go through the entire procedure (with me supervising each child) in the mornings. Some children come to daycare very early and do not have time to brush at home. I do not find it unreasonable for a school-age child to go into the bathroom alone and brush their teeth and rinse the sink. Please relax the regulations.

Date Submitted: 6/6/2018 9:00:26 PM

Agree/Disagree: Disagree

Comment: IF the WAC's are truly designed for the safety and well-being of the child, how can you set different regulations for different programs? This just shows me that the rules are apparently made to be broken and they do not hold the value in which you enforce them. It really gives me perspective.

Date Submitted: 6/6/2018 8:54:23 PM

Agree/Disagree: Disagree

Comment: I DO NOT BELIEVE WE NEED FULL TIIME OUTDOOR DAYCARES SMALL CHILDREN NEED PLAY INSIDE AND OUTSIDE LEARNING BOMNDING AND FRIENDSHIP IN EARLY YEARS AND NOT BEING PUSHED INTO ENVIRONMENTAL AFGENDAS THEY ARE JUST CHILDREN AND PLAY INSIDE AND OUT CQAN BE INCLUDED IN REGULAR DAY CARES

Date Submitted: 6/5/2018 8:38:02 AM

Agree/Disagree: Disagree

Comment: I believe that DEL needs to find another business to monitor. They are becoming Nazi like in the means of providing safe environments for children. When businesses have to shut down because of WACs that literally choke an operation, perhaps its time to monitor the monitors. enough is enough.

Date Submitted: 5/30/2018 7:08:37 PM

Agree/Disagree: Neutral

Comment: IF A CENTER OR LARGER DAY CARE WOULD LIKE TO Have AN OUTDOOR EARLY LEARNING ENVIRONMENTAL TYPE PROGRAM IT WOULD BE UP TO THE PARENTS TO DECIDE IF THATS WHERE THEY WANT TO PLACE THE CHILD MOST HOME DAY CARES DO NOT HAVE THAT TYPE OF STRUCTURES AND LEARNIING BUT TO MAKE RULES ON WHAT TYPE OF DIRT AND SO ON CAN BE TAUGHT TAKES AWAY TRUE ENVIRONMENT AS THAT DOES NOT MAKE IT NATURAL IN MY OPINION

Date Submitted: 5/26/2018 8:01:45 AM

Agree/Disagree: Agree

Comment: I believe outdoor schools should be regulated for the health and safety of the children.

Date Submitted: 5/25/2018 7:20:47 AM

Agree/Disagree: Neutral

Comment: I love the idea of outdoor preschools, but struggle with the fact that traditional centers are held to incredibly high standards for safety and cleaning, while outdoor schools seemingly do not have to abide by the same rules. Kids need to be outside more and there is a ton of learning that can be done in parks and public spaces. Please consider lessening some of the rules for traditional licensed centers if outdoor centers also become licensed.

Date Submitted: 5/24/2018 4:11:27 PM

Agree/Disagree: Agree

Comment: I do believe that children should be out side and to learn about nature, but I do believe that this should be left to the center on weather or not this happens. Some centers have the funding and the room for this others don't. This should be a extra for the students and the parents. The parents decide on where their children attend daycare and they should be the person to decide if the outside area is good for their child.

Date Submitted: 5/23/2018 2:41:03 AM

Agree/Disagree: Agree

Comment: When decisions about children are made, I would advocate for what is best for children. Today, the average 3-5 year old is exposed to 4.5 hours of screen time per day. By the teen years, this doubles to 9 hours. Overuse of screens is linked to decreases in executive function (attention, memory, self-regulation) and increases in aggression, anxiety, depression and obesity. Interestingly, nature play spaces offer a natural remedy and are a proven prescription to increase child development and well-being across multiple development domains — intellectual, emotional, social, spiritual and physical (Kellert, 2005). Perhaps there is a way to pilot, first, to learn more about how this could be good for children, and, find ways to implement with equality, risk assessment and WAC's in mind?

Date Submitted: 5/22/2018 7:10:27 PM

Agree/Disagree: Neutral

Comment: 70-300-0016-1 This states that we need to submit notification of inactive status two business days prior to closure. This will not be possible if something unexpected is the cause of the closure. There needs to be some wording that states, unless emergent or unexpected closure occurs. 170-300-0105 If the Director doesn't meet minimum qualifications this states the program must employ an assistant with the minimum qualifications. Does this mean that while Directors are working toward ECE Certification, the program needs to hire an Assistant Director with the qualifications? That would be detrimental to a program that doesn't have the budget for an Assistant Director. 170-300-0220-1.A I am confused by the wording "Meals and snack cannot be more than 3 hours apart". If we start at 9:00am serve breakfast at 9:15am and our program ends at 12:00pm, does this mean we will have to serve a snack?

Date Submitted: 5/22/2018 3:02:19 PM

Agree/Disagree: Disagree

Comment: I do believe that children should be out side and to learn about nature, but I do believe that this should be left to the center on weather or not this happens. Some centers have the funding and the room for this others don't. This should be a extra for the students and the parents. The parents decide on where their children attend daycare and they should be the person to decide if the outside area is good for their child.

Date Submitted: 5/22/2018 12:23:03 PM

Agree/Disagree: Agree

Comment: Outdoor and nature based play can be very valuable. I would like DEL to consider having programs in the pilot that are currently licensed but that have outdoor programming as a large majority of their day. For example, they are outside for 4 hours in the morning and 4 hours in the afternoon, but have access to running water, toilets and refrigeration for food storage. Perhaps there is a place for children to rest or nap. This would require a "shelter" of some sort with these amenities that is available nearby. Some programs run this way in the summer months and information about this could be valuable as DEL designs an outdoor preschool WAC.

Date Submitted: 5/21/2018 8:57:57 AM

Agree/Disagree: Agree

Comment: Outdoor programs should follow standards that will ensure health, safety, and learning opportunities for children. These programs should be licensed so that they too are monitored by the department in order to ensure quality. Of course, the rules will look different in regards to the physical licensed space, ratios, equipment, etc., however, the most important aspect is that these programs will be monitored, assessed for quality through QRIS, and allow equal access by children who receive subsidy payments.

Date Submitted: 5/20/2018 12:59:44 PM

Agree/Disagree: Disagree

Comment: This is the whole problem with everything from the highest level to the lowest. Different set of standards or requirement even though they are providing the same service. Why hold Center, Home Based and now Outdoor to all separate set of rules and regulations? It's enough already that EA and DEL have different sets of standards when inspecting a location. WHY can't everyone be on the same page? WHY can't we all pull from the same set of WAC's. I understand there may be a few differences on each but it shouldn't be that far off.

Date Submitted: 5/18/2018 3:45:03 PM

Agree/Disagree: Disagree

Comment: I think Outdoor programs receiving grants or federal funding should be licensed and following the same licensing requirements of ratio ( even a lower ration based on the risky play) as all other preschool programs. If they can not comply with ALL licensing compliance than they should not be licensed. IF they are not licensed then they should be required to be certified at least and follow health department safety regulations (ie. bathrooms and running water and emergency communication and transportation devices on site.)

Date Submitted: 5/18/2018 3:41:47 PM

Agree/Disagree: Disagree

Comment: Outdoor preschool. Yes, there are some across the USA. children love being out in nature and the elements however, what about the dirt. If center's are required to have organic, pesticide free dirt for children to play with or garden with then I would think those outdoor playgrounds would need to follow the SAME WACs as centers. Licensors don't particularly like climbing structures due to potential accidents, so children can't climb trees? Think you all need to re-think this concept. If they can play in "REAL DIRT", then so should children centers and day homes.

Date Submitted: 5/18/2018 3:12:15 PM

Agree/Disagree: Disagree

Comment: Licensed provider in home and centers get the shaft again by DEL! These outdoor childcare groups need to follow the same rules every one else is required to we don't get to pick and chose wacs to follow. What about the new weighted wacs we get fined but they can have o clearance fall zones and operated over 4 hours. IF they want to be a preschool operate under 4 hours or follow the same WACS!

Date Submitted: 5/18/2018 3:05:58 PM

Agree/Disagree: Neutral

Comment: learning happens everywhere BUT if there are strict rules and WAC on usage of any area limits learning.... Please think broad spectrum on learning with minimum limitations on home childcare provider---

Date Submitted: 5/18/2018 2:00:05 PM

Agree/Disagree: Disagree

Comment: Outdoor preschool / childcare should follow the same wac law

Date Submitted: 5/16/2018 5:01:44 AM

Agree/Disagree: Disagree

Comment: Outdoor environments provide different risks than indoor environments, HOWEVER, safety rules should be the same. Does this mean we need to loosen our in-home and center rules to allow for more natural play? Will outdoor programs be taught risk-assessment? How is the trained risk-assessment of an outdoor teacher any different than that of an indoor teacher? There are obvious rules that will need to be different (bathroom protocol being a big example), but other things should be aligned with in-home and center rules. A trying example here is fall zones. Outdoor programs encourage tree climbing and truly experiencing nature... and teach children proper risk assessment. Will the children in other programs be denied these same lessons due to over-regulation?

Date Submitted: 5/15/2018 7:40:21 PM

Agree/Disagree: Neutral

Comment: If DEL does move ahead with this pilot I would hope that any future licensing plans for outdoor preschools would be inline with traditional child care licensing WACs. I'm not sure how outdoor schools could be licensed with the same standards, but it seems that they must. Licensed Centers are held to strict standards and outdoor programs should be held to the same.

Date Submitted: 5/15/2018 2:14:41 PM

Agree/Disagree: Neutral

Comment: I love the idea of allowing outdoor preschools and encouraging them. I do believe that all licensed facilities, whether center, in-home, or outdoor, should follow the same set of rules. This will allow in-home and center facilities to use some aspects of outdoor facilities in their program. I think current rules makes it incredibly hard for normal centers to encourage outdoor learning and risk taking with current rules, and should be able to encourage this without becoming a completely outdoor center.

Date Submitted: 5/15/2018 8:47:36 AM

Agree/Disagree: Disagree

Comment: I think it's a horrible idea to let these outside daycares not have to follow the same wacs as indoors homes or centers, We have strict rules on environment and now the weighted wacs please don't allow licensed outoors They can be a preschool and operate under 4 hours if they want but not a licensed daycare.

Date Submitted: 4/30/2018 1:45:37 PM

Agree/Disagree: Disagree

Comment: If outdoor programs are to be licensed, they should have to meet all of the same regulations as other types of licensed programs. It is unfair to allow them to bypass facilities, health and safety, equipment, etc. requirements. There are so many rules that would not be possible to implement in an outdoor program and it is unfair for them to be allowed to operate with a simpler, easier, less expensive set of rules.

Date Submitted: 4/20/2018 2:59:28 PM

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