While I support the new definition and consequent implications for differentiation outlined in the proposed  change in gifted regulations, I am opposed to leaving the development of the district plans to local school boards, who lack the necessary expertise to do so. Furthermore, without DOD oversight and the the peer review process, gifted services will be mediocre at best. Annual plans versus the present five year plans will prevent any actual implementation of  ideas to meet the needs of gifted learners.  Lastly, it is imperative that gifted funding be used specifically for gifted students. Please do not adopt the regulations that have been proposed.