The Department of Education has failed to provide any evidence to justify these proposed changes or to support the advantages cited in the Proposed Regulation Agency Background Document. The existence of this research is referred to many times in the Document, but no specifics are provided. 

(1) The Purpose statement says: "The proposed regulations reflect the relevant findings from research regarding effective program options, appropriate curricular designs and instructional strategies, and the significance of teacher professional development in providing appropriate instruction for gifted students." Where are these relevant findings?

(2) Issues statement #6 "The proposed regulations establish expectations that school boards, and not the Department of Education, will approve local plans that are in compliance with the regulations." This is cited as an advantage but no explanation is provide as to why this is advantageous to the public, the agency, or the Commonwealth.  In fact, not one of the other five "advantages" listed provides a basis for the perceived advantage. Further, disadvantages are not even entertained.

Even the Action Summary in the Virginia Regulatory Town Hall cites this mysterious research review: "The proposed revisions will allow the Virginia Board of Education to review contemporary reseach and best practices in the field that have occurred in the last decade..." Again, no specific citations from that research review have been included as justificaiton for the proposed changes.

Furthermore, where is the Department of Education oversight of local plans? The Department of Education needs to maintain its role in insuring that divisions are in compliance and not to serve merely as a repository for local gifted plans which seems to be the idea behind "each school division shall submit an annual report to the Department of Education in a format prescribed by the department." How is the elimination of this oversight role by DOE an advantage to families? Cite the research behind this decision please. You are leaving accountability of gifted programs in the hands of non-educators, the local school boards.

You have not made a compelling and research-cited case for this changes.  Do not make any changes in the current regulations regarding gifted education programs.