The proposed regulations were carefully crafted to reflect current research and best practices.  The updates to the definitions and the increases in accountability are great.  However, please keep the previous state-level approval of the local plans submitted by the school divisions to VDOE.  Having read most of the local plans for the entire state as part of my previous VDOE job,  it is very clear to me that if that supervision is lost by putting it in the hands of local school boards (who certainly have less training and knowledge in gifted education needs than the specialists at VDOE), the gifted education services across the state will quickly become seriously compromised, if not radically curtailed.  Also, the funding wording should also remain in the regulations, even though the funding is provided in the SOQ.  Gifted education is as important for gifted students as special education is for special education students.  For the sake of our students, please provide as much support as possible to keep their programs strong.