Gifted staff and clients across the state are most concerned about the proposed regulations.  Many jurisdictions risk losing ground at local, state, and national levels.  Issues with alignment to federal guidelines, restrictions on the ability to adjust needs for testing in the identification process, and conducting referrals for screening when schools are not in session do not assist local districts in meeting the needs of our gifted populations.  Funding issues and five-year plans currently in existence could be jeopardized as well.  I have advocated for gifted students at various levels for twenty of my thirty years in Loudoun County Public Schools and still am shocked that we have to fight daily battles with administrators and faculty who don't understand an identified need for special services.

Please consider the following requests:

* Local school division plans should be developed on a five-year basis, not annually.

* Plans should be submitted to the Department of Education for approval to ensure compliance across the Commonwealth.

* Please reinstate the gifted funding guidelines in the proposal to ensure that monies are spent only on activities identified in school divisions' plans as approved by the Board of Education.

Respectfully, Brenda Bengtson