The regulations as proposed fail to address the disproportionate representation of Culturally & Linguistically Diverse gifted students in Virginia's gifted programs. in the past, many Virginia localities have worked  to better serve all of its population including gifted learners who may come from low socio-economic backgrounds and those who originate from culturally and linguistically diverse ethnic groups. However, numerous disproportionalities continue to exist...many African American and Hispanic Students who have high potential are not being served by gifted programs across the state. To revise these regulations without attention to the needs of all students is inappropriate. The new regulations will not encourage the use of multiple criteria which is a notable  'best practice' , they may well discourage divisions from using this research-based practice which allows multiple identification tools to be used to assess  students' gifted potential. All students in Virginia deserve fair and equitable access to state & locally funded gifted services. We appeal to you to review and revise the regulations to ensure that a minimum of 4 identification criteria are used (one of which should be a nontraditional, non-biased assessment tool) and that all districts will be required to serve culturally and linguistically gifted students that are represented among their general population. Further, we recommend that reporting procedures be implemented to ensure that all divisions continue to annually report demographic data and specify procedures utilized to ensure equitable access to local, regional & state gifted services.