I have serious concerns about the fiscal impact of the proposed Gifted Regulation on my locality. and the instructional impact on our gifted students. I ask you not to pass them in their current form.   There are many problems with the proposed regulations but I will name only those that concern us the most.  I am concerned with dropping the use of nationally standardized test scores as a requirement.  This is like lowering a standard.  Are we afraid of where our students are scoring? Will our school systems continue to fund the cost of the tests  if they are no longer required/recommended?   I am also concerned with calling for a one year, rather than a 5 year plan.  This is a step back from best practice to worst practices in instructional planning.  Every other body I know of is requiring long-range planning of its leaders.   These short-range plans will impact the vision of the locality and our ability to bring about continuous improvement.  Locally we are very concerned with  the change suggested that would require identification within 60 business days.  This will require additional staff to be hired or for staff currently instructing students to be pulled from the classroom and be required to work for 11 or 12 months and deal with nothing but assessment.  We cannot afford it.   Such a requirement needs to be backed up with additional state funds for personnel.  The last concern that I will mention at this time is my concern that local plans will no longer be reviewed by state department.  The state's review held all of the localities to a minimum standard of excellence.  The proposed regulations removes the expert review and opens the window  for neglect of the gifted. Please reconsider these proposed regulations on behalf of gifted students in Prince George and across the Commonwealth.