Following are just a few of the areas of the concern I have with the proposed revisions.

1.    Current regulations call for 5-year Local Plans for the Education of the Gifted while the proposed regulations call for annual plans. I believe having plans developed on an annual basis is not sound educational practice. Instead a five?year cycle is preferred. A school division then would be able to develop long?term goals, implement changes, and evaluate progress before updating its plan.

2.    Current regulations require DOE approval and a peer review of local plans. The proposed change only requires local school board approval. I favor having plans submitted to the Department of Education for approval to ensure compliance to requirements of identification and programming across the Commonwealth. The present system of peer review is an accountability measure as well as a teaching and learning process for school divisions.

 3.    Current regulations assure that available funds are to "be used to support only those activities identified in the school division's plan". This section is being removed in the proposed revisions. I want a reinstatement of the gifted funding segment which states that funding administered by the DOE for the education of gifted students be used only to support those activities identified in the school division's plan as approved by the Board of Education.

4.     8VAC20-40-20. Definitions —The proposed revisions define specific academic aptitudes as students with aptitudes in selected academic areas: English/ language arts, mathematics, history/social science, and science. I believe the word and will result in many divisions no longer offering identification in this area as it is nearly impossible to identify specific aptitudes in history/social science, and science in the early elementary grades. Changing the "and" in this definition to an "or" would promote what is considered current best practice in the field of gifted education