The education in Virginia is exceptional & the educators put in their valuable time to provide services to the Gifted students. The revision to current regulations of the gifted program in Virginia might be necessary but the revision should not take away the accountability by each county to VA DOE in gifted education, standardization of the implemented programs across state, & foremost, a regulatory body monitoring the plans proposed by all counties. There is no need to stress the importance of ‘effective regulation’ in times like these.

8 VAC 20-40-60 A - This is clearly a deregulatory step with far reaching negative consequences over long term. Approval of long term plans by VA DOE should be maintained. Also the ‘annual’ plan will not allow sufficient time for proper planning & implementation including necessary training & alignment of resources.

8 VAC 20-40-60 B - The new proposed regulations need each county in Virginia to come up with their education plan for the gifted every year approve, implement, & review it.

The potential pit-falls of this proposed change -

* The county committee which comes up with the plan can’t also be the approver & then be the reviewer.

* Each county will spend money, resources, valuable time of educators each year in discussions, voting, & review, to come up with a new plan.

*All these should rather be utilized to implement & effectively advance the plan which already exists.

8 VAC 20-40-70 - The new proposed regulation removes reference to funding. It is critical to keep the paragraph about the funding for the gifted programs requiring it to be exclusively used for such services.

Being parents of two gifted children, we have experienced gifted programs in multiple states & can’t over emphasize the value of the gifted program in Virginia. We would like these programs to be continued & enhanced to adequately equip the Virginia students to meet the challenges of finding their niche in the global community.