As parents of a gifted child and as concerned members of our community, we believe the proposed changes will reduce the quality and level of gifted services currently available.  Our specific concerns and recommendations are listed below.

1.  Do not change the wording from "or" to "and" throughout these regulations.  While the intent to require gifted services in more subjects and to a potentially broader group of students is laudable, making this requirement without ensuring adequate funding for the additional services will only degrade the level of services available.  Deplorable as it may be, financial resources for education are scarce in many localities.  Local governments are beset by numerous competing financial requirements, as are the taxpayers who fund those requirements.  The change to "and" instead of "or" in this proposal, without the addition of adequate resources to fund these expanded services, will result in existing resources being stretched even thinner.  The quality of gifted services currently available within our schools will be reduced. 

2.  Do not change the approving agency from DOE to local school boards.  Local school board approval of plans vice state Department of Education approval also puts our gifted services at risk.  School board members generally do not have appropriate background, skills, and experience to evaluate gifted education programs.  This responsibility should remain with the state DOE, whose personnel are knowledgeable and have the specialized experience to evaluate education plans for gifted students. 

3.  Do not require annual plans vice longer-term plans.  The schedule for reviewing and approving plans should not be changed to an annual basis.  If implemented, this will require administrators, teachers, and local gifted boards to focus on short-term goals and increase administrative costs.  Again, without additional resources to fund increased requirements, something must be eliminated - and that something will likely be long-range, productive planning to provide gifted services to our children. 

4.  Do not remove the statement requiring DOE funds for the education of gifted students to be used only for those purposes.  Funding determined by the state DOE to be used for the education of gifted students should be available to those students, and not redirected by local governments to other needs.  Especially in these times of increasing economic difficulties, local governments will more aggressively pursue funding in various areas to support competing needs.  If not specifically identified only for the education of gifted students, some local governments may interpret state DOE funds to be available for other purposes they determine. 

Thank you for this opportunity to comment on these proposed changes.