I oppose limiting the category of Developmental Delay to the ages of 3 to6 and agree with the IDEA 2004 guidelines of continuing that category to the age of 9.  Early Childhood educators realize that the age of 6 is no magical number where children can begin to progress on level with others simply because they are 6 years of age.  It has been accepted for decades that children do not learn until they are "ready".  With many it happens early but not with all.  By the time children have completed third grade they are all beginning to level off in reading to at least perform equal to peers required to do third grade work.  Changing numbers is not going to change those facts.  We are not do any service to our children when we restrict their ability to perform at their own speed.

I oppose including any eligibility criteria for disability categories in the regulations that exceed those specifically defined in the federal regulations.  Such overreaching provisions may work to the disadvantage of children who would otherwise qualify for services as a child with a disability.