Achievement is not the only piece, it is just a required piece. I'm not balking b/c my kid has been excluded just b/c I have an issue with achievement being required. (Dd does have a GT id and advanced class placment.) You can get in with a 95th percentile+ grade level achievement score plus an "aptitude" test (they'll take IQ or CogAT here) or a teacher behavioral recommendation. Thus, if you've got behavioral characteristics and IQ, that's not going to do it, but if you have behavioral characteristics and top 5% achievement per grade level, you're in.
I imagine that they'd consider above level achievement as well although dd's EXPLORE scores didn't seem to be looked at in her ID even though math and science more than qualified.
A gifted ID also does not guarantee access to advanced coursework or any service anymore, which is concerning to me. The same FAQ states, "Advanced classes require evidence of high achievement. Gifted identification looks at scores in the area of achievement, aptitude and behaviors in the 95th percentile. While sometimes these scores overlap, an advanced class might have different criteria than gifted identification. Because advanced classes have a faster pace and require a student to go deeper into the content, certain skills and characteristics (such as work habits, attendance, past performance, and motivation) are considered before enrollment in an advanced course."
Again, maybe an advanced class isn't the best fit for certain underachieving and 2E kids, but what else are you going to do for them? In dd10's school, there are a lot of high achieving kids in the accelerated math and reading classes (about 20% of the 5th graders are in GT reading) where there are some 2E kids with verbal IQ scores in the 99th+ who are in the regular reading class with nothing extra being offered b/c they aren't high achieving. That really doesn't rub me right.