Here is a tidbit you may have not realized, but the possibility does exist that the plan limits could actually drop next year. (I know, that quite a ways off, but it is food for thought)
The CPI factors have dropped so much the last few months it is a real possibility.
The 2009 limits were based on the following factors:
July 219.964
Aug 219.086
Sept 218.783

The most recent limits are well below those:
Oct 216.573
Nov 212.425

Tom,
both 401(a)(17) and 415(d) state that adjsutments will be applied "for increases in the cost-of-living". One could interpret that to mean that decrease are ignored. Opinion?

the Code says its the increase of the calendar quarter (for any given year) over the 'base period' (which was 2001) [as oppossed to 'the preceding plan year quarter'. I take that to mean you could never drop below the base period value (e.g. 40,000).
since the average base period value for the CPI was around 170, the current values still represent an increase

Are you saying a decrease would be applied as long as it never drops below the base period?
(Thats' not my view; I'm just asking yours.)

that would be my understanding from reading the code (and what I have read elsewhere)
of course, what I have read elsewhere may prejudice my reading of the code!