Comment from Patricia Clay, NOAA Fisheries

1) Rather than a single "best" there are often several good and competing sets of data or even interpretations of the same data. So identifying the range of useful data seems most useful (including conflicting western science interpretations, local or traditional fisheries knowledge and anecdotal information - which is NOT the same as systematic local or traditional knowledge). This option is recommended in the 2004 National Academies of Science report "Improving the Use of the "Best Scientific Information Available" Standard in Fisheries Management." 2) Most SSCs and similar panels of the Councils cannot possibly review all the EISs and EAs that come through their Councils, so I would avoid any language requiring them to be the basis of all peer reviews. Further, existing Federal regulations spell out the maximum time that any regulation can take from inception to final publication. It would be impossible to set up a special peer review panel for each EIS to come down the pike and still meet these deadlines. And in some regions NMFS personnel provide data for and write sections of the EIS, so they cannot provide an independent review. Thus overly specific requirements are likely to cause more problems than they solve, due to regional differences.