Comment from Dr. Rebecca Lewison

I am writing to oppose the National Marine Fisheries Service's (NMFS) proposed rule regarding confidentiality of information under the Magnuson-Stevens Fishery Conservation and Management Act (MSA). Given the ramifications of this proposed rule, an extension of the public comment period from 30 days (June 22) to 90 days (August 21) is warranted and required. The proposed regulations regarding access to observer data under the MSA will only serve to hinder the development of innovative fisheries management strategies by severely curtailing the pool of scientists who have access to these data. Fisheries observer data, in particular, is critical in establishing sustainable fisheries management practices and to monitor the impacts on ocean habitats and on target and non-target species. NMFS' mandate is to protect resources held in trust for the public. Public access to fisheries data allows for independent assessments that fisheries management decisions are consistent with this mandate. Preventing non-government scientists access to observer data or only providing grossly aggregated data will undermine public trust in NMFS. It will also limit the application of best-available science to US fisheries management.