Comment on FR Doc # N/A

I am an independent researcher commenting in the public interest. I am not requesting that the agency be prevented from disposing of records it no longer needs; I am asking NARA to clarify the schedule's scope and to ensure that records necessary for oversight and accountability are preserved. 1.) Access and audit records appear unaddressed. The schedule describes the CDW as a repository that "captures and migrates data from multiple IRS production systems," consolidating tax-return, enforcement, and compliance data — including taxpayers' personal and business identifiers — for query and analysis. The appraisal memorandum states that the individual source systems are "separately scheduled," but neither the schedule nor the appraisal addresses the records that document access to and use of the CDW itself: user-access provisioning (the BEARS/PUMAS requests the schedule references), query logs, and records of bulk extractions. Please confirm whether such access, query, and extraction records are covered by this schedule or scheduled under a separate authority, and identify that authority. 2.) The accountability record should be preserved even where the underlying data is temporary. Because the CDW consolidates sensitive taxpayer data drawn from many systems into a single analytical environment, the records that show who accessed that environment, when, and what was extracted have independent value for oversight, regardless of whether the bulk research data is ultimately destroyed. I respectfully ask NARA to ensure that access-provenance and audit records associated with the CDW are scheduled for a retention period adequate to support inspector-general, congressional, and judicial oversight, and are not treated as part of a destroy-eligible "research data" category. This concern is heightened by the documented, well-publicized expansion of access to federal data systems during 2025–2026 and the attendant public questions about who has accessed consolidated stores of citizens' data. 3.) The retention extension warrants attention to safeguards. Item 0001 extends retention of CDW research data from 10 years to 50–70 years. Retaining a consolidated store of taxpayer personal information for multiple decades increases the privacy and security stakes of the system. To the extent NARA approves the longer retention, I ask that the appraisal record reflect that access controls and audit logging for the CDW are commensurate with that extended retention, and that the access/audit records described above are preserved for at least as long as the data they govern. I appreciate NARA's consideration and ask that these points be addressed in the Consolidated Reply for this schedule.