I strongly oppose the proposed length of stay guidelines adopted by the Board of Juvenile Justice. I am a youth defender and have been so for the last 17 years. The proposed guidelines were submitted to the Board of Juvenile Justice and adopted without any concomitant impact study. The proposed guidelines contradict current research and evidence-based policies on youth incarceration by dramatically increasing length of stay. The proposed guidelines also fail to account for the costs of such a dramatic increase in DJJ population and the required personnel and facilities. The guidelines that were adopted and implemented in 2015 are effective at achieving the goal of youth court which is, foremost, rehabilitation of youth. An impact study to justify the proposed length of stay increases should be required before they can be adopted.