85 



began working for LGL on Mnrch 0, 1991. V^BBi^ said that at 

 the time he was working at the Council, he did not know that LCL 

 would contract with PSPA. 



One of MHHBBK first projects was analyzing the econo mic i' 



aspects of the Council's SEIS for LGL's PSPA contract, ^■■■■^-/'y /( 

 conducted some background research for LGL on groundfish during /J,\,^^ 

 March 1991. ^■■■■■^■told the reporting agent that he attended . ■' ^ 

 public Council meetings in March and April concerning the 

 groundfish industry and attended a lecture at NPFMC. He said he 

 occasionally asked NPFMC staff questions on how they arrived at 

 certain conclusions in the SEIS. He denied that he was given 

 preferential treatment or obtained any non-public information 

 from any Council employee. The NPFMC released the I/O SEIS for 

 public review at its April 1991 meeting. 



Clarence Pautzke, Execu tive Director of the NPFMC, told the _ fl)'C 



reporting agent that .iH^BBK- was not present at any non-public 



staff meetings at which the I/O issue was discussed, and that ■ -j\i C 



■■■■■^tewas not granted acces s to any non-pub lic or pro prietary l,^^',^ ^ 

 i nforma tion on the I/O issue, ii^— 1— ^a nd ^M^fcfc . 'A 



■MMBi^ilb. NPFMC economists, said they met with •{■■■■fcto (~J/iC 

 discuss the economic model the Council used to analyze the I/O 

 issue prior t o the Council's April 1991 meeting. They too both (-i\(r 

 said •■i^^^ neither asked for nor received information from the I )\^ 

 Council that was not available t o the pub lic. Neither Pautzke, /-,-\/^ ) 



i^niil^K^ nor .-•■■■■IB' said that1^^Bli^«ttempted to influence/ I }(}- - 

 their work on the I/O issue. 



:oDpleted his critique of the economic analysis and 

 conclusions of the SEIS in June 1991, after the SEIS was 

 published and before the Council vote on the I/O issue, 

 ^■^■■^an independent consultant from British Columbia, Canada, 

 critiqued the biological portion of the SEIS for LGL. 



In 1991 LGL provided consulting services on contracts totaling 

 ^■IBIii^B^' The PSPA paid LGL about $29,000 for the critique of • 

 the SEIS. PSPA was one of ^^active LGL clients for that year. 

 Investigation did not disclose that there were any contracts 

 either between LGL and NPFMC or between PSPA and NPFMC. 





(4) 



Conclusion 



.worked on the I/O issue first as a member of the(7J(_L.' 

 I then for a consulting company. He did not 



Council staff and then for a consulting company 

 violate 18 U.S.C, § 207 by working for the consulting company 

 because the I/O issue was not a particular matter involving 

 specific parties. Further, we did not substantiate that''^ 

 represented LGL in an attempt to influence the Council on a 

 natter in which he participated while working fo r the Coun cil. 

 This investigation did not uncover" evidence that flHlHMPeither 



