198 



o In order for shoreside processing to utilize 80,000 mt of 

 whiting, the EA/RIR indicates that an investment of $30 million 

 in additional processing capability will be necessary. 



o An untried (no test market analysis) assumption is made that 

 by expanding existing shoreside processing lines to produce 

 suriii, this higher-priced specialty product will be readily 

 accepted in the marketplace and benefits will flow to the local 

 and state economies. 



o The preferred alternative is difficult to justify because it 

 encourages economic inefficiencies and results in extreme impacts 

 in relation to benefits, 



o Given the fact that the catcher/processors have the capability 

 to process the entire 1992 harvest guideline in 8 to 10 weeks, 

 why should they be forced to subsidize the expansion of shoreside 

 processing at the expense of their own efficiency? 



o It would seem that the traditional fishery was the foreign 

 fishery followed by U.S. catcher vessels supplying foreign joint 

 venture processors; the proposed action would limit the amount of 

 fish catcher vessels can sell to the at-sea processors and 

 thereby impose inefficiencies upon them by requiring them to sell 

 their remaining catch (80,000+ mt) to shoreside processors and 

 interfere with the normal workings of free market enterprise. 



o The action regarding harvesting by catcher/processors in 1992 

 is confusing. As explained by your staff and the F/NWR talking 

 points prepared for the Jan. 7 briefing of F, F/CM, and GCF, 

 catcher/processors will be prohibited from harvesting. However, 

 pg. 18 of the EA/RIR states that "catcher/processors will be 

 allowed to participate in the fishery, but vessels must choose 

 whether to act as a catcher or as a processor (not both)." 



o Under the socioeconomic framework of the FMP, as established 

 by Aaendment 4, actions taken under this framework are to be 

 evaluated for consistency with the FMP goals and objectives. The 

 preferred alternative is clearly inconsistent with objective 13 

 ("when considering alternative management measures to resolve an 

 issue, choose the measure that best accomplishes the change with 

 the least disruption of current domestic fishing practices, 

 marketing procedures and environment"). 



o The action also raises some seriously perplexing policy 

 questions such as, should the U.S. government be involved beyond 

 the wise use of the resource and preserving the viability of the 

 fishery? 



