199 



Adequac y of Analysis 



Summary - This Is an incomplete analysis that fails to justify 

 the preferred alternative. 



o Quantitative analysis is admittedly lacking and th« 

 qualitative analysis that is included is made on assumptions that 

 are highly questionable, and conclusions are largely speculative. 



o The Council's recommended action is identified as alternative 

 /7 in the EA/RIR (pg. 4), which is supposed to be an analytical 

 docuaent supporting the Council's "Final Report on Proposed 1992 

 Managenent Measures to Allocate Pacific Whiting"; however, it is 

 not identified, discussed, or analyzed in the Final Report 

 (the EA/RIR should be an appendix to the Final Report not vice 

 versa) . 



o The analysis in the Final Report and the EA/RIR is primarily 

 one of ihcome distribution and does not analyze costs/benefits 

 (no net benefit conclusion); while the analysis seeks to 

 establish a social basis for the action, it fails to establish 

 either a social or an econonic basis. 



o The analysis shows lots of redistribution of income to 

 individuals and local and state economies, but does not help 

 gauge one alternative vs. another. 



o The analysis fails to identify costs and econonic and social 

 benefits to the nation as a whole. Accordingly, the action is 

 not consistent with the FMP's Objective 4 ("attempt to achieve 

 the greatest possible net economic benefit to the nation from the 

 managed fisheries"). 



o The Input/Output model is not useful in selecting the best 

 alternative on a cost/benefit basis; I.O. model does show a 

 shifting of benefits from the Seattle area to Oregon; however, 

 this is obvious without the model because the catcher/processors 

 are based in Seattle and most shoreside processors are located in 

 Oregon. 



o Negative impacts on catcher/processors are largely ignored. 



o The best available information is not used (see Final Report, 

 pg. 18, lines 6-8) . 



There is no analysis of impacts on fisheries in adjacent areas 

 as required by the Magnuson Act. 



o The Final Report and the EA/RIR contain internal 

 inconsistencies (e.g., regarding the income distribution effects 

 on catcher/processor employees - local to Seattle or accruing to 

 Washington and Oregon economies?) 



