200 



o A critical inconsistency in the analysis is the estlnate of 

 shoresidQ processing capacity for 1992: pg. 43 of the Final 

 Report (dated Dec. 91) estimates it at 40 - 60,000 mt, whereas 

 pg. 8 of the EA/RIR (also dated Dec. 91) says it is over 80,000 

 rot. Only the EA/RIR includes the preferred alternative /7 

 allocating 80,000 mt for shoreside processing. The EA/RIR should 

 have analyzed all of the alternatives based on the most recent 

 estimate by NMFS of shoreside processing. Shoreside processing 

 amounted to only 20,000 »t in 1991, a year vhen much more was 

 available to this sector. 



o This analysis lacks an objective presentation of shoreside vs. 

 at-sea processing benefits and costs. It is skewed to benefit 

 shoreside processors at the expense of the catcher/processors as 

 though shoreside processors were the traditional processing 

 activity in this fishery. Shoreside processors have historically 

 processed small quantities of whiting (8,000 int or less 

 representing a small fraction of the overall harvest) until 1991 

 when they utilized 20,000 ret (representing 9 percent of the 

 harvest) . Catcher/processors entered the fishery in 1990 and 

 caught and processed about 5,000 mt and in 1991 they harvested 

 117,000 mt and motherships processed 80,000 at (almost 200,000 mt 

 was processed at sea in 1991 by domestic processors). 



o The analysis does not distinguish between all catcher vessels 

 that have the ability to bring the net on board for delivery to 

 the shoreside processors, and those that do not. Furthermore, 

 the EA/RIR does not analyze the impact of the action based on 

 catcher vessel characteristics. 



o Table 8 (pgs. 37 - 39, Final Report) shows that the 1991 

 allocation has the greatest income benefit; however, product 

 values for shoreside processors appear to be based upon highly 

 speculative assumptions that markets will exist for expanded 

 products); speculative estimates of shoreside impacts form the 

 basis for expansion of the shoreside processing industry in an 

 amount of $30 million at the expense of existing capacity at sea. 



o The EA/RIR does not analyze whether requiring 

 catcher/processors to act as motherships introduces costs. It is 

 implausible to conclude that catcher/processors can buy whiting 

 more cheaply than they could catch whiting, plus inefficiency is 

 presupposed because the catcher/processor vessels are not 

 operating optimally or as they were designed (to harvest as well 

 as process) . 



o Fishing for alternative species is not an option for 

 catcher/processors because everything is calibrated for Pacific 

 whiting; this opportunity cost should be factored into the 

 analysis. Furthermore, we are unaware of surpluses available for 

 other species that could be harvested by- this sector. 



