flooding the market with product). Or it can refer to the cost of harvesting and processing, which can also be affected by management.

National Standard 8 requires determining whether “fishing communities” are affected (there are some guidelines, but there is considerable debate about what constitutes a fishing community within the intent of MSFCMA); assessing what is required for their sustained participation in the fisheries and minimizing the economic effects on communities to be consistent with the conservation mandates of National Standard 1; and carrying out economic and social impact analyses. In addition to the MSFCMA, economic impact analyses are required by the Regulatory Flexibility Act (RFA) and have been a focus of litigation and have important social and economic implications.

NMFS has taken important steps to address the issue of economic and other social-science research, but much remains to be done. NMFS has developed guidelines for economic analysis of fishery management actions and has recently revised its guidelines for social-impact assessment. Those guidelines specify the types of questions that should be answered (How will income and employment be affected? How will the costs and benefits of an action be distributed among the various stakeholders?) and the types of analyses that are necessary to answer them. If the guidelines were followed in every instance, litigation resulting from noncompliance with the RFA probably would be reduced drastically. However, NMFS and the council system do not have the data or the personnel necessary to complete all such required studies.

NMFS has adopted a plan to improve social-science capability in the fisheries management system. The plan calls for 96 new social science positions in the next few years, with a balance of experts to be spread throughout the regions and at NMFS headquarters and hiring that will take place in stages. The first round of searches is currently under way, and some appointments have been made. Until these positions are filled, NMFS’s ability to do the social-science research and monitoring necessary to accomplish its goals will be seriously compromised.

NMFS has recently instituted a policy change that will require the regional councils to complete the documentation to comply with NEPA, RFA, and other statutory or executive order requirements for analysis of management alternatives before a final vote on a FMP. In the past, councils and NMFS have been criticized for focusing on one management alternative (the council’s preferred alternative) and then doing the NEPA and RFA analysis to justify the selected option after electing to adopt it; this violates



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