e estimated by Exxon.   DRI
          a reported that Exxon's figure has "no basis" and said
no
    supporting analysis   has never been provided     for the    Exxon
    estimate.   (Final  Socioeconomic  Impact  Analysis,  DRI, April,
    1986, p. 26.)    If this data is not available in the public
    records, it could have been generated by either Exxon or DRI.

         DNR, apparently based on DRI's work, estimates twenty-eight
,-percent (28%) of construction jobs would be filled by local
(238)residents (DEIS, p. 161). For the six hundred twenty (620)
\..operations  jobs,  DNR estimates   fifty percent   (50%)  would be
    filled by study area residents (DEIS,- p. 162).    The DEIS fails,
    .however, to analyze how the lower estimate is derived.      DRI is
    more explicit in acknowledging the basis of the estimate:

              The difficulty in both the EMC and DRI analyses of
         confidently projecting personal job preferences, job
         mobility, and the composition of skills education and
         experience in the study area work force needs to be
         frankly acknowledged.    The more conservative    (i.e.,
         lower) estimate of local resident employment in the
         construction phase is clearly more reasonable when one
         considers that all of the prospective employees from
         the study area are assumed to come from the ranks of
         the unemployed.   Under both the EMC and DRI analysis,
         direct Project jobs filled by existing study area
         residents  are  assumed   to  be  filled  by  unemployed
         persons currently residing in the study area and thug
         occasioning no new employment-related in-migration.
         It is also assumed by DRI (and implicitly in the EMC
         analysis) that EMC and EMC's construction contractor
         and related subcontractors will be predisposed to
         hiring local residents for the indicated jobs in Table
         5 and will not adhere to or pursue recruitment and
         hiring policies leading to a transference to the study
         area  of   their   existing   employees   on  assignment
         elsewhere or promoting the in-migration of job seekers
         with the requisite skills, education, and experience.
         All of these assumptions warrant careful examination
         since the skills and experience of the unemployed in
         the study area may not match those associated with the
         indicated jobs in Tables 5 and 6.     The importance of
         these assumptions relating to the Project's employment
         benefits are discussed further in Chapter III.

    (Final Socioeconomic Impact Analysis, DRI, April 1986, p. 27.)

         Therefore, it is reasonable to conclude that the DNR
   estimates contained in the DEIS are based on Exxon's assertion
   that it will "diligently pursue" local hiring practices (an



                                  'icii-ii e4iists between the local
    work force and the requirements of the Exxon contractors.     Even
    where there is a skills match, DRI states that a preferential
    hiring program would be required to give local persons
    opportunities against qualified in-migrants (Final Socioeconomic
    Impact Analysis, DRI, April 1986, p. 126).

         The DEIS has not previously analyzed the likely increase in
    local employment opportunities. While it is only common sense to
    say there will be more jobs, and more jobs means more money, the
    question is not that simple.      The DEIS must substantiate its
s estimates by something more than unemployment rates and Exxon's
(239)job qualifications. What are the estimates if a preferential
\../hiring policy is not pursued?       What has been the historical
    experience in other large projects in the United States?       What
    are the characteristics of the pool of available workers in the
    Upper Penninsula of Michigan and northern Minnesota and Wisconsin
    which might compete for these jobs?     What specific differences
    may exist if a union versus a non-union contractor is chosen?

         These questions become significant when the "Alternatives"
    section of the DEIS is considered.     DNR has no suggestions for
    employment   policies   other   than   "...   carefully   targeting
    employment announcements in terms of both geography and skills
    levels."    (DEIS, p. 240.)      For the operations period,    
DNR
    suggests the State should help bring new business to the area
    (DEIS, p. 240).     While   it does suggest the possibility of
,   employment  strategies for the local Native American communities,
(240)it does not explain why these should be necessary only for the
\./non-white communities (DEIS, p. 241-242).

         If an adequate impact analysis had been performed, the
    "Alternatives" section would be much different.      For instance,
g the promised "local preference" should be suggested as an
    alternative,  not as an assumption of impact analysis.        If a
    skills match or mismatch were identified, required training
    programs could have been considered.

         Since increased employment is consistently and publicly
    treated by Exxon as an overriding beneficial impact of its
    proposed activity, the DEIS should examine it with the eye of an
    expert so the public could be truly informed on how to get and
    keep these employment opportunities in the State. In addition,
    the job opportunity impact is truly significant and has been
    inadequately examined for purposes of aiding the later analysis
    to come pursuant to sec. 144.85, Stats., when Exxon seeks its
    mining permit.

                             B. In-Migration

         An issue closely related to employment opportunities and
    other project impacts is the number of new people coming into the



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