OPINION
RABINOWITZ, Justice.
James White applied to the Commercial Fisheries Entry Commission (CFEC) for a limited entry permit pursuant to the Alaska Limited Entry Act, AS 16.05.010-16.05.-
950.
The CFEC distributes entry permits for each fishery to those applicants who have the highest point totals. Points are awarded for items such as ownership of fishing gear or vessels, economic dependence on fishing, and past participation in the particular fishery.
See
AS 16.43.250(a). The burden is on the applicant to establish his or her qualification for a permit.
White failed to demonstrate to the Commission’s satisfaction that he was entitled to points for economic dependence on the fishery. As a result, his application for a permit was denied. White appealed the denial to the superior court, which affirmed the Commission’s decision. This appeal followed.
I.
James White filed a timely application for a Southeast drift gill net entry permit in April 1975. He claimed that he was entitled to six points for income dependence in 1972. Economic dependence is determined by calculating the ratio of an applicant’s “annual catch value"
to the sum of that value and all “nonfishing occupational income”
received in that year. The ratio is then converted to a percentage.
Under 20 AAC 05.630(b)(1), a drift gill net fisherman in Southeast Alaska must establish an “income dependence percentage” of
90% to
receive six economic dependence points.
White valued his 1972 catch at $1,153.00 in his application for a permit.
His nonf-ishing occupational income would thus have had to have been less than $128.11 for him to show that he was 90% dependent on fishing that year.
See
formula set out in 20 AAC 05.660(2),
supra
n. 5. Federal income tax returns appended to his application indicated that White had received $10,-330.00 in income other than wages in 1972. The CFEC wrote to White shortly after it received the application and stated that if he did not submit a federal income tax form (Schedule C) detailing the sources of each item of income, it would assume that “most” of it derived from nonfishing occupational sources, and thus deny him dependence points.
White sent the CFEC additional documentation showing that the $10,330.00 figure represented income (and losses) resulting from nonfishing as well as fishing busi
ness activity. The forms indicated that he had drawn $14,868.00 in revenue from Harbor Plumbing and Heating, a business he owned as sole proprietor, and had lost $4,538.00 in commercial fishing, yielding net business revenue in 1972 of $10,330.00.
The CFEC thereafter issued White a formal classification notice indicating that he had been awarded fifteen points and had been denied the six he claimed for 1972 income dependence. He was therefore five points short of the twenty necessary to assure him that he would be able to participate in the drift gill net fishery in Southeast Alaska. The classification notice advised him that he had a right to request an administrative hearing on the classification on or before July 24, 1975. White did not file such a request, and on February 2, 1976 he was notified that his permit application had been denied because of an inadequacy of points.
Shortly thereafter, the CFEC advised White that, pursuant to 20 AAC 05.-520(a)(1), he would be given an opportunity to submit additional evidence supporting his application. In response, White prepared and submitted affidavits bearing upon his occupational history in 1972. The affidavits showed that in 1971 he had purchased and commenced operating three vessels in the power troll and drift gill net fisheries. For several years prior to 1972, he had owned and managed Harbor Plumbing and Heating. In January 1972, he had entered into an agreement with his brother, delegating to the latter authority over the operation of the plumbing business in order to permit James to fish full-time. In their affidavits, both men asserted that James’ brother had operated the business without James’ assistance except for occasional conferences on policy and management problems. James stated that he had spent “better than 90% of [his] time in activities relating to commercial fishing, trolling and gillnetting,” and referred to the opinion of his accountant that $14,868.00 represented a fair annual return on his $100,000.00 investment in the business.
The CFEC declined to award White any additional points on the basis of these affidavits. The notification stated that he was not entitled to an administrative hearing on the decision, referring to 20 AAC 05.-520(e),
but did inform him that he could appeal the decision to the superior court. On appeal, the superior court affirmed the decision of the CFEC.
II.
White contends that the superior court erred in upholding the CFEC’s interpretation of its regulations defining “nonfishing occupational income.” Specifically, White argues that the income he received from the plumbing business was not “earned,” that it was not “received as compensation for personal services actually rendered,” and that he was not “engaged in” business within the meaning of 20 AAC 05.660(3),
supra
n. 4. He takes the position that his income from Harbor Plumbing and Heating was “investment income” and therefore
should not have been included in the calculation of his nonfishing occupational income.
The threshold question in an administrative appeal is whether the record is adequate to permit meaningful judicial review.
Fields v. Kodiak City Council,
628 P.2d 927, 932 (Alaska 1981). If it is not, and the basis of an administrative decision is unclear, it may be necessary to remand the case for preparation of a record revealing the agency’s reasoning process.
Id.
at 932;
Moore v. State,
553 P.2d 8, 36 & n. 20 (Alaska 1976). “Only by focusing on the relationship between evidence and findings, and between findings and ultimate action, can we determine whether the [agency’s] action is supported by substantial evidence.”
Fields,
628 P.2d at 933.
Although White has not specifically argued that the lack of findings by the CFEC constitutes reversible error, we consider this point because the deficiency is manifest on the record before us.
See Hewing, supra
n. 9, 512 P.2d at 898 n. 4.
The CFEC provided no reasons in support of its decision to deny White economic dependence points.
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OPINION
RABINOWITZ, Justice.
James White applied to the Commercial Fisheries Entry Commission (CFEC) for a limited entry permit pursuant to the Alaska Limited Entry Act, AS 16.05.010-16.05.-
950.
The CFEC distributes entry permits for each fishery to those applicants who have the highest point totals. Points are awarded for items such as ownership of fishing gear or vessels, economic dependence on fishing, and past participation in the particular fishery.
See
AS 16.43.250(a). The burden is on the applicant to establish his or her qualification for a permit.
White failed to demonstrate to the Commission’s satisfaction that he was entitled to points for economic dependence on the fishery. As a result, his application for a permit was denied. White appealed the denial to the superior court, which affirmed the Commission’s decision. This appeal followed.
I.
James White filed a timely application for a Southeast drift gill net entry permit in April 1975. He claimed that he was entitled to six points for income dependence in 1972. Economic dependence is determined by calculating the ratio of an applicant’s “annual catch value"
to the sum of that value and all “nonfishing occupational income”
received in that year. The ratio is then converted to a percentage.
Under 20 AAC 05.630(b)(1), a drift gill net fisherman in Southeast Alaska must establish an “income dependence percentage” of
90% to
receive six economic dependence points.
White valued his 1972 catch at $1,153.00 in his application for a permit.
His nonf-ishing occupational income would thus have had to have been less than $128.11 for him to show that he was 90% dependent on fishing that year.
See
formula set out in 20 AAC 05.660(2),
supra
n. 5. Federal income tax returns appended to his application indicated that White had received $10,-330.00 in income other than wages in 1972. The CFEC wrote to White shortly after it received the application and stated that if he did not submit a federal income tax form (Schedule C) detailing the sources of each item of income, it would assume that “most” of it derived from nonfishing occupational sources, and thus deny him dependence points.
White sent the CFEC additional documentation showing that the $10,330.00 figure represented income (and losses) resulting from nonfishing as well as fishing busi
ness activity. The forms indicated that he had drawn $14,868.00 in revenue from Harbor Plumbing and Heating, a business he owned as sole proprietor, and had lost $4,538.00 in commercial fishing, yielding net business revenue in 1972 of $10,330.00.
The CFEC thereafter issued White a formal classification notice indicating that he had been awarded fifteen points and had been denied the six he claimed for 1972 income dependence. He was therefore five points short of the twenty necessary to assure him that he would be able to participate in the drift gill net fishery in Southeast Alaska. The classification notice advised him that he had a right to request an administrative hearing on the classification on or before July 24, 1975. White did not file such a request, and on February 2, 1976 he was notified that his permit application had been denied because of an inadequacy of points.
Shortly thereafter, the CFEC advised White that, pursuant to 20 AAC 05.-520(a)(1), he would be given an opportunity to submit additional evidence supporting his application. In response, White prepared and submitted affidavits bearing upon his occupational history in 1972. The affidavits showed that in 1971 he had purchased and commenced operating three vessels in the power troll and drift gill net fisheries. For several years prior to 1972, he had owned and managed Harbor Plumbing and Heating. In January 1972, he had entered into an agreement with his brother, delegating to the latter authority over the operation of the plumbing business in order to permit James to fish full-time. In their affidavits, both men asserted that James’ brother had operated the business without James’ assistance except for occasional conferences on policy and management problems. James stated that he had spent “better than 90% of [his] time in activities relating to commercial fishing, trolling and gillnetting,” and referred to the opinion of his accountant that $14,868.00 represented a fair annual return on his $100,000.00 investment in the business.
The CFEC declined to award White any additional points on the basis of these affidavits. The notification stated that he was not entitled to an administrative hearing on the decision, referring to 20 AAC 05.-520(e),
but did inform him that he could appeal the decision to the superior court. On appeal, the superior court affirmed the decision of the CFEC.
II.
White contends that the superior court erred in upholding the CFEC’s interpretation of its regulations defining “nonfishing occupational income.” Specifically, White argues that the income he received from the plumbing business was not “earned,” that it was not “received as compensation for personal services actually rendered,” and that he was not “engaged in” business within the meaning of 20 AAC 05.660(3),
supra
n. 4. He takes the position that his income from Harbor Plumbing and Heating was “investment income” and therefore
should not have been included in the calculation of his nonfishing occupational income.
The threshold question in an administrative appeal is whether the record is adequate to permit meaningful judicial review.
Fields v. Kodiak City Council,
628 P.2d 927, 932 (Alaska 1981). If it is not, and the basis of an administrative decision is unclear, it may be necessary to remand the case for preparation of a record revealing the agency’s reasoning process.
Id.
at 932;
Moore v. State,
553 P.2d 8, 36 & n. 20 (Alaska 1976). “Only by focusing on the relationship between evidence and findings, and between findings and ultimate action, can we determine whether the [agency’s] action is supported by substantial evidence.”
Fields,
628 P.2d at 933.
Although White has not specifically argued that the lack of findings by the CFEC constitutes reversible error, we consider this point because the deficiency is manifest on the record before us.
See Hewing, supra
n. 9, 512 P.2d at 898 n. 4.
The CFEC provided no reasons in support of its decision to deny White economic dependence points. It merely told him that “no additional points may be verified toward your application referenced above based upon the evidence you have submitted.” As the CFEC itself noted in its brief before this court, “one cannot tell whether the Commission ruled adversely to White on the factual issue, or whether its ruling was based on legal grounds, i.e., its interpretation of 20 AAC 05.660(3).” It is impossible to ascertain whether the CFEC rejected White’s factual claim that he was not involved in the day-to-day operation of the plumbing business
or whether it concluded as a matter of law that income from a sole proprietorship should necessarily be deemed “nonfishing occupational income” within the meaning of 20 AAC 05.660(3). Thus, the superior court did not have the reasons for the CFEC’s decision before it and should have remanded the case for adequate findings. In not doing so, the superior court committed reversible error.
Furthermore, in light of our decision in
Forquer v. CFEC,
677 P.2d 1236 (Alaska, 1984), we hold that White is entitled to a hearing on remand. In
Forquer,
we held that 20 AAC 05.520(e),
supra
n. 8, was invalid, being inconsistent with statutory due process rights granted under AS 16.43.260(c) of the Limited Entry Act.
Forquer v. CFEC,
677 P.2d at 1243. The appellants in
Forquer,
like White, had been denied a hearing concerning the additional evidence submitted pursuant to 20 AÁC 05.520(d)(1) because they had been afforded an opportunity for a hearing in 1975.
Forquer v. CFEC,
677 P.2d at 1240. We re
jected the CFEC’s contention that the provision for a hearing after the initial classification was sufficient to satisfy the statute’s requirements, and remanded for hearings in two of the three consolidated cases. We follow the same course here.
III.
We now turn to the question of the proper scope of the hearing on remand. When the CFEC awarded White 15 points in 1975, it gave him the opportunity to appeal its denial of additional points; he did not take advantage of this opportunity. When it solicited and received new evidence from him, however, it began a new adjudication distinct from its 1975 determination.
See Ostman v. CFEC,
678 P.2d 1323 at 1328 (Alaska 1984). By its own terms, this new proceeding was limited to “evidence in support of
additional
point claims”; the wisdom of the Commission’s 1975 decision to award White 15 points was not in issue.
White, the CFEC, and the superior court have all focused on the six income dependence points White was denied, and our inability to determine how the Commission reached its decision has to do with the decision on these six points. The remand now ordered, therefore, is limited to the question of whether or not White is entitled to six points for income dependence for 1972.
During oral argument before the superi- or court, counsel for the CFEC suggested that the Commission might, in yet another proceeding, revoke points already granted in the event a remand was ordered. In an effort to forestall this possibility, White attempted to amend his prayer for relief; the superior court denied his motion. The superior court’s oral decision implies that it did not reach the issue of whether and under what circumstances the Commission might be able to revoke points it had already awarded. Instead, the superior court chose to reject White’s arguments on the merits.
We decline to issue what would in effect be a declaratory judgment on the CFEC’s power to re-examine its point awards. The record does not show to what extent White has relied on what is now an eight-year failure to re-examine the 15 points he was granted. Nor does it indicate whether or not witnesses and records relevant to that award are still available. For its part, the Commission has not cited a statute or regulation which gives it the power to do what White fears it will do. In this proceeding the Commission has never answered the question its counsel and White’s pose. Because White’s 1979 appeal did not put the 15 points awarded him in issue, that question was not properly before the superior court and it is not properly before this court. Thus, we need not answer it.
IV.
The case is REVERSED and REMANDED for proceedings consistent with this decision.