140 1 STATE OF FLORIDA DIVISION OF ADMINISTRATIVE HEARINGS 2 SUGAR CANE GROWERS COOPERATIVE OF ) 3 FLORIDA, INC., ROTH FARMS, INC., ) and WEDGWORTH FARMS, INC., ) 4 and ) FLORIDA SUGAR CANE LEAGUE, INC., ) 5 UNITED STATES SUGAR CORPORATION, ) and NEW HOPE SOUTH, INC., ) 6 and ) FLORIDA FRUIT AND VEGETABLE ) 7 ASSOCIATION, LEWIS POPE FARMS, ) W.E. SCHLECHTER & SONS, INC., and ) CASE NOs. 92-3038 8 HUNDLEY FARMS, INC., ) 92-3039 Petitioners, ) 9 v. ) SOUTH FLORIDA WATER MANAGEMENT ) 10 DISTRICT, ) Respondent, ) 11 and ) MICCOSUKEE TRIBE OF INDIANS OF ) 12 FLORIDA, the UNITED STATES OF ) AMERICA, FLORIDA DEPARTMENT ) 13 OF ENVIRONMENTAL REGULATION, and ) FLORIDA WILDLIFE FEDERATION, ) 14 Intervenors. ) ------------------------------------) 15 CONTINUED DEPOSITION OF: GRACE JOHNS, Ph.D. 16 TAKEN: Pursuant to Notice Instance 17 of Sugar Cane Growers Cooperative of Florida, Inc., 18 Roth Farms, Inc., and Wedgworth Farms, Inc., 19 DATE: March 30, 1993 20 TIME: Commencing at 9:30 a.m. 21 PLACE: AA1 Parliamentary Reporting 22 3511 West Commercial Boulevard Ft. Lauderdale, Florida 23 BEFORE: ELLEN N. COHEN, RPR 24 Stenographic Court Reporter and Notary Public - State 25 of Florida at Large 141 1 APPEARANCES 2 HOPPING BOYD GREEN & SAMS 123 South Calhoun Street 3 Post Office Box 6526 Tallahassee, Florida 32314 4 BY: DONNA STINSON, ESQ. 5 -and- CAROLYN S. RAEPPLE, ESQ. 6 Attorney for Petitioners Sugar Cane 7 Growers Cooperative of Florida, Inc., Roth Farms, Inc., and Wedgworth Farms, Inc. 8 9 PEEPLES, EARL & BLANK One Biscayne Tower 10 Suite 3636 Two South Biscayne Boulevard 11 Miami, Florida 33131 12 BY: RICK J. BURGESS, ESQ. 13 Attorney for Petitioners Florida Sugar Cane League, Inc., United States Sugar 14 Corporation, and New Hope South, Inc. 15 POPHAM, HAIK, SCHNOBRICH & KAUFMAN 16 4000 International Place 100 S.E. Second Street 17 Miami, Florida 33131 18 BY: PAUL L. NETTLETON, ESQ. 19 Attorneys for the Respondent 20 UNITED STATES DEPARTMENT OF JUSTICE 21 ENVIRONMENT & NATURAL RESOURCES DIVISION GENERAL LITIGATION SECTION 22 P.O. Box 663 Washington, D.C. 20044-0663 23 BY: KEITH E. SAXE, ESQ. 24 Attorneys for Intervenor United States of 25 America 142 1 A P P E A R A N C E S (Continued) 2 -and- 3 UNITED STATES ATTORNEYS OFFICE 155 Miami Avenue - Suite 600 4 Miami, Florida 33130 5 BY: ROBERT ROSENBERG, ESQ., Assistant U.S. Attorney 6 Attorneys for Intervenor United States of 7 America 8 ALSO PRESENT: RONALD T. LUKE J.D., Ph.D. 9 ANDREW BERNSTEIN 10 11 INDEX PAGE 12 DIRECT EXAMINATION BY MS. STINSON..........143 13 14 EXHIBITS PAGE 15 JOHNS' EXHIBIT No. 16....................217 17....................226 16 18-A..................228 18-B................,.228 17 19....................252 o0o 18 19 20 21 22 23 24 25 143 1 GRACE JOHNS, Ph.D. 2 the Deponent herein, having been previously duly sworn, was 3 examined and testified further as follows: 4 DIRECT EXAMINATION 5 BY MS. STINSON: (Continued) 6 Q. On Exhibit 7 from yesterday -- 7 A. Yes. 8 Q. -- I had asked you about some comments in paragraph 9 3 that refer to the SWIM Plan but we didn't have the SWIM 10 Plan before us. Today I've got a SWIM Plan, let me see if 11 we can tie this together. Let me show you a copy of the 12 SWIM Plan. 13 The letter states, Exhibit 7 states that "In my 14 humble opinion, without the elimination of problems a 15 through e, the Everglades will not be saved. If we take 16 this approach, the public will no doubt try to compare the 17 benefits we estimate with economic impacts (costs) of the 18 Settlement Agreement. This is not appropriate unless we 19 also consider the costs of solving problems a, b, d and e." 20 Are those letters, a through e, those that appear 21 on page ii of the SWIM Plan? 22 A. Yes. 23 Q. By this paragraph, are you stating that the SWIM 24 Plan does not address or will not correct problems a, b, d 25 and e, or that's your understanding, that what the SWIM 144 1 Plan addresses is essentially c? 2 MR. NETTLETON: Object to the form. 3 BY THE WITNESS: 4 A. I don't remember what the rest of this document 5 talks about. I was simply referring to a, b, d and e as 6 written on this page. 7 BY MS. STINSON: 8 Q. Have you in your analysis, have you considered the 9 impact or the costs of solving problems a, b, d or e? 10 A. B might be included. Isn't that -- that, I 11 believe, is the cost of hydroperiod restoration, so in that 12 sense it's included. 13 Q. What part of hydroperiod restoration have you -- 14 A. The part -- part of the cost of the STAs that we 15 looked at and their impacts were included in hydroperiod 16 restoration. 17 Q. Is that an engineering portion of the STAs 18 themselves? 19 A. Yes. 20 Q. So you are not referring to other hydroperiod 21 changes in the whole canal system? 22 A. It's whatever hydroperiod changes that the District 23 has included in their estimates of the cost of constructing 24 the STAs and hydroperiod restoration. That's what they 25 have indicated that it would cost. 145 1 Q. But I want to make real clear that that hydroperiod 2 restoration refers only to whatever hydroperiod restoration 3 is included in the STAs themselves; is that correct? 4 A. I don't recall if it's specific to just the STAs or 5 any other type of hydroperiod restoration. 6 Q. Do you recall any other hydroperiod restoration 7 that is addressed by the SWIM Plan? 8 A. I don't remember. 9 Q. What about b -- 10 I'm sorry, what letter was that? 11 A. B. 12 Q. That was b. 13 What is a, does the SWIM Plan address problem a or 14 did your analysis address the costs of solving problem a? 15 MR. NETTLETON: Object to the form. 16 BY THE WITNESS: 17 A. To the extent that the act and the Settlement 18 Agreement relates to a, then it was considered. 19 BY MS. STINSON: 20 Q. Would you read A into the record just so when we 21 read it we'll be clear. 22 A. "Fragmentation of the Everglades, resulting in the 23 loss of connections between the central Everglades and 24 adjacent transitional wetlands. Everglades wildlife 25 communities and sustainability of the ecosystem may be 146 1 impaired by this separation and isolation." 2 Q. Does anything in the SWIM Plan, to your knowledge, 3 address that problem? 4 A. I don't remember, I'd have to look through the SWIM 5 Plan. 6 Q. Is there anything other than the STAs proposed by 7 the SWIM Plan that your analysis considers? 8 A. Our analysis primarily considered c. And maybe 9 perhaps to some extent a, b, d and e. But at the time I 10 wrote this letter, I was just making a statement that you 11 needed to consider, in my opinion, a through e. 12 Q. And in your opinion, the problems a through e are 13 not purported to be totally resolved by the SWIM Plan? 14 MR. NETTLETON: Object to the form. 15 BY THE WITNESS: 16 A. No, I don't -- I don't know. 17 BY MS. STINSON: 18 Q. Does your economic impact analysis consider the 19 costs and effects of solving problems a through e? 20 A. They consider the impact of the Marjorie Stoneman 21 Douglas Everglades Restoration Act and the Settlement 22 Agreement between the United States and the South Florida 23 Water Management District. 24 Q. Do you know whether those two things solve problems 25 a through e? 147 1 MR. NETTLETON: Object to the form. 2 BY THE WITNESS: 3 A. Could you restate the question, I don't quite 4 understand the question. 5 BY MS. STINSON: 6 Q. Do you know whether the Marjorie Stoneman Douglas 7 Act and the Settlement Agreement purport to resolve all of 8 the problems a through e? 9 MR. NETTLETON: Same objection. 10 BY THE WITNESS: 11 A. My understanding is they don't resolve all of them 12 but I don't know which ones -- maybe some they resolve -- 13 some of them are resolved and some of them aren't, I don't 14 know. 15 BY MS. STINSON: 16 Q. Do you have, just to make this easier, a copy of 17 your contract completion report with you we can use? 18 A. No, I don't, I didn't bring it. 19 Q. In the report that you have done, the contract 20 completion report for the 10-year study, did you do any 21 analysis of the impact of changes in land ownership? 22 A. No. 23 Q. Besides sales, job earnings and employment, does 24 the report consider any other measures of economic impact? 25 A. Lost income to the mills and the growers. 148 1 Q. Anything else? 2 A. Not that I can recall at the moment. 3 Q. Are you generally familiar with the literature on 4 economic impact assessments? 5 A. Yes. 6 Q. Are there other measures of economic impact 7 considered in the literature that should be addressed in an 8 economic impact assessment? 9 MR. NETTLETON: Object to the form. 10 BY THE WITNESS: 11 A. What we've looked at are the most common. Do you 12 have anything in mind? 13 BY MS. STINSON: 14 Q. Well, are there -- 15 No. 16 Are there other measures that are also often 17 considered in impact assessments other than sales, job 18 earnings, employment and then, as you indicated, lost 19 income to the mills and growers, are there additional 20 community impacts? 21 A. Well, there are tax impacts, local tax impacts. 22 Now that you mention it, we did look at the 23 property tax impacts and the state income tax impacts, but 24 we specifically looked at agricultural land in the EAA. We 25 didn't look at land that was not agricultural in the EAA. 149 1 Q. Are you saying then you didn't look -- 2 Well, explain that to me, why didn't you look at 3 non-agricultural land? 4 A. We were told not to. Our assignment was to look at 5 the primary economic activities in the EAA, which are 6 agriculture and the related services. 7 Q. Have you looked at the impact of the, looking for a 8 shorthand way for saying the Marjorie Stoneman Douglas Act 9 and the Settlement Agreement, on the EAA alone as apart 10 from Palm Beach County? 11 MR. NETTLETON: Object to the form. 12 BY THE WITNESS: 13 A. We looked at the economic impact to the EAA and 14 Palm Beach County. We did not separate the EAA from Palm 15 Beach County in reporting our job losses. 16 BY MS. STINSON: 17 Q. Why did you choose to look at the geographic area 18 of Palm Beach County as opposed to geographic area of the 19 EAA in looking at the impact assessment? 20 A. Because the input/output multipliers that we used 21 were specific to the county, Palm Beach County. That's my 22 best recollection of why at this time. 23 Q. You indicate in the report that potential 24 mitigation responses, including shifting production to 25 areas within or outside the EAA, presently idle or in other 150 1 crops. 2 Have you done any analysis to determine the 3 availability of such land? 4 MR. NETTLETON: Object to the form. 5 BY THE WITNESS: 6 A. We do know that there is land on which you can grow 7 sugar cane that isn't currently in sugar cane production. 8 BY MS. STINSON: 9 Q. Within or without the EAA? 10 A. Mostly without the EAA, but there may be some 11 acreage within the EAA as well. 12 Q. How do you know that? 13 A. The Palm Beach County property appraiser's office 14 land use records indicate there is land in other uses other 15 than sugar cane and that land could be -- some of that land 16 could be converted to sugar cane production. 17 Q. What leads you to believe that it could be 18 converted, say outside the EAA, let's talk about that 19 first? 20 A. Well, there's lots of sand land that is in cattle 21 production and some of that -- and also pasture. Some of 22 that land could be converted. 23 Q. Have you analyzed the feasibility of doing that 24 from a cost or practicality standpoint? 25 A. No. 151 1 We have not looked at how much it would cost to 2 convert sand land into sugar cane land. 3 Q. Have you looked at whether that would be feasible 4 given the location of the mills? 5 A. Yes, preliminarily. 6 It appears that transporting the cane from the sand 7 lands to the mills would not be a deterrent to growing cane 8 on that land. 9 Q. And what led you to that conclusion, what analysis 10 did you do? 11 A. It was a very, just a simple analysis, mostly 12 distance. The distance from those potential lands to the 13 mills is about comparable to the distance that they are 14 currently shipping from and to. 15 Q. You indicate in your report that the area supported 16 15,600 jobs in 1990. Are these actual jobs or FTEs? 17 MR. NETTLETON: Object to the form. 18 Q. Do you know? 19 A. Those are the summation of the jobs reported by the 20 businesses to Dun & Bradstreet during their surveys. 21 Q. Again, are we talking about FTEs or jobs, do you 22 know? 23 A. Those would be -- 24 MR. NETTLETON: Form. 25 BY THE WITNESS: 152 1 A. (Continuing) What do you mean by "jobs"? 2 BY MS. STINSON: 3 Q. Well, a job can be a part-time job which is not a 4 whole FTE, right, or a seasonal job which is not a whole 5 FTE? 6 MR. SAXE: Object to the form. 7 BY THE WITNESS: 8 A. When they answered the question they were talking 9 about the number of people working at their enterprise at 10 the time the question was answered. 11 BY MS. STINSON: 12 Q. And the source for this number is a survey by Dun & 13 Bradstreet; is that correct? 14 A. Yes. 15 Q. Do you know whether this includes the jobs of the 16 seasonal farm workers who harvested the vegetables, rice 17 and sod? 18 A. It does not include the H2A workers or the seasonal 19 farm workers who harvest vegetables, rice and sod. 20 Q. On the next page ES-2, you indicate that conversion 21 of the land to STAs is expected to result in an estimated 22 loss of 830 full-time equivalent jobs in sugar cane 23 milling. 24 How many of those jobs are located within the EAA 25 itself? 153 1 A. Most of them -- a good portion of those jobs would 2 be located in the EAA. The rest of them would be located 3 in other areas of Palm Beach County. 4 Q. Do you have any estimate of what number would be 5 lost in the EAA, itself? 6 A. No. 7 Q. Do you know, have you analyzed what type of workers 8 would be required for the STA construction? 9 A. Yes. 10 Q. What type? 11 A. Well, there's a list of them. You have engineers, 12 equipment operators, truck drivers, pipefitters, 13 carpenters, cement finishers, electricians and construction 14 assistants. 15 Q. Do you know whether there is a labor force that 16 includes those types of skills within the EAA? 17 A. Well, you probably have equipment operators, truck 18 drivers, carpenters. You may have some cement finishers, 19 electricians and construction assistants. 20 Q. Have you analyzed the labor force within the EAA to 21 determine the availability of those trades? 22 A. Not specifically, but we do have an understanding 23 of what type of employees would be needed to grow and 24 process sugar cane, sod and vegetables and transport them. 25 Q. On ES-4, page ES-4 at the top, you indicate 154 1 "Employment from BMPs is expected to increase by about 172 2 FTEs." 3 What kind of workers would those be, what kind of 4 workers are those? It's at the very top of ES-4. 5 A. Field people to manage the water tables, manage the 6 water, irrigation laborers to manage the irrigation water. 7 I have it in a table here. I don't recall off the 8 top of my head (perusing document). 9 There would be, most of it would be additional on- 10 farm labor to do the type of work similar to what they 11 would already be doing, R&D people, scientists, field 12 workers and laboratory technicians, a couple of those. 13 Q. What table is that that you are referring to? 14 A. Table 9-4 after page 9-14. You can get an idea of 15 the type of labor by looking at our discussion of best 16 management practices and how they would be implemented in 17 the BMP chapter. 18 Q. On page ES-5 you discuss property values or local 19 real estate tax revenues. 20 Given the way assessments and agricultural 21 exemptions work, would the decreases in property values 22 cause actual reductions in real estate taxes, do you know? 23 MR. NETTLETON: Object to the form. 24 BY THE WITNESS: 25 A. The Palm Beach County property appraiser's office 155 1 evaluates the income to farming in the EAA and that 2 appraiser uses that income to create an assessed value of 3 the property. 4 From that assessed value, the tax rate is applied 5 and that determines the real estate tax. 6 BY MS. STINSON: 7 Q. Have you done any calculations to determine what 8 effect there would be in real estate taxes? 9 A. Yes. 10 Q. Is that included in your report? 11 A. Yes. 12 Q. Have you done the calculations to determine what 13 the net effect on real estate taxes would be? 14 A. Yes. 15 Q. Point to that or tell me where to find that. 16 A. That's local taxes, local real estate taxes. 17 Property taxes. We use it interchangeably. Agricultural 18 land in the EAA pays property taxes. 19 Q. Is there a table that includes those calculations, 20 how you arrived at the 3.8 and $2.6 million? 21 A. There's a table in each section on the storm water 22 treatment areas, the BMPs and the assessments that report 23 the change in real estate taxes. 24 Q. Is there anything that will show me the actual 25 calculation by which you arrived at the numbers you 156 1 reported? 2 A. We describe what we do in the report and the 3 spreadsheet, the computer spreadsheet of this, of each 4 table, you know, these tables. Table, for example, 9-5 has 5 the calculation of the change in real estate taxes. 6 Q. And the spreadsheet would have been provided to me 7 on disk? 8 A. Yes. 9 Q. Have you performed any analysis of the match of the 10 education and skill levels of EAA workers with the types of 11 workers required by the projected job market in Palm Beach 12 County and adjacent counties? 13 MR. SAXE: Object to the form. 14 BY THE WITNESS: 15 A. Could you just be a little more specific. 16 BY MS. STINSON: 17 Q. Have you done any analysis to determine whether the 18 types of workers in the EAA that may be displaced have the 19 skills which would enable them to find jobs in Palm Beach 20 County or elsewhere? 21 A. Not that I recall specifically at this time. 22 Q. On page 1-1 you mentioned the sport fishing 23 industry in Lake Okeechobee. 24 Do you know whether the reduction of agricultural 25 activities would have any impact on that sport fishing 157 1 business? 2 A. Would you ask the question again. 3 (Whereupon, the pertinent portion of the Record was 4 read back by the Court Reporter.) 5 MR. NETTLETON: Object to the form. 6 BY THE WITNESS: 7 A. (Continuing) During our analysis we did -- I did 8 not come to the conclusion that it would have an impact. 9 BY MS. STINSON: 10 Q. Did you look at the question? 11 A. Yes. 12 Q. What did you look at to come to that conclusion? 13 A. The interaction -- just looking at the interaction 14 between agriculture and the fishing industry there. We 15 didn't look at it very closely, but it just -- it would 16 seem that, you know, from our experience there wouldn't 17 be -- and it was not brought to our attention that there 18 would be a relationship between the two such that if 19 agricultural production was affected by the Act that, 20 necessarily, the fishing industry would be affected. They 21 seemed to be pretty separate in the EAA. 22 Q. Did you look, for example, to see where the people 23 who came to sport fish were from? 24 A. That information was mostly in talking to people in 25 the EAA, so it would be anecdotal information that they 158 1 came from outside the area. 2 Q. Have you done any analysis of the impact of the Act 3 and Settlement Agreement on Clewiston? 4 MR. SAXE: Would you read back the question, 5 please. 6 (Whereupon, the pertinent portion of the Record was 7 read back by the Court Reporter.) 8 A. Well, the raw -- a raw sugar mill is in Clewiston, 9 so we looked at that. Sugar refinery in Clewiston, we 10 looked at that. 11 Q. Have you looked at the loss of jobs or retail 12 business or community impacts in Clewiston? 13 A. Yes. 14 Q. Other than the direct loss or possible losses at 15 the mill and refinery? 16 A. It affected resale and service industries. 17 Q. Do you know what county Clewiston is in? 18 A. Hendry County. 19 Q. Is there something in the report that tells us how 20 many jobs would be lost in Clewiston, how many retail jobs 21 would be affected? 22 A. It's included in the aggregate numbers for EAA in 23 Palm Beach County and we did not separate those numbers 24 out. 25 Q. Then your analysis is not just of Palm Beach 159 1 County; is that correct? 2 A. The EAA -- the regulated portion of the EAA and 3 wherever the mills are, which some of them may be outside. 4 I think the one in Clewiston is outside the regulated 5 portion but we do include that mill and that area. 6 Q. Did you include, then, the population base of 7 Clewiston and other information from Clewiston in applying 8 the RIMS multipliers? 9 A. The regulated portion of the EAA, we looked at how 10 they would respond to the Act and the Settlement Agreement 11 in terms of, first of all, the change in production and the 12 change in sales. 13 We then -- now, that change in sales affects all of 14 the raw sugar mills or could affect all the raw sugar 15 mills. So we used the RIMS multipliers that represent Palm 16 Beach County to get an estimate for that area, the EAA and 17 Palm Beach County. 18 So that impact includes the slice of the EAA, the 19 regulated portion of the EAA that's in Hendry County and 20 the portion of the EAA that's in Palm Beach County. 21 Q. But for the whole area you applied the Palm Beach 22 County multipliers? 23 A. Yes. 24 Q. Have you determined the impact on the amount of 25 sugar refined in the EAA due to reductions in the sugar 160 1 produced in the EAA? 2 MR. NETTLETON: Object to the form. 3 BY THE WITNESS: 4 A. Yes. 5 What type of impact? 6 BY MS. STINSON: 7 Q. What reduction there may be in the amount of sugar 8 refined in the EAA? 9 A. We looked at that. 10 Q. Can you point to me in the report where that 11 information is? 12 A. Yes. 13 Would you like me to? 14 Q. Yes, please. 15 A. Page 11-1. This section discusses it. 16 Q. What is your conclusion with regard to the impact? 17 A. We found there would be no impact to the 18 refineries. 19 Q. And why is that? 20 A. Because in our analyses and looking at all the 21 different -- say, even the hundred-dollar-an-acre 22 assessment, there is still enough cane or sugar grown in 23 the EAA to run them through -- run it through those 24 refineries. 25 So the reduction in marketing would come from 161 1 reduced shipping to other markets. 2 Q. Did you determine that there are any unrealized 3 potential economies of scale in EAA sugar growing, sugar 4 production? 5 MR. SAXE: Object to the form. 6 BY THE WITNESS: 7 A. Would you say that again. 8 BY MS. STINSON: 9 Q. In looking at the cost of production of sugar in 10 the EAA, did you determine whether there are or could be 11 economies of scale that do not currently exist? 12 MR. SAXE: Object to the form. 13 BY THE WITNESS: 14 A. I don't believe we did. If they don't exist or 15 didn't exist, we didn't include them. 16 BY MS. STINSON: 17 Q. Well, if there are potential -- did you determine 18 whether there are potential economies of scale that have 19 not been realized? 20 MR. SAXE: Object to the form. 21 And, Counsel, what do you mean by "potential 22 economies of scale?" 23 BY THE WITNESS: 24 A. I do not understand the question at all. 25 BY MS. STINSON: 162 1 Q. Let me come back to that one. 2 Do you know whether the ownership of vegetable land 3 relates to the ownership of sugar cane land, whether 4 they're common owners? 5 MR. SAXE: Object to the form. Ownership relates 6 to ownership. 7 BY THE WITNESS: 8 A. You want to know if I know? 9 BY MS. STINSON: 10 Q. Right. 11 A. That there's any relationship? 12 Q. Yes. 13 A. My understanding is that some of the vegetable land 14 is owned by sugar cane producers. 15 Q. Have you analyzed that as part of your impact 16 assessment? 17 A. I don't understand what you mean by "analyzed." 18 Q. Would the fact that one owner has both vegetable 19 operations and sugar operations affect a question of 20 whether land would go out of production? 21 A. To be honest with you, I don't recall. 22 Q. You indicate on page 2-3 that the EAA generated 23 about 1.5 billion in sales in 1991 and those sales are 24 presented in table 2-6. Can you tell me the source of that 25 information? 163 1 A. That's from Dun & Bradstreet, the data that they 2 provided us. 3 Q. Does that include the sugar refining? 4 A. Yes. 5 Q. Of the 15,600 people that we talked about a little 6 bit ago, and the seasonal workers that are not included in 7 that figure, do you know whether those seasonal workers 8 reside in the EAA or not? 9 A. They reside, yes, they reside at least temporarily 10 but they may go to other parts of Florida. 11 Q. Do you know whether any portion of those people 12 maintain their base, their permanent residence in the EAA, 13 the seasonal workers? 14 A. If I recall correctly, some of them do maintain a 15 permanent resident base, but I don't know how many, I don't 16 remember how many or what proportion. 17 Q. Do you have data to show how many of those seasonal 18 workers maintain a permanent residence in the EAA? 19 A. We didn't look at that issue specifically, so I 20 would have to look back and see if there's -- I don't 21 remember exactly where I got that information from. 22 Q. You indicate that 75 percent of the employees live 23 within the EAA, some in Palm Beach, Broward, Dade and 24 Martin, and 16 percent live outside the areas. 25 Do you have any information to show where they 164 1 live, the 16 percent? 2 A. We may. I'm trying to remember. We have it all on 3 a spreadsheet that you all have, so you'd be able to read 4 it off the spreadsheet. We might have aggregated it 5 from -- 6 You know what, look at the survey form, see if we 7 asked it. I'm just trying to go by memory here (perusing). 8 We don't have the survey form here. 9 Well, anyway, look at the survey form and see if we 10 asked specifically for them to name the impact cities. 11 (Perusing) Oh, here we are. 12 Okay, on the business survey they would have 13 answered inside the EAA, eastern Palm Beach, Dade, Broward 14 or Martin County. 15 And the next answer would be, are they in 16 Okeechobee, Highlands, Glades or Hendry County and not in 17 the EAA. 18 And the final one would be outside of the above 19 areas. 20 So that's the most breakdown we have. 21 Q. On page 2-4 you indicate the median income of 22 households and the source of the information from Dun & 23 Bradstreet. 24 Have you compared that to the U.S. census 25 information? 165 1 MR. NETTLETON: Object to the form. 2 BY THE WITNESS: 3 A. Would you tell me what table you are referring to. 4 BY MS. STINSON: 5 Q. Not a table, page 2-4, it's the last paragraph. 6 A. Yes, if I recall correctly, we did have census data 7 and we did compare them. 8 Q. Do you know how they compared? 9 A. Well, they must have compared fine or else I would 10 not have reported what this sentence says. 11 Q. Table 2-6, did you provide to us a disk with a 12 spreadsheet which would show the calculations and the 13 sources for that information? 14 A. It should have been on the disk. 15 If it's not, then we must have lost it because I 16 gave you everything we had in our computer files. 17 Or maybe I did it by hand, and if I did it by hand, 18 you have that too. I don't remember throwing that out. 19 The raw data that this came from, you all have. 20 Q. In your 10-year report did you consider the 21 production differences between yield belts or among the 22 yield belts? 23 MR. SAXE: Object to the form. Production 24 differences. 25 BY THE WITNESS: 166 1 A. We considered productivity. Yield per acre 2 changes, differences among the yield belts. 3 BY MS. STINSON: 4 Q. And what was that based on? 5 A. Information provided by the Palm Beach County 6 property appraiser's office. 7 Q. What specific information did they provide to you? 8 A. Yield per acre by farm belt. 9 Q. And is that what we discussed yesterday, the 10 averages from the plots from different yields? 11 A. Yes, the Palm Beach County property appraiser's 12 office apparently, from what I'm told by him, averages the 13 data provided to him by the Sugar Cane League and the 14 Cooperative which is the plot data you showed me yesterday, 15 the field data. 16 And he averages them and he reports them by yield 17 belt. He has a little spreadsheet that you all have, 18 should have. And we took that information right from his 19 records. 20 Q. Subsequently, have you gotten individual data 21 for each plot? 22 A. Yes, their fields. 23 Q. Fields? 24 A. Toward the end of the project, I guess it was about 25 in June or July, I don't remember what month, we did get 167 1 individual field data from those, whatever, 140 fields in 2 the EAA, but we didn't have a chance to look at them at 3 that time. 4 Q. I'm looking for it here but at some point you use, 5 on page 4-5, you use the term "opportunity costs of 6 processing sugar." 7 A. What page are you referring to? 8 Q. 4-5. Can you define to me what you mean by that? 9 A. Okay. That would be the rate of return that you 10 could get from your next best investment of money. 11 Q. How did you determine what that was? 12 A. If I remember correctly, now I'm going from memory, 13 we used an interest rate of 8 percent. 14 Q. Why? What does that represent? 15 A. Oh. That represents that every year you want to 16 get an 8 percent return on the money that you've invested 17 in your business. 18 Q. Why did you choose that number? 19 A. Eight percent is -- well, it's an estimate of 20 your -- the next best use of your money and -- 21 Q. The question is: Why did you choose 8 percent? 22 A. Just a minute. 23 It's the yield of bonds, government bonds, 24 long-term and oftentimes intermediate-term bonds. So if 25 you invest your money, a risk-free investment would be to 168 1 invest in bonds and so that -- well, now the return on 2 bonds is much lower than 8 percent, but at the time we used 3 that number because historically during the 1980s that was 4 the yield that you could get off of other investments like 5 bonds. 6 Q. On page 4-6 you've got some numbers at the top of 7 the page. What is the source and have you provided to us 8 information which would show us how you calculated each of 9 those numbers? 10 A. Yes, you have the spreadsheet. We provided you 11 with the spreadsheet that calculated those numbers. 12 Q. The information on page 4-8 on yields per belt, 13 again, have you provided us information that would show how 14 those figures were calculated? 15 A. Yes. 16 Q. And that's on a disk you've given us? 17 A. It's on one of the spreadsheets, yes. 18 Q. On 4-9, the last paragraph, you indicate 19 information or predictions from IFAS regarding soil 20 subsidence. What is the source of that? 21 A. You are talking about the last paragraph, 22 reductions by IFAS? 23 Q. Correct. 24 A. I know where it's from, I just want to make sure I 25 give you the right cite. 169 1 It's a report by George Snyder at IFAS and it might 2 be this one, cite 24 on the bottom of that page, it might 3 be that one. It's that little document that looks like 4 (indicating) this. 5 Q. And it's by George Snyder? 6 A. George Snyder at IFAS. 7 Q. Okay. We'll try to find that. 8 On page 4-10, the cost per gross farm acre, I guess 9 this is -- I'm not sure. Are those annual costs? 10 A. Yes. 11 Q. What is the source? 12 A. The source -- those are calculated numbers that I 13 calculated based on the information on BMPs that we discuss 14 in the BMP chapter, so the sources would be the sources 15 that we cite in the BMP chapter. 16 Q. Your calculations, are they on a spreadsheet that 17 you have provided to us? 18 A. Yes. 19 Q. Are the calculations in arriving at the real 20 property tax figures also on a spreadsheet? 21 MR. SAXE: Where are you, Counsel? 22 MS. STINSON: Still on page 4-10. 23 BY THE WITNESS: 24 A. Yes. 25 BY MS. STINSON: 170 1 Q. On page 4-11 you convert gross farm acre to 2 harvested acre. Tell me how you did that. 3 A. Where are you referring to on page 4-11? 4 Q. I'm looking. 5 At the top you indicated all receipt and cost items 6 are represented per gross farm acre and not per harvested 7 acre as is recorded in USDA and IFAS publications. Did you 8 do calculations to convert? 9 A. Yes. 10 MR. SAXE: Object to the form. Convert what, 11 Counsel? 12 BY MS. STINSON: 13 Q. Gross acres to harvested acres or harvested acres 14 to gross acres? 15 A. We did calculations to convert cost per harvested 16 acre to cost per gross acre. 17 Q. What did you do? 18 A. We took the cost per harvested acre and multiplied 19 it by .75, I'm pretty sure that's what we did. 20 Q. Why by .75? 21 A. That's the amount of land in actual sugar cane 22 production. 23 Q. Well, based on what, what's the source of? 24 A. That comes from a report by Jose Alvarez. 25 Q. What report? 171 1 A. Cost and Returns to Sugar Cane Production on Muck 2 Soils in the EAA. 3 Q. Again, on this page, you talk about opportunity 4 costs. Is that the same 8 percent that we discussed a 5 minute ago? 6 A. So we're on the second paragraph of page 4-11; is 7 that what you are referring to? 8 Q. Yes. 9 MR. SAXE: You are referring to the second 10 paragraph, the reference to opportunity cost on the 11 third line down. 12 MS. STINSON: Yes. And the reference in the next 13 to the last line of the first paragraph. 14 BY THE WITNESS: 15 A. The depreciations and returns to investment that's 16 referred to in the second paragraph were amortized at 8 17 percent annual interest. 18 In other words, if you read that sentence, 19 depreciations and returns to the investment is the 1994 20 purchase price of the farm machinery compliment amortized 21 the 8 percent annual interest estimated over the estimated 22 economic life of the machinery. 23 BY MS. STINSON: 24 Q. In the first paragraph you indicate, well, the end 25 of the sentence says "...and still cover its cash 172 1 depreciation and opportunity costs." 2 "Opportunity costs" is what? 3 A. Well, it has the same definition but I'm not 4 exactly sure what percent was used on that. 5 Q. Is there anything that would tell me what percent 6 you used on that? 7 MR. NETTLETON: Object to the form. 8 BY THE WITNESS: 9 A. Okay, I'm going from the best memory I can possibly 10 muster up here. If you turn to table 4-5 right before page 11 4-7 and you look under fixed, says "Interest." 12 If I remember correctly, I'm trying to remember as 13 best I can, it seems to me at this time that that is 14 represented as the opportunity cost either per ton or per 15 pound of raw sugar. 16 BY MS. STINSON: 17 Q. And is that based on an 8 percent figure? 18 A. That is based on whatever USDA based it on. 19 Q. From the report cited on that table? 20 A. Yes. 21 Q. You have a land value on page 4-11, third 22 paragraph, of 2,856 per acre. How does that compare to the 23 county's appraised value; do you know? 24 A. I don't remember at this time. 25 Q. At the bottom of page 4-11 you say that "The 173 1 average trend in raw sugar recovered is 2 percent per year 2 since 1964." 3 How did you calculate that 2 percent? 4 A. We calculated the percent change in recovery 5 between the current year and the previous year and then we 6 averaged those percentages over the period since 1964 and 7 the average percent was a 2-percent increase per year. 8 Q. So you took what percent difference from, say, '64 9 to '65 and -- 10 A. '65 to '64 and '66 to '65. 11 Q. And then arranged all those percentages? 12 A. Yes, if I remember correctly, that's what we did. 13 Q. On page 4-12 you discuss price increases, 14 inflation, expected increases in inflation. 15 What is the source of the assumptions regarding 16 inflation? 17 A. Well, right here it's inflation and the cost of 18 increasing productivity at the mill. Inflation and the 19 cost of increasing productivity is estimated using the 20 10-year average of producer prices for all commodities as 21 reported in the Florida statistical abstract, 1991. 22 Q. The price increase of 1.7 percent per year referred 23 to on page 4-12, what is the source of that or how did you 24 compute that? 25 A. For each year of the forecast period we took the 174 1 revenue received by the mill and subtracted off the costs. 2 We took that net and converted it to dollars per ton of 3 sugar cane. Then we looked at how much that maximum sugar 4 cane price, which is what that is, increases. We looked at 5 how it increases from year to year and found it increased 6 by 1.7 percent per year. 7 Q. Is that based on historical information or your 8 projection? 9 A. If I remember correctly, it was a projection based 10 on the increases in the recovery rate and increases in 11 inflation at the mill. 12 Q. On page 4-13 you talk about baseline projections. 13 Under the baseline projection does any land leave 14 production during your 10-year forecast? 15 A. Which baseline projection are you referring to? 16 Q. I guess scenario two which is discussed on 4-13. 17 A. Under scenario two practically all of the land, or 18 a good portion of the land, or most of the land would leave 19 production with the liberalization of sugar prices. 20 Q. Without -- 21 A. (Continuing) The sugar market, I'm sorry, I'm 22 getting sloppy here. 23 With the liberalization of the sugar market as 24 described on page 4-13, we find that the residual returns 25 to land and risk of all eight model farms are negative. 175 1 From that we can infer that sugar cane production is no 2 longer profitable in the EAA. Land would leave production. 3 Q. Under scenario one have you, under your baseline 4 projection, does any land leave production in the baseline? 5 A. You are referring specifically to sugar cane? 6 Q. Yes. 7 A. Under the baseline, my best recollection is that no 8 land leaves production under the baseline. 9 Q. What about vegetables? 10 A. Under the vegetables, one of the crops does leave 11 production under the baseline. 12 Q. Is that as shown in a chart or table somewhere? 13 A. I know it's described in the report under baseline 14 economic projections for vegetables. 15 Q. What about sod? 16 A. To the best of my recollection, sod does not leave 17 production under the baseline. 18 Q. On page 5-1 you indicate that individual farms grow 19 a variety of vegetables. 20 Have you analyzed a scenario where individual farms 21 grow both vegetable -- sugar cane and corn? 22 A. No, I don't believe we have, if I recall correctly. 23 Q. Do you know what determines whether fallow sugar 24 cane land would be planted in corn? 25 A. I don't understand the question. 176 1 Q. Do you know whether some fallow cane land is 2 planted in corn, whether that's a standard -- 3 A. Yes. 4 Q. -- practice? 5 A. Yes, it is, some of it is. 6 Q. Do you know why some is and some isn't; what makes 7 the determination -- what affects the determination as to 8 whether to plant fallow sugar cane land in corn? 9 MR. NETTLETON: Object to the form. 10 BY THE WITNESS: 11 A. I don't understand the question really. 12 Let me see. Land would be planted to corn if the 13 owner of the land wanted it planted to corn. 14 BY MS. STINSON: 15 Q. Do you know what would affect his wanting to plant 16 it in corn or not, is that anything you looked at in your 17 economic analysis? 18 MR. NETTLETON: Object to the form. 19 BY THE WITNESS: 20 A. It probably came up but I don't recall exactly. 21 BY MS. STINSON: 22 Q. Do you know how much or what percentage of the land 23 planted in vegetables is owned by sugar cane producers? 24 A. Not off the top of my head, but I could figure it 25 out. 177 1 Q. Do you have the information that would allow you to 2 figure that out or is it contained in the report? 3 A. It may not be in the report but we do have the 4 property ownership records and so, for example, my 5 understanding is that U.S. Sugar -- or South Bay Growers is 6 a subsidiary of U.S. Sugar, and South Bay Growers grows 7 vegetables, so if you know how much land is owned by South 8 Bay Growers, there's a connection there between sugar cane 9 and vegetables. 10 Q. Is that property ownership information something 11 you have produced to us? 12 A. Yes. 13 Q. On page 6-1 you discuss the production of sod and 14 you have, in the last paragraph, some cost and profit 15 figures. 16 Do you have information on the price history of 17 sod, is that contained in the report? 18 A. I may not. I don't remember if we put it in the 19 report. 20 Q. Would that be in some information you have provided 21 to us? 22 A. Yes. We -- it probably is because there's two 23 sources, one is the information provided by the sod company 24 and the other is the information in the census publication, 25 a Florida agriculture census information which we provided 178 1 to you all. 2 Q. Is that the source of your information on sod 3 prices? 4 A. Yes. 5 There's also probably a spreadsheet that you all 6 have that calculates sod prices. 7 Q. Would that include assumptions about the price of 8 sod in the future and the cost of production of sod in the 9 future? 10 A. Would what include? 11 Q. The spreadsheet. 12 A. Yes, it includes our calculations. 13 In here we don't say what we used for the price of 14 sod (perusing)? 15 I don't see it there. I recall something like 7 16 cents a square foot but, you know, I'm willing to help you 17 out on where that came from. 18 Q. On page 7-1 you discuss the factors for measuring 19 economic contribution. Have you projected the change in 20 the number of firms or owners in the EAA by type that would 21 result from the economic impacts? 22 MR. SAXE: Object to the form. 23 MR. NETTLETON: Could you read back the 24 question, please. 25 (Whereupon, the pertinent portion of the Record was 179 1 read back by the Court Reporter.) 2 MS. STINSON: Let me scratch that one. 3 BY MS. STINSON: 4 Q. Have you projected the change in the number or type 5 of businesses, business firms in the EAA? 6 MR. SAXE: Object to the form. Is there more to 7 the question? 8 MS. STINSON: Not now. 9 BY THE WITNESS: 10 A. The number of business entities. You want to know 11 if we forecasted a change in the number of business 12 entities? 13 BY MS. STINSON: 14 Q. Right. 15 In the types you have forecasted, you have loss of 16 retail jobs. Did you determine whether there will be a 17 change in the number of types of businesses? 18 A. No, not that I recall. 19 Q. Have you projected, as a result of the impact, any 20 change in public facility and service costs? 21 MR. SAXE: Object to the form. 22 BY THE WITNESS: 23 A. You mean like change in the cost of running schools 24 and waste water treatment plants, things like that? 25 BY MS. STINSON: 180 1 Q. Correct. 2 A. No, we didn't look at the changes in the cost of 3 operating waste water treatment plants or public schools. 4 Q. Have you considered any change as a result of the 5 impact in property values for non-agricultural land? 6 A. Well, we looked at the change in property values 7 for agricultural land and mills and I believe -- that's 8 probably it. I mean in terms of the value of a business in 9 Belle Glade, no, we didn't look at that, you know, that 10 land that that business is on. 11 Q. You indicated a little bit ago that you used the, I 12 believe the area of Palm Beach County because that's what 13 you had RIMS multipliers for. 14 Is it possible to construct multipliers for the 15 region, the geographic region of the EAA? 16 MR. SAXE: Object to the form. I think you are 17 mischaracterizing the earlier testimony of the witness. 18 BY THE WITNESS: 19 A. You probably could theoretically and practically. 20 BY MS. STINSON: 21 Q. Let me back up. On page 7-3 you talk about job 22 loss and that they are measured in FTE units. 23 MR. BURGESS: What page is that, Counsel? 24 MS. STINSON: 7-3. 25 BY MS. STINSON: 181 1 Q. Have you made any estimate of how many jobs as 2 opposed to FTEs that would convert into? 3 MR. NETTLETON: Object to the form. 4 BY THE WITNESS: 5 A. FTEs, as you call it, stands for full-time 6 equivalent, so it is a real job. We didn't spend much time 7 on it but we attempted to convert that to both full-time 8 and part-time employees. 9 BY MS. STINSON: 10 Q. Did you do that? Is there a figure which would 11 include that? 12 A. Not in this report. I think -- let me see if I can 13 remember. 14 It would be in Chapter 11 if we did it. I know we 15 talked about it to the governing board, but this 1.5 that 16 we used as a factor is just an estimate, is an estimate. 17 Q. Did you do any analysis to arrive at that estimate? 18 A. Yes, we did an analysis. 19 Q. What did you do? 20 A. Well, in looking at, you know, overall, and talking 21 to people and looking at, you know, different pieces of 22 data, maybe at most perhaps 50 percent, you know, of the 23 jobs are part time but that's probably on the high side. 24 Q. Is -- 25 A. (Continuing) So then you just figure out the factor 182 1 from there mathematically. You take the number of 2 full-time equivalent jobs and multiply it by the factor 3 that converts full-time equivalent jobs into full-time and 4 part-time equivalent jobs. 5 Q. Can you tell me specifically what data or 6 information you used to come up with that factor? 7 A. I don't remember exactly. 8 Q. On page 7-4 at the very bottom you indicate that 50 9 percent of the depreciation of mill equipment is an upper 10 bound I believe that you indicate that could need to be 11 replaced each year. 12 What is the basis for that figure? 13 A. That's, if I recall correctly, just an estimate. 14 I'm not sure what the basis of it was that we used for 15 that, if there is any basis at all. 16 Q. On page 7-5 you discuss the impact of long-term and 17 intermediate debt and discuss banks possibly foreclosing. 18 If a bank forecloses and the property remains in 19 the hands of the lender, the bank, what is your assumption 20 with regard to production? 21 A. Is that the bank -- 22 MR. SAXE: Object to the form: What do you mean by 23 "with regard to production"? 24 MS. STINSON: Whether the land would remain in 25 production. 183 1 BY THE WITNESS: 2 A. The bank would rent -- I'm sorry, the bank would 3 hire a manager to keep it operating or would put the land 4 up for sale and sell it. 5 BY MS. STINSON: 6 Q. If they cannot sell it, is it your assumption that 7 they would then operate it, they would hire a manager and 8 keep the land in production? 9 A. If they could make any money doing that, they 10 would. 11 Q. Have you prepared any scenarios to look at the 12 impact if it is necessary to make larger STAs than the 13 35,000 acres currently assumed? 14 A. No, we only looked at a STA size of 35,000 acres, 15 no more, no less. 16 (Whereupon, a brief recess was taken.) 17 BY MS. STINSON: 18 Q. On page 8-7 -- 19 A. I don't have 8-7. Oh, wait a minute, I'm sorry. 20 8-7. 21 Q. Found it? 22 A. Yes. 23 Q. The $358 million cost of the STAs is what year 24 dollars? 25 A. Current dollars I believe. 184 1 Q. "Current" being '92, at the time? 2 A. Yes, they're the estimates from the District as of 3 March '92, thereabouts. 4 Q. And are the District's estimates found in a table 5 or somewhere in your report? 6 A. On table 8-8 the "total" column, that's the 7 estimate of everything except the purchase price of the 8 land. So the purchase price of the land is 358 minus $242 9 million 10 Q. And what is the source of that, is that from the 11 SWIM Plan? 12 A. It is from the District. It was provided to us by 13 the District. And these numbers may show up in the SWIM 14 Plan. I'm not sure if they do or not. 15 Q. Do you know whether there are any firms located 16 within the EAA that are capable of doing the engineering, 17 design and construction management for the STAs? 18 A. No, I don't know of any in the EAA. 19 Q. Do you know whether there are any firms in the EAA 20 that are capable of doing the construction work required 21 for the STAs? 22 A. I don't recall. I knew it at one time, I don't 23 remember now. 24 Q. How did you know it? What information did you look 25 at? 185 1 A. The Dun & Bradstreet information on individual 2 businesses in the EAA. 3 Q. That would be your source of information for 4 determining whether there were any firms capable of 5 handling the construction work? 6 A. Yes. In the EAA. 7 Q. Right. 8 Do you know whether there are any workers in the 9 EAA that have the skills necessary for the skilled jobs on 10 the STA projects? 11 MR. SAXE: Objection. Asked and answered. 12 MR. NETTLETON: Same objection. 13 BY THE WITNESS: 14 A. Could you ask the question again. 15 BY MS. STINSON: 16 Q. On page 8-7 you indicate that about 257 of the jobs 17 require skilled workers and then you name them. 18 Do you know what number of those 257 jobs could be 19 filled by workers within the EAA? 20 A. No, not at this time. 21 Q. Did you at some time? 22 A. I may have, I don't recall. 23 Q. Do you have any information that would be a source 24 for an answer to that question? 25 A. If you knew -- when you know what kind of 186 1 businesses or what the exact businesses are in the EAA and 2 the kind of people that they hire, then you can get an idea 3 of whether or not any of those jobs that currently exist in 4 the EAA have the same -- are filled by people who could 5 also fill the jobs required to construct the STAs. 6 So you could know that from the business 7 information from Dun & Bradstreet, the phone directory, 8 that sort of thing, and the survey of businesses in the 9 EAA. 10 Q. That you did? 11 A. Yes. 12 Q. Did you look at what materials and equipment 13 necessary to construct the STAs could be purchased within 14 the EAA? 15 A. I don't believe we did. 16 Q. On page 8-8 you state that "It is expected that the 17 STAs will be financed with money generated within Florida." 18 What is the basis for that statement? 19 A. What is the basis for that statement? 20 Q. Correct. 21 A. In other words, the money that is used to 22 finance -- to pay for the STAs will come from residents and 23 businesses within the State of Florida. 24 Q. Why do you assume that? 25 A. Well, at the time, since we were looking at the 187 1 assessments and since the District, you know, there is a 2 revenue source from the District which is our property 3 taxes, and then you have maybe the state contributing, it 4 was just an expectation that the best expectation we had at 5 the time that most of the money would come from within 6 Florida, but we weren't saying that that was written in 7 stone or anything, we just had to make an assumption about 8 where the money was going to come from. 9 Q. So that statement is based on the assumption that 10 the money to finance the STAs would come from state 11 revenues, Water Management District, ad valorem taxes and 12 some kind of assessment on the agricultural interests, is 13 that -- 14 A. And/or any of that, yes. A combination. 15 Q. What effect, if any, does this assumption have on 16 your analysis? 17 A. I don't really remember at this time. 18 Q. Well, as an economist, what effect could that have 19 or where would that fit into an economic impact analysis? 20 A. If you were doing an estimate of how being taxed 21 affects the economy, then you would want to make -- would 22 need to make an assumption of where the money came from. 23 We looked at growers, farm land in the EAA. You might also 24 want to look at the taxes paid by residents in Florida, 25 part of the taxes that would go toward part of the 188 1 construction of the STAs. 2 Q. The assessments that you evaluated were 10, 25 and 3 100, is that correct, dollars per acre? 4 A. Yes. 5 Q. Would the $100 per acre assessment cover the cost 6 of the STAs? 7 A. I don't know. 8 Q. Did you make any assumptions with regard to whether 9 any of those levels of assessments would cover the entire 10 cost of implementing the Marjorie Stoneman Douglas Act or 11 the Settlement Agreement? 12 A. No. We looked specifically -- the District asked 13 us to look at those assessment levels specifically on the 14 land in the Everglades -- in the regulated portion of the 15 Everglades agricultural area. 16 They did not ask us to look at the impact of taxes 17 or assessments paid by anyone outside of that area. 18 Q. You would agree, would you not, that the $25 an 19 acre assessment would not cover the costs of the STAs? 20 A. I really don't know. I do not know. 21 Q. Well, assume with me, if you will, that it would 22 not and that additional funds would be necessary to 23 construct the STAs. Would one source of those additional 24 funds be the Water Management District's ad valorem 25 taxation? 189 1 MR. SAXE: Object to the form. 2 MR. NETTLETON: Same objection. 3 BY THE WITNESS: 4 A. I suppose they could use the ad valorem property 5 tax base. 6 BY MS. STINSON: 7 Q. And that's, in fact, one of the sources that you 8 considered in your statement that it is expected STAs will 9 be financed with money generated within Florida; correct? 10 MR. SAXE: Object to the form. 11 BY THE WITNESS: 12 A. That's a possibility. 13 BY MS. STINSON: 14 Q. If there was an increase in ad valorem taxation to 15 finance the STAs that would be imposed upon owners within 16 the EAA as well as outside the EAA; correct? 17 MR. SAXE: Object to the form. 18 BY THE WITNESS: 19 A. Would you please repeat the question, I don't 20 understand it. 21 BY MS. STINSON: 22 Q. If one of the sources to finance the STA -- or 23 scratch that. 24 Assume that one of the sources to finance the STA 25 is ad valorem taxes of the Water Management District, that 190 1 tax is imposed upon the EAA property as well as property in 2 Dade, Broward and other counties within the Water 3 Management District; correct? 4 MR. SAXE: To form. 5 MR. NETTLETON: Object to the form. 6 BY THE WITNESS: 7 A. My understanding is that it is. 8 BY MS. STINSON: 9 Q. But you did not analyze the effect of an increase 10 in ad valorem taxation, possible increase on the EAA; is 11 that correct? 12 A. That's correct. 13 Q. Now, you indicated a minute ago that the District 14 wanted you to look at the effect on the regulated portion 15 of the EAA, correct, the effect of these 10, 25 and $100 16 per acre assessments? 17 A. Correct. 18 Q. But your report looks at the effect on the entire 19 geographic area of Palm Beach County and the regulated 20 portion of the EAA; correct? 21 A. And the area affected by the raw sugar mills. 22 Q. Nothing in your report or your analysis states how 23 many jobs and what monetary impact there will be only 24 within the regulated portion of the EAA; is that correct? 25 A. That's included in our numbers, but we did not 191 1 separate those out. 2 Q. On page 8-8 the third paragraph down, you indicate 3 that certain percentages of materials for the construction 4 of the STAs would be purchased within Palm Beach County. 5 What is the source for your estimates in that 6 paragraph? 7 A. Hazen and Sawyer has environmental and civil 8 engineers and structural engineers, so I assigned that, 9 made that assignment to one of our engineers to determine 10 as best as he could, based on the expertise of Hazen and 11 Sawyer and our knowledge of where you buy all this stuff at 12 about, from a reasonable, you know, what reasonably could 13 you expect to purchase within Florida and outside of 14 Florida, within Palm Beach County and outside of Palm Beach 15 County. 16 Q. What engineer? 17 A. Steve Ivanic. 18 Q. Do you know what he looked at to come up with these 19 percentages? 20 A. He looked at our own jobs that we do, our 21 construction management jobs, our design jobs. 22 He may have used any type of reference material 23 that engineers use, like R.S. Means 1992 and just the 24 experience of Hazen and Sawyer employees. The engineers at 25 Hazen and Sawyer. 192 1 We design civil engineering projects and 2 environmental engineering projects and we do the project 3 management, we do the job bids, so a lot of that is just 4 in-house information. 5 Q. Is there any kind of data, backup data that is in 6 the report or that you have provided to us that would 7 support these numbers? 8 A. There might be, in the file that had information on 9 who builds the STAs, you know, the number of employees that 10 build the STAs, that sort of thing, it might be in there. 11 Q. But you are not sure? 12 A. I'm not sure. 13 Q. You indicate that annual operation and maintenance 14 of the STAs will create 50 full-time equivalent jobs. 15 Do you make any assumption with regard to where 16 those people will live? 17 A. No. Not that I recall. 18 Q. Do you make any assumption with regard to where 19 the construction workers for the STAs will live? 20 A. Well, we say that it is expected that most jobs 21 will be filled by south Florida residents and also, if I 22 recall correctly, the District communicated to me that they 23 would require that the firms who design and construct the 24 project be located in the local area. 25 Q. Do you have any documentation to indicate that 193 1 they would require that? 2 A. I may have, I don't remember. 3 Q. If you did, what would it be? 4 A. I'm trying to remember. I'm trying to think 5 back. 6 It could be in a Telcom. I don't really remember 7 where it could be, to be honest with you. 8 Q. But the basis for your assumption is something 9 you were told by the District; is that correct? 10 A. Yes. 11 Q. Page 9-4, the paragraph, the next to the last 12 paragraph that begins "The highest net returns," you 13 indicate that one-half of the acreage in the final sugar 14 cane ratoon will be successively (sic) replanted to sugar 15 cane and the other half will be planted to rice. 16 What is the basis for that statement? 17 A. The proportion of the land in the last ratoon 18 that's successfully replanted to rice -- I mean to sugar 19 cane, in my best recollection, comes from the IFAS report 20 called Costs and Returns to Sugar Cane Production on Muck 21 Soils in the EAA. So the other half of the land in that 22 final ratoon would ordinarily be left fallow, but now that 23 we're looking at BMPs, one option is for rice to be grown 24 on that fallow land, so that is the basis for this 25 statement. 194 1 Q. Do you know whether there are any hindrances 2 within the federal rice program to the addition of acres to 3 be planted in rice in the EAA? 4 MR. NETTLETON: Object to the form. 5 BY MS. STINSON: 6 Q. Are there any barriers to the production of 7 rice? 8 MR. NETTLETON: Object to the form. 9 MR. SAXE: Object to the form. 10 BY THE WITNESS: 11 A. Could you be more specific? 12 BY MS. STINSON: 13 Q. Are you familiar with the federal policy with 14 regard to rice? 15 MR. NETTLETON: Object to the form. 16 MR. SAXE: Object to the form. 17 MR. NETTLETON: Is that the federal rice policy? 18 BY MS. STINSON: 19 Q. You can answer anyway. 20 A. Yes, I am familiar with the rice policy. 21 Q. Is there anything in that rice policy which would 22 affect a grower's ability to plant land in rice and sell it 23 of course, I mean anybody can plant it? 24 MR. NETTLETON: Object to the form. 25 MR. SAXE: Objection to form. 195 1 BY THE WITNESS: 2 A. Not that I recall. We definitely looked at that 3 issue and we didn't find any reason why the grower could 4 not join the rice program. 5 BY MS. STINSON: 6 Q. Did you look at what effect it would have on the 7 rice program if there were additional acres planted in 8 rice? 9 MR. SAXE: Objection to form. 10 BY THE WITNESS: 11 A. No, I didn't. We mentioned something about how it 12 would affect -- if all those acres that we look at actually 13 were planted in rice, we looked at well, how would that 14 affect the U.S. price of rice -- 15 BY MS. STINSON: 16 Q. "You" is -- 17 A. -- or the market price of rice, and that would have 18 an effect on how the sugar program operated. 19 Q. You did look at that? 20 A. We looked at -- I mean we looked at it but we 21 didn't use it in this report. In other words, we didn't 22 say that they couldn't grow it, grow the rice because of 23 anything that -- any changes to the sugar program. In 24 other words, the sugar program operates as it's always 25 operated. 196 1 Q. Rice program? 2 A. Rice program, excuse me. 3 Q. When you looked at it, did you reach any 4 conclusions about what effect there would be from planting 5 these acres in rice? 6 A. Could you restate the question, I don't understand 7 the question. 8 Q. The answer you just gave me said you looked at the 9 effect of rice, the price of rice if these acres in the EAA 10 were planted in rice; correct? 11 A. Yes. 12 Q. You looked at it. What conclusions did you draw? 13 A. I'm trying to recall. 14 I don't really recall at the moment what 15 conclusions we drew on that. 16 Q. Is there any information in your report or which 17 you have given me which would describe what you found or 18 what you concluded? 19 A. Yes. On page 9-7, third paragraph. It says: All 20 sugar cane farms are assumed to grow rice on 12-1/2 percent 21 of their gross farm acreage, this implies that if an 22 additional 58,000 acres of rice will be grown in the EAA, 23 U.S. rice supply will increase by 3 percent. 24 In reality not all farms may need to grow rice 25 because they may be able to meet the requirements of the 197 1 Act by implementing other types of BMPs. And there's 2 probably more somewhere else." 3 Q. That did not answer my question as to what effect 4 on the rice program there would be from planting additional 5 acres of rice in the EAA. 6 MR. SAXE: Objection to form, Counsel. 7 What do you mean "effect on the rice program"? 8 MS. STINSON: My question stands. 9 BY THE WITNESS: 10 A. My recollection is that we did not foresee any 11 change in the rice program due to these farmers growing 12 rice. 13 BY MS. STINSON: 14 Q. Other than the narrative which you read me from 15 9-7, is there anything in your report or that you have 16 provided which would support the answer you just gave me? 17 A. I would recommend reading page 9-7 through 9-9. 18 Q. Is there anything -- 19 A. (Continuing) And reading the cite, footnote 49. 20 Q. In terms, however, of your analysis that led you to 21 the conclusion that there would be no effect, is there 22 anything which describes how you reached that conclusion? 23 You indicate on 9-7 that if these acres were 24 planted, rice supply would increase by 3 percent, but is 25 there anything that follows that through and says but this 198 1 3 percent would have no effect on the U.S. rice program or 2 rice policy? 3 MR. SAXE: Objection. Asked and answered. 4 BY THE WITNESS: 5 A. That's not -- we didn't write that in here, no. 6 BY MS. STINSON: 7 Q. Do you know whether there is sufficient milling 8 capacity within the area to handle 58,000 additional acres 9 of rice? 10 A. I don't know if there is or not. 11 Q. Did you look at that question? 12 A. We know it's an issue but we were not able to 13 answer that question. 14 Q. Table 9-1 sets forth the revenues and costs for 15 rice; correct? 16 MR. NETTLETON: I'm sorry, Counsel, what page? 17 MS. STINSON: It's table 9-1 right after page 9-10. 18 BY MS. STINSON: 19 Q. Is that correct? 20 A. Read that question again or what was the 21 question again. 22 (Whereupon, the pertinent portion of the Record was 23 read back by the Court Reporter.) 24 A. (Continuing) Yes, in 1992. 25 Q. The yield per harvested acre is from what source? 199 1 A. Jose Alvarez, IFAS, it was the Cost and Returns to 2 Rice Production in the EAA. 3 Q. In projecting the costs and revenues, I believe on 4 page 9-9 you indicate that you inflate the cost by 3.5 5 percent per year or over one year for 1994 projections. 6 How did you arrive at that figure, the 3.5? 7 A. I'll give you the best answer I can recall. 8 The 3.5 was the actual inflation in '83 and then 9 the 1.5 is the average inflation over the last ten years, 10 something like that. 11 Q. Is there any information, any disk or spreadsheet 12 that would set out your projections for rice production? 13 A. I would look at what we used for inflation for the 14 sugar cane cost numbers. I don't really recall anything 15 else. 16 Q. On page 9-10 you indicate that IFAS studies have 17 shown that, et cetera, the normal crop yield per acre can 18 be achieved with substantially less phosphorus applied. 19 A. Where are you reading from? 20 Q. Page 9-10 under BMPs for vegetables. 21 A. What line? Do you want to read it again. 22 Q. The seventh line down in the fertilization 23 practices. 24 A. Okay, I read the sentence I believe you read. What 25 was the question? 200 1 Q. The question is: Have you discussed with vegetable 2 growers whether they agree with that statement? 3 A. I don't recall. 4 Q. Do you know whether growers agree or disagree with 5 that statement? 6 A. I don't recall. 7 Q. On page 9-11, the paragraph that begins "Celery and 8 lettuce," next to the last paragraph. 9 A. Okay. 10 Q. You discuss the cumulative effect of the BMPs' 11 increasing yield risks. Did you factor yield risk into 12 your analysis? 13 A. You mean from the BMPs specifically? 14 Q. Right. 15 A. Obviously, since that's what we're talking about. 16 We considered yield risk and we took it very 17 seriously and we have designed the BMPs in this report that 18 we looked at such that you would put in enough effort to 19 minimize, if not completely eliminate, yield risk. 20 Q. How do you put in enough effort to minimize or 21 eliminate yield risk? 22 A. You have more effort put into managing water 23 tables. 24 Q. How is that reflected in your analysis? 25 A. Under our assumptions and our discussion of BMPs 201 1 and their costs toward the beginning of the chapter 9. 2 Q. Well, in the bottom line, what effect in your 3 calculations or economic analysis have you used to describe 4 the efforts that would be needed -- that needed to minimize 5 the yield risk? 6 MR. SAXE: Objection to form. 7 BY MS. STINSON: 8 Q. You say better management of water table. How does 9 that translate into your calculations? 10 A. It translates into the cost per acre to implement 11 BMPs. 12 Q. In what way? What, in labor or machinery, did you 13 increase -- 14 A. Mostly in labor. 15 Q. Did you make a specific calculation which would 16 increase labor cost to better manage water tables? 17 A. Those would be in the estimates of the BMP costs. 18 Q. How did you come up with those figures? 19 Specifically how did you factor in minimization of yield 20 risk into your calculations? 21 A. Through the way in which the BMPs are implemented. 22 Q. That's a generalization. Tell me now specifically 23 in what way -- 24 MR. SAXE: Objection to form. 25 BY MS. STINSON: 202 1 Q. -- BMPs are implemented? 2 MR. SAXE: Which BMPs are you talking about, the 3 example given by the deponent of water table 4 management? 5 BY THE WITNESS: 6 A. On page 9-5 through the top of 9-7 we talk about 7 the grower, growers would implement the BMPs and we took 8 very seriously the issue of yield risk from water table 9 management. 10 So in our conversations with Professor Del Botcher 11 we put in as much labor and materials and overhead as we 12 could to minimize yield risk as we saw -- as Del Botcher 13 saw it, using the best available information. 14 BY MS. STINSON: 15 Q. Can you tell me, though, if you were not taking so 16 seriously yield risks how the numbers would be different -- 17 MR. NETTLETON: Object. 18 MR. SAXE: Object. 19 BY MS. STINSON: 20 Q. -- did you increase the labor costs that were given 21 to you somewhere by a factor; how did you reach the 22 numbers? 23 MR. NETTLETON: Objection to form. 24 MR. SAXE: Objection to form. 25 BY THE WITNESS: 203 1 A. We didn't specifically net out any cost within and 2 without minimizing yield risk. The whole point was to try 3 to minimize yield risk so we didn't look at it with and 4 without minimizing yield risk. 5 BY MS. STINSON: 6 Q. On page 9-12, the next to the last paragraph, about 7 the middle of the paragraph, you indicate an amount that 8 the sugar mill can afford to pay the growers. Have you 9 provided your calculations in which you arrived at that 10 figure? 11 MR. NETTLETON: Which figure are you referring to? 12 MS. STINSON: The figure indicated in that 13 paragraph of $18 per acre. 14 MR. NETTLETON: Object to the form. 15 BY THE WITNESS: 16 A. Ask the question again. 17 BY MS. STINSON: 18 Q. Have you provided to us, or is it in the report 19 somewhere, how that $18 is calculated? 20 A. Yes. Right after we say it, $18 an acre, it is 21 based on 1990 depreciation per ton of cane as reported by 22 USDA of 84 cents. This depreciation is multiplied by the 23 average yield in tons per gross acre in yield belt five 24 over the past 10 years of 21 to obtain the $18 per acre. 25 That's right in that same paragraph on page 9-12. 204 1 Q. In the last paragraph you indicated federal, state 2 and real estate taxes have not been deducted. The real 3 estate taxes are based on average profitability and that it 4 is assumed that taxes will adjust each year so that the 5 farm can pay its taxes and still remain in business. 6 Have you done calculations to determine exactly 7 what the relationship is between profitability and real 8 estate taxes? 9 A. Throughout -- since I've been a consultant. 10 Q. To lead you to the conclusion that you make in the 11 last paragraph on page 9-12, have you done such 12 calculations? 13 MR. NETTLETON: Object to the form. 14 BY THE WITNESS: 15 A. We may have done -- we may have calculated the 16 taxes every year. We probably did in the study. 17 BY MS. STINSON: 18 Q. Where would that calculation appear? And I was 19 talking just now about real estate taxes, not the federal 20 and state income taxes. 21 A. On table 4-6, after page 4-12, real estate taxes 22 are the second to the last line from the bottom. 23 Q. Is there a disk that you provided us with a 24 spreadsheet that would show actually how those figures were 25 calculated? 205 1 A. I don't remember. 2 Q. Can you tell us how those were calculated? 3 A. I'm trying to remember. The real estate taxes are 4 calculated as explained on page 4-10 underneath section 5 4.9, that whole paragraph. And so those are -- must be in 6 and probably are in and more than likely are in the 7 spreadsheets that we've given you. 8 Q. On page 9-14, the last paragraph, you refer to 9 making estimations using the RIMS II multipliers to 10 determine the indirect and induced economic impacts of 11 BMPs. 12 Can you tell me or is there something that will 13 tell me specifically which RIMS II multipliers were used? 14 MR. NETTLETON: Object to the form. 15 BY THE WITNESS: 16 A. The sweet corn production multipliers are on page 17 8-3 under vegetables, is the industry classification. The 18 rice multipliers are on page 19-15 under rice milling. 19 BY MS. STINSON: 20 Q. Page 9-16, you have a figure in the first paragraph 21 at the end of $492,000 lost real estate tax revenue. 22 Is there something that will show me how you 23 arrived at that figure? 24 A. Yes. 25 Q. What is that? 206 1 A. Turn the page to table 9-5. There's a spreadsheet 2 that has -- one spreadsheet has the summary tables for each 3 of the aspects of the Act and Settlement Agreement that we 4 looked at. 5 If you look under, on table 9-5, if you look under 6 the total change in property taxes, in 1994 you'll see 7 $492,000. That cell should tell you how we calculated that 8 number. Or at least the cells above it. Well, the whole 9 thing, that cell and whatever cell it leads you to will 10 tell you how we calculated that number. 11 Q. I'm sorry, I don't know what you mean by "cell"? 12 A. Okay. The spreadsheet that corresponds to this 13 table. 14 Q. Right? 15 A. Each of these numbers are in a cell. 16 Q. Okay. Something on a disk you have provided to us? 17 A. Yes. Yes. And that cell has an equation in it, 18 for the $492,000 it has an equation. That equation also 19 refers to other cells in the spreadsheet, so you go to 20 those cells. And those cells have equations that indicate 21 other numbers. And so you can figure out how we calculated 22 that cell based on what is in it. 23 MR. SAXE: How far are you going to go? 24 MS. STINSON: You mean before lunch? 25 MR. SAXE: Before lunch. 207 1 MS. STINSON: This much (indicating). In fact, 2 this much. It's time for lunch. 3 (Whereupon, at 12:10 p.m. a luncheon recess was 4 taken, after which the proceedings resumed.) 5 o0o 6 7 A F T E R N O O N S E S S I O N 8 1:20 o'clock p.m. 9 GRACE JOHNS, Ph.D. 10 was called as a witness and, having been previously duly 11 sworn, was examined and testified further as follows: 12 DIRECT EXAMINATION 13 BY MS. STINSON: (Continued) 14 Q. Let me cover a couple of things I made notes of 15 last night before I forget. 16 You indicated that you had worked on, I think, 17 three separate solid waste proposals in south Florida, 18 costed them out or something, is that correct?, in your own 19 work other than on this project, you worked on some 20 projects for solid waste facilities or solid waste funding 21 mechanisms? 22 A. I can clarify that for you. 23 Q. Okay, please do. 24 A. I worked on one study for the Solid Waste Authority 25 of Palm Beach County and I looked at the financial and 208 1 economic feasibility of implementing volume-based systems 2 to finance solid waste management services in Palm Beach 3 County. 4 Q. When was that work? 5 A. That was, I think began in about November of '91 6 and ended in February of '92. 7 Q. Was there a report you submitted to the Solid Waste 8 Authority? 9 A. Yes. 10 Q. Were there similar projects to different entities? 11 A. There was a project for Broward County that looked 12 at the feasibility of re-using the waste water generated in 13 Broward County. 14 Q. And tell me when that was. 15 A. That was July of '91, thereabouts, to about October 16 of '91, thereabouts. 17 Q. And again, did you submit some kind of report to 18 Broward County? 19 A. Yes. 20 Q. And was there another project you worked on 21 involving solid waste, for a municipality perhaps? 22 A. In south Florida you are referring to; right? 23 Q. Yes. 24 A. There was a re-use feasibility study we did for 25 south Broward County, water re-use. 209 1 Q. And when was that? 2 A. About October of 1990 to about March of 1991. 3 Q. And what entity did you do that for? 4 A. City of Hollywood. 5 Q. Did you submit a report? 6 A. Yes. 7 Q. Since you began work on the project we've been 8 discussing here involving the Everglades in, what, January 9 of 1992, is that approximately correct? 10 A. We began work, it was either late January or early 11 February of '92. 12 Q. Have you worked on any other projects? 13 A. Yes. 14 Q. What other projects? 15 A. Well, let me just tell you, I recently put together a 16 presentation for the State of South Carolina. They are 17 educating their commissioners and solid waste staff in all 18 of South Carolina regarding managing solid waste and on, I 19 believe it's April 9, I'm to go on television, certain 20 educational channel, to talk about financing solid waste 21 programs, .where it will be, I'm told it will be watched by 22 about 500 people in South Carolina. 23 Q. And how long have you worked on that? 24 A. I think I started about a week ago, a week or so 25 ago on that one. I just finished developing the overheads 210 1 that will be used for the presentation. 2 Q. Other than that, have you worked on any other 3 projects since you began or since January or February of 4 '92? 5 A. I looked at a report that we did through our 6 Raleigh office having to do with the most financially 7 desirable ways of managing solid waste at the Fort Bragg 8 military installation. 9 Q. When did you -- 10 A. (Continuing) I reviewed it and I did some of the 11 analysis work. 12 Q. When did you do that? 13 A. In about November, I'm guessing here, thereabouts. 14 Q. Can you approximate for me how much time you spent 15 doing that? 16 A. Not too much, a couple days. Maybe three days. 17 Q. Anything else? 18 A. For the City of North Miami Beach, I calculated the 19 assessments to charge to houses, to homes, owners in a 20 residential neighborhood in North Miami Beach. 21 Q. Assessments for what? 22 A. Neighborhood improvements. 23 Q. And when did you do that? 24 A. About October, November, something like that. 25 Q. How much time did you spend on that? 211 1 A. Probably not even a week. 2 Maybe a week and a half, something like that. 3 Q. Anything else? 4 A. At the moment, I don't recall if -- there has been 5 no significant project other than this one that I can 6 recall. 7 Q. Have you or has Hazen and Sawyer been asked to look 8 at, in any way, how the SWIM Plan or the Marjorie Stoneman 9 Douglas Act and Settlement Agreement could or should be 10 funded? 11 A. No, we've not been asked to do that. 12 Q. Do you know whether anyone has been asked to do 13 that? 14 A. I don't know. 15 Q. You are currently working on a 20-year analysis; 16 correct? 17 A. Yes. 18 Q. And you began work on that approximately January 19 '93; is that correct? 20 A. Yes. Thereabouts. 21 Q. Well, have you submitted any reports with your 22 20-year analysis? 23 A. No. 24 Q. Have you submitted any drafts? 25 A. No. 212 1 Q. Do you have a contract for the 20-year analysis? 2 A. Yes, I'm pretty sure we've gotten that by now. 3 Q. Do you know when you got that? 4 A. Not exactly, no. 5 Q. I asked because I don't believe it's in the 6 documents you produced to me. Did you get it within the 7 last couple of weeks, to your knowledge? 8 A. I don't remember when I received it. If I received 9 it, it would have been in the files that we gave you, I 10 believe, unless it only got put in our bookkeeping files, 11 so you may or may not have that contract, and I don't 12 remember when we received it exactly. It was sometime 13 after January, if I recall correctly. 14 Q. Under that contract can you describe for me what 15 the scope of work is? 16 A. It's to conduct a 20-year evaluation looking at 17 soil subsidence and U.S. government policy with respect to 18 sugar cane -- sugar, raw sugar. And then another part of 19 that contract was meetings with economists which we 20 conducted January and February? Yes, February. 21 Q. What is the total dollar amount for the contract, 22 the 20-year analysis? 23 A. I'm trying to remember. 24 Q. You can give me a ballpark. 25 A. It's funny, I can't remember. It's about 25 maybe 213 1 at the most. I can't remember what it is. 2 Q. Who is working on that besides yourself? 3 A. I'm basically the only one working on it. I get 4 maybe a little bit of advice and perhaps I ask some 5 questions to Chris Meline. 6 Q. Do you have any subcontractors? 7 A. No. 8 Q. In the contract or in your scope of work are the 9 issues of soil subsidence and U.S. policies specifically 10 enumerated? 11 A. Could you repeat the question again, I'm sorry. 12 Q. In your scope of work for the 20-year analysis, are 13 the two issues of soil subsidence and U.S. policy 14 specifically set forth? 15 A. Yes. 16 Q. Are there any other issues such as those which are 17 specifically set forth for you to consider in your 20-year 18 analysis? 19 A. There might be. I don't remember. Those were the 20 two primary things. 21 (Whereupon, a brief recess was taken.) 22 BY MS. STINSON: 23 Q. Since you began work on your 20-year analysis, just 24 procedurally, what have you done? 25 A. I evaluated the information in the most recent USDA 214 1 sugar and sweetener outlook publication, I believe it was 2 the June or July of '92. 3 Q. Is that something that you had not had a chance to 4 evaluate in your 10-year report?