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Deposition from SWIM Challenges Case No. 92-3038, 92-3039, and 92-3040 |
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Deposition from SWIM Challenges Case No. 92-3038, 92-3039, and 92-3040 |
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INDEX
PAGE
EXHIBITS
PAGE
JOHNS' EXHIBIT No. 1......................77
2......................81
3......................90
4......................96
5.....................105
6.....................108
7.....................112
8.....................118
9.....................119
10...................119
11...................121
12...................123
13...................127
14...................128
15...................130
o0o
4
GRACE JOHNS, Ph.D.
the Deponent herein, having been first duly sworn, was
examined and testified as follows:
DIRECT EXAMINATION
BY MS. STINSON:
Q. Would you please state your name and business
address.
A. Grace Johns, Hazen and Sawyer, 4000 Hollywood
Boulevard, Seventh Floor, North Tower, Hollywood, Florida,
33021.
Q. Ms. Johns, what is your occupation?
A. Principal economist.
Q. Have you ever had your deposition taken before?
A. Yes.
Q. If there's anything I ask that you don't
understand, please feel free to tell me you don't
understand and ask me to ask a different question, or you
can say "I don't know" or "I don't understand" and that's
fine. I'm just here to try to get information.
Tell me what Hazen and Sawyer is.
A.They are an environmental engineering consulting
firm. They have engineers, scientists and economists.
Q. Where are they based?
A. Their corporate headquarters are in New York City.
Q. And how long have you been with Hazen and Sawyer?
5
A. Since June of 1990.
Q. Tell me, if you would, your educational background
starting with college.
A. I attended the University of Florida and got my --
received my bachelor's degree there in agriculture with an
emphasis in food and resource economics. I graduated in
'81.
I then attended the University of California at
Berkeley in the Ph.D. program of the College of Natural
Resources, Department of Agricultural and Natural Resource
Economics. I received my Ph.D. there in 1987.
Q. You didn't have an intervening master's?
A. No.
Q. And subsequent to 1987, what has been your
professional -- well, let me back up.
Did you work as an economist or in related fields
while you were working on your degree?
A. Yes.
Q. Tell me what you did.
A. I worked at a consulting firm, economic consulting
firm called Minimax Research Corporation where I did,
performed consulting services for primarily EPRI and
Pacific Gas and Electric looking at energy use in
agriculture.
Q. And where was that?
6
A. Berkeley, California.
Q. In Berkeley.
How long did you work for Minimax Research?
A. Hum. I have to guess. Two years. I mean I could
tell you if you gave me a minute to think about it, but I
think it was about two years.
Q. And that was sometime between --
A. '84, February of '84 to the end of '87.
Is that right?
No, no, I'm sorry. '86. End of '86. Something in
that area.
Q. Did you work anywhere else prior to receiving your
Ph.D.?
A. Yes. I worked as an independent consultant in
Berkeley and we completed a project for PG&E at that time
and we also began working on the economics of fisheries of
sport fishing in the San Francisco Bay area.
Q. Who was that for?
A. That was, we subcontracted with a company called
QED Research and that was a project for the Metropolitan
Water District of Southern California.
Q. You said you were a private consultant but
indicated that "we" worked on this project. Who was the
"we"?
A. Oh, Doug Winter. We shared an office. We worked
7
together in an office in Berkeley.
Q. And did the two of you work together on that
project?
A. On the fisheries one or the PG&E one? The PG&E
one, we worked together on.
Q. And the fisheries?
A. I worked on that on my own.
Q. What was the project for PG&E?
A. That was completing the use of energy by
agriculture in the Pacific Gas & Electric company service
area and we evaluated the energy savings from PG&E's energy
management program.
Q. Anywhere else prior to receiving your Ph.D., any
other jobs?
A. Not that I recall.
Q. And after receiving your Ph.D., what have you done?
A. Well, then I began working for QED Research.
Q. Okay. And where is that, is that in Berkeley?
A. That was in Palo Alto, California.
QED split into two companies and I began working
for Spectrum Economics, which is the same people as were
with QED Research, except one or two of the owners left
QED -- actually, they left and they kept the name QED, and
everybody else, which was the bulk of QED, became Spectrum
Economics.
8
Q. And you remained in Palo Alto?
A. Yes.
Q. And how long did you work there?
A. From 198 -- end of '87 to 19 -- to June of 1990.
Q. What projects did you work on when you were with
Spectrum?
A. Numerous projects.
Where do I begin?
Q.Tell me some of the significant projects.
A. Okay. There was work that we did for the
Metropolitan Water District of Southern California looking
at the value of recreation at the reservoirs in California.
Q. Okay.
A. We worked on some litigation -- consulting work for
a couple of farmers, one was the Siller Brothers
Corporation.
Q. What kind of work for the farmers?
A. Well, that was a divorce case where they were
trying to split up the assets of Siller company, the
corporation.
It was a very large agricultural corporation and it
was a divorce settlement that had turned into a lawsuit and
we were on the side of the husband. He was one of the
co-owners.
And we were trying to show what the firm, how the
9
firm would operate if its assets were split up; in other
words, if his wife received a portion of those assets, how
would that change the value of his corporation.
Q. Any other significant, projects you recall?
A. Yes. There was the --
Well, we did quite a bit of recreation research.
We did quite a bit of agriculturalresearch.
Now, I could go through each and every project.
Q. Well, let me, maybe I can short-circuit it
somewhat.
Can you just tell me what you mean by "recreation
research"?
A. Okay. There's an issue regarding, as you change
the water levels in reservoirs and the river flows in the
rivers, how does that affect all the different types of
recreation. There's a lot of recreation activities that go
on at the rivers and reservoirs in California.
So we did quite a bit of looking at how recreation
changes when you change water flows and reservoir water
levels.
Q. And what do you mean by agriculture research?
A. Looking at how farm operations change when there is
a shock to that farm operation.
Like one of the projects we did was for a winery.
It was a vineyard and winery and the insurance, their
10
insurance company did something to them that interrupted
their operations, and so I looked at how that interruption
affected their business, and that was for a litigation
support.
Q. And you were working for the grower of, the winery?
A. Yes, the winery.
We did quite a few projects. Another one was
looking at water use in industry.
You know, there was a drought going on at that
time, so there was quite a bit of concern in all the
different economies within California and there was quite a
bit of concern about how water is used in California. So
our company was in quite a big demand and we looked at how
the economies change as water supplies change; agriculture,
recreation and tourism and sport fishing. So we did quite
a number of different projects in those areas.
Q. In those projects, did you do, what, valuation of
non-market resources, did you perform those?
A. Yes.
Q. In doing the valuation of recreation of reservoirs,
would you consider that a valuation of a non-market
resource?
A. In recreation, yes, you could call it that.
Q. What was the methodology you used in doing that
study?
11
A. That was using a travel cost model.
Q. Did you do surveys in the area?
A. No. We --
Q. What did you do?
A. That project was a long time ago. I'm going to
have to go back in the depths of my memory and remember
exactly how we did that. But it had to do with -- I don't
recall exactly what data we used in that project, that was
back in 1987, '86, and I'd have to go back over it again.
Now, that's a non-market good in the sense that
it's not exactly a non-market good because you do pay to
get into a recreation area, you do buy goods and services,
you buy gasoline to get there. So, it's not a well-defined
market, like if you go and buy a house and/or if you go and
buy groceries.
Q. In your work in California, did you do any
valuations of, I guess, pure non-market resources?
A. No, we --
I use -- I say we. It really means I. I'm a
company person, I work for a company and whenever we refer
to what we do -- what I do, we always say we. It's one of
those corporate cultures. So I don't want you to think
that we -- we means I but I'm supported by a staff and I'm
supported by a company, so that that's why I often say we,
but you can use the two interchangeably, I and we, okay.
12
Just wanted to make that clear.
Could you repeat.
Q. It's a royal plural.
A. Could you repeat the question.
Oh, non-market goods you asked me.
Q. Yes.
A. Could you ask your question again so I know how to
answer.
Q. Did you do any analyses of what you call pure
non-market?
A. We used the results of other people's contingent
valuation studies, I've never conducted a contingent
valuation study, but they tend to be very useful when you
are doing analyses, so I've used them in my studies, in my
evaluations, used other people's.
I also participated as a support staff person in
reviewing a non-market valuation study conducted by a
non-economist during the San Francisco Bay Delta Hearings.
Q. What are the San Francisco Bay Delta Hearings?
A. That's where there's water that flows from the San
Joaquin and Sacramento Rivers flow into the San Francisco
Bay and delta, that's, to make a long story short, it was
allocating water in California.
Q. Okay. And you provided input into those hearings?
A. I just would -- yes. Yes.
13
Q.By reviewing contingent valuation studies done by a
non-economist?
A. Yes, for the California Department of Fish and
Game, I believe was the...
That was what the non-economist was working for,
was that entity.
Q. Now, then, in June of 1990 you left California and
moved to Florida; is that correct?
A. Yes.
Q. And you've been with Hazen and Sawyer since that
time?
A. Yes.
Q. Other than the project which we're here on today
involving the Everglades, tell me what other projects you
have worked on, if any, at Hazen and Sawyer.
A. Well, there was the Broward County re-use
feasibility study. I was a key team member on that study.
Q. What is that study?
A. That was looking at the feasibility of re-using all
of the waste water in Broward County as a water supply for
irrigation and industrial uses.
And so I provided the, sort of the economics and
financial information, looking at how much do these systems
cost and what are the issues that you want to look at to
evaluate economic feasibility and how much -- you know, the
14
relative costs of the different types of water re-use.
Q. Anything else?
A. No -- you mean in projects?
Q. Yes.
A. Three solid waste financial studies for three
different city -- well, two counties and a city.
I did a full cost accounting. Looked at all their
costs, capital operating, and looked at user fees, variable
rate and fixed rate user fees to charge to cover the costs
of solid waste management.
I was a member of the team that designed the water
re-use system for south Broward County, costed it out,
looked at cost efficient transmission lines, where to put
them, who to be -- who should be served by the re-use
system.
Q. I asked you when we began if you had ever given a
deposition before and you said yes. Tell me what
depositions you have given and in what matters.
A. One deposition.
Q. Okay.
A. Siller versus Siller.
Q. That was the divorce in California?
A. Yes.
Q. Did you testify at trial or hearing in that matter?
A. Yes.
15
Q. Do you know whether you were qualified as an expert
witness in that proceeding?
A. Yes.
Q. What were you qualified as an expert in, if you
recall?
A. Agricultural economics, agricultural policy.
Q. You were qualified both in agricultural economics
and agricultural policy?
A. Yes.
Q. Tell me what your experience is in terms of
agricultural policy.
A. During the trial I testified on the likely course
of U.S. government policy specifically related to the rice
program, if I recall correctly. That was many years ago,
what is it, '87, I believe, or '88, so I'm trying to
remember back that far.
And I don't remember my exact testimony in that
case regarding U.S. policy but it was a part of being able
to talk about the profitability of agriculture for this
particular grower.
Q. Have you ever worked on any matters involving bond
feasibility studies?
A. Could you be more specific.
Q. Has any of your work involved whether issuance of
bonds was feasible?
16
A. Not directly, no.
Q. Indirectly?
A. Well, indirectly, in terms of doing the financing
and the full cost accounting and estimating the costs and
looking at who pays what, but the ultimate decision on
hether to issue bonds, I have never made a recommendation.
Q. Essentially, the work that you would have done
that's indirectly related is just to determine whether a
project is feasible?
A. Yes.
Q. Have you, other than in the Siller case, have you
ever given testimony in a judicial proceeding?
A. No, not me, no. Not in person.
Q. The work that you did on financial feasibility, did
any of those projects culminate in issuance of bonds, to
your knowledge, for example for the Broward County water
re-use system or the solid waste proposals?
A. One of them did, the south Broward County job.
Q. The water re-use?
A. Yes. Our cost analysis ultimately led -- the
information was used when the bonds were written up and
issued.
Q. Have you worked on any other projects where your
analysis was used in a bond issuance?
A. I'm -- there might have been. I don't know.
17
Q. What about in developing a bond prospectus, has any
of the work you've done been used in issuing bond
prospectuses?
A. I don't know.
Q. In this proceeding today, if I refer to the
Everglades litigation, I will be referring to this
proceeding or more generically perhaps to the federal
lawsuit.
Are you familiar with the federal lawsuit and this
proceeding that you've been noticed for today?
A. I have enough familiarity to be deposed and show up
for trial.
Q. When did you first become involved or were you
first contacted with respect to the Everglades litigation
or any aspect of it?
MR. NETTLETON: Object to the form.
BY THE WITNESS:
A. You know, I don't really remember.
BY MS. STINSON:
Q. Do you remember how you first became involved or
how you were contacted?
A. I suppose when I was given a contract from the
District for litigation support, but I --
Q. Perhaps you misunderstood.
When were you first contacted by or did you become
18
involved with the South Florida Water Management District
with respect to this Everglades SWIM Plan?
A. I don't really understand the question.
Q. It's real simple. I'm just trying to find out when
you and how you first became involved in doing an economic
impact assessment.
A. Okay, I can answer that.
Q. All right.
A. We received a RFP -- actually we found the ad of
the RFP in the newspaper and we answered the ad.
Q. "You" being Hazen and Sawyer?
A. Hazen and Sawyer. And we were selected by the
District and we began the study, the economic impact study.
Q. Do you recall when the ad was in the newspaper?
A. It might have -- late November.
Q. Of?
A. (Continuing) About.
Q. '91?
A. Of '91. That's an approximate time, date.
Q. Were you personally involved in responding to the
RFP; did you develop the proposal?
A. Yes. Yes. We developed the proposal and submitted
it.
I wrote the proposal, submitted it, put our
qualifications in a package and sent it off to the
19
District.
Q. You were the lead person in doing that?
A. Yes.
Q. After you submitted your proposal, what happened,
just procedurally? Were you contacted by the District?
Did you have an interview? Did you provide additional
information? What happened?
A. We were contacted by the District and told that we
were selected to do the project, to perform the project.
Q. Was there no contact between the time you submitted
the proposal and you received notice that you had been
selected?
A. There was no verbal or written contact that I
recall.
Q. How were you told that you received the contract?
A. I was not in the office at the time. Pat Davis at
Hazen and Sawyer, who's a vice president, received a phone
call from the District saying that we were selected to
perform the study.
Q. And then what?
A. Then we received -- if I recall correctly, we
received a letter, formal letter from the District and then
we went into contract negotiations.
Q. Were you involved in the contract negotiations?
A. Yes.
20
Q. You, personally?
A. Yes.
Q. With whom did you negotiate at the District, who
all was involved?
A. Rhonda Haag, Dick Rogers, Carl Woehelke.
Q. Are all these people with the District?
A. Yes.
I believe Paul Muncy was there.
It was in a room with a bunch of people around the
table, that's what I remember the most.
Q. And all your negotiation was done at this one
meeting?
A. Yes.
Q. Was anyone from Hazen and Sawyer there in addition
to yourself?
A. Soddie Shaboney (phonetic).
Q. And who is that?
A. An associate with Hazen and Sawyer.
Q. You called yourself a principal economist with
Hazen and Sawyer; what does that mean, are you a
shareholder, a partner?
A. I'm part of the bonus pool, from a financial
aspect.
Q. Do you recall when the negotiation meeting was?
A. It was probably in January.
21
Q. And what were the issues at that meeting, what did
you negotiate?
A. We went through the scope of work, each task in the
scope of work, and I gave them an explanation how we would
perform each task. Then we talked about how much it would
cost to perform each task.
Q. And did you negotiate on the cost?
A. Yes.
Q. And the result of that meeting, then, was a written
contract, I presume?
A. Yes.
Q. Who do you report to at the Water Management
District for this contract, the contract to do the economic
impact assessment, or who did you?
A. Currently I'm reporting to Sally Kennedy.
Q. And previously?
A. Peter Rhoades, and then before that Paul Muncy.
Q. Since when have you reported to Sally Kennedy?
A. About September of '92.
Q. And prior to that time it was Pete Rhoades?
A. Yes.
Q. From when to when did you report to him?
A. About March through September, and then Sally would
have started October to the present.
Q. And Paul Muncy, from the beginning until March?
22
A. Yes.
Q. Who do you report to internally at Hazen and
Sawyer, what are the lines of authority there?
A. Peter Robinson.
Q. Is he locally based?
A. He's in Hollywood. He's the senior vice president.
Q. What role has he played in this project?
A. I report to him on the progress of the project.
Q. Does he review your work?
A. Yes.
Q. Has he taken an active role in terms of
recommending changes or approaches?
A. No.
Q. And who at Hazen and Sawyer works with you on the
project, are there some other economists?
A. That have worked with me on this project?
Q. Yes.
A. There's Chris Meline, Norman Pearson.
Q. Are both of those people still working on the
project?
A. No.
Q. Is either of them?
A. No.
Q. For what period of time did Chris Meline work on
it?
23
A. From January through October -- through September,
and he provides some input and advice from time to time
since then.
Q. Okay. And Norman Pearson?
A. About June. From about --
I'm sorry, I believe it was from like February
through July.
Q. Is he still with Hazen and Sawyer?
A. No, he was never with Hazen and Sawyer. We
subcontracted with him.
Q. Who was he with?
A. He was an independent consultant.
Q. An economist?
A. Yes, an agricultural economist.
Q. Did he have his own firm or --
A. No. I don't know.
Q. How did you come to use Mr. Pearson?
A. I wanted a team member with direct experience in
implementing best management practices in agriculture and
he was referred to us.
I had actually met him before and had had some
verbal contact with him from time to time, and he had some
very good experience with working with BMPs and citrus and
drainage type issues, so I felt that he would be a good
team member.
24
Q. Who recommended him to you, was it someone at the
District, do you recall?
A. Somebody at the University of Florida recommended
him to me. I don't remember which professor did.
They were impressed with him. They had seen his
presentation on his thesis and they recommended him, which
was a coincidence because I also knew of him and knew
that -- of his background.
Q. Mr. Meline is with Hazen and Sawyer; is that
correct?
A. Yes.
Q. Is he still?
A. Yes.
Q. Did you use any other subcontractors on the
project?
A. We did hire a woman named Lisa Meday. We needed
some quick GIS work.
Q. GIS being?
A. Geographic information system work. And she
provided some limited consulting work in terms of making
pictures of the EAA in terms of where the production is in
the EAA from the computerized records of the Dade County --
I'm sorry, the Palm Beach County property appraiser's
office.
Q. Was that essentially a data collection activity?
25
1 A. No, it was a data management activity. It was very
2 limited, but we did hire her as a subcontractor for a few
3 hours. I think it was 40 hours.
4 Q. What kind of quality review system is there at
5 Hazen and Sawyer that your work has been subject to?
6 A. We have a quality control system whereby one senior
7 officer reviews not just the end product, but is constantly
8 being updated about the progress, and that person in this
9 case was Peter Robinson.
10 Q. What is his background?
11 A. He is a civil engineer and has an MBA. He has 30
12 years of experience, most of it in south Florida in terms
13 of civil and environmental engineering and finance.
14 Q. What is his experience in finance?
15 A. He evaluates the cost of, for example, building
16 waste water treatment plants or closing landfills, opening
17 landfills, and has done a bit of work related to issuing
18 bonds and, I'm not familiar with every financial study that
19 he's done but he is a real world guy. I mean, this is how
20 much it costs, let's figure out who's going to pay for it
21 and how it's going to get paid for in looking at the
22 benefits and the costs.
23 He's a results kind of person. Let's figure out
24 how much it's going to cost and who's going to pay for it
25 and make sure it's equitable to everyone so everyone's
26
happy.
Q. Am I correct in assuming that Mr. Pearson was
retained to work on the cost and effect of BMPs?
A. Yes.
Q. Did he do anything outside of that area?
A. He did a little bit of work, just a very little bit
regarding the mills, raw sugar mills, very little, couple
hours of work, but all of it was related to BMPs, the vast
majority of it.
Q. Do you have any experience in the use of BMPs in
agriculture?
A. Yes.
Well, what do you mean by "BMPs" specifically? You
mean in general or specific BMPs?
Q. In general.
A. In general, yes.
Q. What is your experience?
A. Well, the experience is mostly related to
California agriculture. How to reduce the amount of
electricity used in agriculture and how to conserve water
in agriculture.
Q. The contract that you entered into subsequent to
your negotiation, your RFP and the response and the
negotiations that we've been talking about was a contract
to perform an economic impact assessment; is that correct?
27
A. It was to evaluate the economic impacts of the
Marjorie Stoneman Douglas Act and the Settlement Agreement
between the United States and the South Florida Water
Management District.
Q. At some point you were also retained, were you not,
to do a benefits study?
A. Yes.
Q. The benefits of the Marjorie Stoneman Douglas Act
or what, what was it a benefits study of?
A. It was the benefits of preventing injuries to the
Everglades. We looked at three levels of injuries.
Q. That's low, medium and high basically?
A. Yes.
Q. How did you come to be retained to do that study,
the process again?
A. Paul Muncy called me up, this was during the
project, I guess it was in February, mid-February perhaps
of '92.
Q. Okay.
A. (Continuing) He called me up and asked me about
evaluating the benefits. At that time he wanted -- was
asking me about evaluating the benefits of the act and
settlement agreement. And he asked me how much -- how long
it would take and how much it would cost to do something
like that.
28
Q. Did he say why it was he was checking, what
prompted him to find out?
A. No.
Not that I recall.
Q. I'm sorry, go on with your description.
A. Well, I answered him. I said it would take two
years and $2 million.
Q. And his response?
A. He says: Well, what can you do for $50,000 in four
months?
Q. And your response?
A. I told him about how, what is often done or what is
done frequently is you do an initial assessment of what the
value of the benefits are for a particular non-market
situation, you know, a situation where you have a problem
and you want to figure out, well, this is an environmental
problem, we want to save -- we want to fix the problem,
what are the benefits of fixing this problem.
You can do a full-blown study to estimate the
benefits and/or you can begin, at least begin with looking
at what other studies of other resources, other economic
values of other non-market goods.
So it's a matter of saying let's take a look at the
values that have been estimated for other similar, and I
use that loosely, natural resources, in terms of preventing
29
damages to those resources.
And so I told him that that is a possibility. If
they wanted to get started thinking about valuing the
benefits of restoring the Everglades, then an initial study
of the nature that we conducted would provide some insight
into the value of protecting the Everglades and also, in my
mind, start to educate the people of Florida regarding how
to provide a method of comparing the value of a natural
resource, a non-market natural resource to the value of
goods and services that we take for granted that we buy and
sell in marketplaces all the time.
Q. Tell me, after this conversation you had with
Mr. Muncy in approximately February, what happened
procedurally, did you enter into a contract, what occurred?
A. He asked me -- I was going to be giving a
presentation to the Everglades Funding Council in early
March, if I recall correctly. The date would have been in
about early March. I was to give a presentation to the
Everglades Funding Council regarding the progress of the
economic impact evaluation, which we already had a contract
for.
And he asked me, Paul asked me during that phone
conversation, it might have been that phone conversation or
subsequent one, to put together at the end, after I talk
about the progress of the economic evaluation, to talk
30
about valuing the Everglades. In other words, talk about
the process by which one would try to value the prevention
of injuries to the Everglades.
So I did that. And we did a flip chart
presentation. And I came to that part of the presentation
where we talked about looking at the benefits. And we went
through the whole thing, well, as much as we could in, I
don't know, 15 minutes or however long I took up there.
And at the end of the presentation --
And I talked about doing the $2 million two-year
study, and I talked about doing the $50,000 four-month
study and they seemed to be very interested, they were
very, very interested.
Q. This is the Funding Council?
A. The Funding Council.
And so from that Funding Council, the Funding
Council decided to do the $50,000 four-month study.
Q. Was an RFP done for that study? Did they
advertise?
A. I don't know.
Q. You didn't respond with a proposal to an RFP; is
that correct?
A. Correct. If I recall correctly, yes.
Q. And ultimately you entered, by "you entered," Hazen
and Sawyer entered into a contract with the Water
31
Management District to do the benefits valuation; correct?
A. Yes.
Q. The $50,000 four-month version of the benefit
study?
A. Yes.
Q. Who was the principal author of that study?
A. I don't understand the question.
Q. The benefit study, were you the principal author of
the benefits study?
MR. NETTLETON: Object to the form.
BY THE WITNESS:
A. I don't understand the question.
BY MS. STINSON:
Q. On the impact assessment, were you the principal
author of that document, the economic impact assessment
report?
MR. NETTLETON: Object to the form.
BY THE WITNESS:
A. Define author.
BY MS. STINSON:
Q. Okay, maybe that's the problem.
Did you actually write, either on a computer or
otherwise, the text that is in the impact assessment
report?
A. Yes. I wrote the vast majority, probably 99
32
percent -- well, let's say 95 percent of the economic --
valuation of the economic impacts.
Q. And on the benefits side, who performed that
function; did you?
A. I performed editing but the text was written by the
sub -- our subconsultant, NRDA.
Q. What person with NRDA, do you know?
A. Richard Carson.
Q. And where is NRDA?
A. La Jolla, California.
Q. And what is it?
A. It's called Natural Resource Damage Assessment,
Inc. My understanding, I'm going to tell you what my
understanding is, because I haven't seen, you know, legal
proof of any of this, but my understanding is it's a
consortium of professors in the area of natural resource
economics and one of their, or maybe it's their main line
of business is estimating the value of natural resource
damages.
Q. Is Richard Carson a professor?
A. Yes.
Q. Where?
A. University of California, at La Jolla -- no,
San Diego, I'm sorry, UC, San Diego.
Q. How did you come to subcontract the work to this
33
organization or this person?
A. We were very -- our staff was very busy at that
time with many different projects and the District had
asked if they could have the report completed by, I don't
know, end of June or whenever it was, so I wanted to put a
team member on our team that was uniquely qualified to do
that type of an analysis and Richard Carson was by far the
best choice of anyone in the country to do this.
Q. Did you know him from California?
A. Yes.
Q. What dealings had you had with him previously?
A. He was a graduate student at Cal Berkeley in the
same department that I was in, agricultural and natural
resource economics.
Q. So he got his Ph.D. in the same thing you got yours
in; is that correct?
A. Yes.
Q. Was it your own personal experience with Richard
Carson that caused you to call him and see if they would do
this work?
A. He wrote a book, him and the other author's name
escapes me at the moment, but, on valuing non-market goods.
Q. What book is that?
A. What's the title?
The exact title escapes me at this time of the
34
morning but it had to do with valuing non-market goods,
specifically using the contingent valuation method.
Q. You mentioned a minute ago that you felt he was
uniquely qualified to do this kind of study. Why did you
believe that?
A. Because he's done quite a bit of work in contingent
valuation in valuing non-market goods. I was familiar with
his work, I've read his work and I was impressed with it.
Q. Are there other people in the country who also do
that kind of work?
A. Yes.
Q. Is there anything that set him apart from other
people?
A. Well, I could have hired -- we could have asked
Michael Hanneman to help us or other people, other -- a few
other natural resource economists.
Q. Who is Michael Hanneman?
A. Actually my understanding is Michael Hanneman might
be one of the co-associates with NRDA but I don't know that
for a fact.
Actually he is. The NRDA is actually a consortium
of professors who do this kind of thing so we basically
hired NRDA, but I contacted Richard Carson because I knew
him.
Q. Why did you mention Michael Hanneman's name?
35
A. Well, he's also someone who's very experienced and
is also qualified to do such a study.
Q. Did you mention his name because he's a known
person in the field or just somebody you know?
A. He's a known person in the field and he's someone I
know.
Q. Other than the benefits study, the $50,000
four-month job, to your knowledge, has the South Florida
Water Management District done any additional work on the
benefits side?
A. Not to my knowledge.
Q. Do you know whether there's any agreement or
understanding to do additional work on the benefits side?
A. Not that I know of.
Q. Who, in addition to Mr. Carson, Professor Carson
and yourself as editor worked on the benefits report?
A. Nick Flores.
Q. And who is he?
A. He is with NRDA.
Q. Is he also a professor?
A. Not that I know of.
Q. Do you know what his background is?
A. I knew it at one time.
I don't recall it right now.
Q. What role did he play?
36
A. I spoke with him from time to time over the phone
regarding the study. His role -- well, he obviously must
have worked on the job because he knew so much about it.
You know, we talked a lot and we talked about what they
were doing and what I thought they ought to be doing, in
editing of the report.
Those are the two people I spoke with the most,
Richard Carson and Nick Flores over at NRDA, and I imagine
Nick did participate in working on the job, in this
particular job.
Q. Was it your understanding that he reported to
Richard Carson?
A. Yes.
Q. Was Richard Carson the person in charge of the
project for NRDA, to your knowledge?
A. Yes. Yes, he was.
Q. Do you recall approximately when you contracted
with the District to do the benefits side?
A. Do I remember when?
Q. Yes, approximately.
A. March maybe. I don't recall the exact date.
Q. After you entered into the contract for the impact
assessment, tell me what you first did in terms of
beginning to work on the project, what information you
gathered or people you talked to.
37
A. We began to compile a list of information sources,
potential information sources. We began to talk about our
relationship -- what type of relationship, if we should go
forward and communicate with the Florida Sugar Cane League
and the Florida Sugar Cane Cooperative.
Q. When you say "we began to talk," is that you and
the people at the District or you folks internally at Hazen
and Sawyer?
A. Internally at Hazen and Sawyer. How to move
forward on the project.
And so we then began to make contact with the
Florida Sugar Cane League and the cooperative and any other
grower in the EAA who was interested in talking to us.
Q. Did you speak with anyone else, any other possible
sources of information, experts in the field?
A. We talked to people at IFAS. We talked to people at
USDA. We talked to the Palm Beach County property
appraiser's office, the Hendry County property appraiser's
office. We talked to people at the Palm Beach County
Planning Department. We talked to someone at Donnelley
Marketing Information Services.
Q. Why did you talk to people at Donnelley Marketing?
A. At the beginning of a project you don't know -- you
have an idea of the quality of the data but what you do is
you try to get data from every possible information source
38
that you can, and that was one of the potential information
sources that we could use.
Actually it did turn out that we did get that
information, but Donnelley Marketing Information Service
collects information on businesses that they sell to
private people for marketing purposes primarily, and they
happen to have a pretty extensive data base of information
on individual businesses all over the country. In addition
to that they will provide summary statistics by zip code on
businesses and demographics.
Q. Who did you talk to at IFAS?
A. Jose Alvarez, Bill Boggess, Bob Emerson.
Q. Where is Mr. Emerson?
A. He's in Gainesville.
Q. Is he with the University of Florida?
A. Yes.
Q. Anyone else?
A. Oh, yes. I'm trying to remember them all. Tom
Scheuneman, David Mulkey, Del Botcher, John Holt, Leo
Polopolus, John Reynolds.
Q. Are these all people with IFAS or University of
Florida?
A. They're with both.
Q. Both. They're all with both?
A. Um hum. My understanding is if you work for IFAS you
39
work for UF.
Mr. Coale, C o a l e.
If I leave anybody out, they're in the report. In
the report we list everybody we talk to.
Q. Did you talk to all these people in the preliminary
stages just as source of information?
A. Yes.
Q. Did you talk to them individually or did you have
meetings with some or all of them?
A. We spoke with them individually.
We did give a presentation toward the end of the
project in about June to a group of the professors and a
couple of the graduate students in the Ag Econ department
at University of Florida.
Q. And you also spoke with people at USDA?
A. Yes.
Q. Do you recall who?
A. Ron Lord, Annette Clausen. That's all I remember at
this time.
Q. Then after you did this preliminary I guess contact of
potential sources, what was your next step in conducting
your analysis?
A. We started zeroing in on where the information was and
we began to collect the information.
Q. What types of information?
40
A. The USDA publication, "Sugar and Sweetener
Situation Outlook," I believe we relied on the March 1992
report. We received the statistical, is it called U.S.
Statistical Sugar Abstract.
So basically we began collecting data. Published
data.
We began asking people questions, mainly to make
sure that the data was what we thought it was representing,
you know. We talked to people who either compiled the data
themselves and to make sure we understood, you know, what
each of the costs represented, what the prices represented,
you know, what everything meant that was published and so
that's what we did there.
Q. At some point I presume you also had to decide what
methodology you would use to do this assessment; is that a
fair statement?
A. The methodology was already spelled out in the
statement of work.
Q. And that was something you put together to submit
20 the proposal?
A. Yes.
If you look at the RFP, the RFP was pretty well
written, the scope of work there, so we went by that. It
was a pretty good scope of work that was already written by
the District, so we went by that.
41
Q. Well, at the time you wrote the proposal did you
know or had you decided that you would use the FLIPSIM
model?
A. No. We only knew we were going to use model farms.
The statement of work that's in the contract,
that's a compilation of what the District had already
written in their RFP and then Hazen and Sawyer, expounding
on that and becoming more specific with how the study would
be done.
Now, exactly, you know, what kind of computer
spreadsheets or models would be used had not been
determined until after we -- as far as I can remember, it
was not until we began working on the project.
Q. But at the time you did the proposal you had
determined to do it by means of model farms; is that
correct?
A. We had in, yes, in our contract we had already
talked about model farms, if I recall correctly.
Q. When in the process did you decide then what
computer model to use to determine the effects?
A. Proposal early on in the project. I don't recall
whether we decided to use FLIPSIM but there was some
discussion between Chris and myself over what would be the
best thing to do, whether we should do our own spreadsheet
model or should we use a model that's already been
42
developed to -- and we had decided -- we ultimately
decided, or I ultimately decided to use the FLIPSIM model.
Q. How did you make that decision?
A. Well, it was based on, we didn't want to re-invent
the wheel. In other words, we wanted to spend a lot of
time talking to the growers, and we wanted to spend a lot
of time developing the baseline economic projections and we
wanted to spend time looking at the BMPs and we didn't want
to spend a lot of time making models.
So we decided, or at least I decided to go ahead and
use the FLIPSIM because it was already there, we wouldn't
have to do any programming, we would just use that.
Q. How did you even hear about it, I guess, and did
you discuss that particular model with anybody?
A. Yes. I was talking to Bill Boggess, he was one of
the people that we initially contacted, and I was talking
to him about my decision that I had to make, whether or not
we go ahead and just do the spreadsheet model and develop
that and spend time on that or if there was any models out
that, already out there that we could use, and he had
mentioned he has used the FLIPSIM model in his evaluation
of the impacts, the financial impacts to dairy farmers
north of Lake Okeechobee.
Q. Had you heard of FLIPSIM before he mentioned it?
A. No.
43
Q. Had you known Professor Boggess from the University
of Florida?
A. Yes.
Q. The contract that you originally entered into
called for a 20-year study; did it not?
A. Yes.
Q. And at some point that was modified to be a 10-year
study?
A. Yes.
Q. Why was that decision made, what led up to the
decision to change it from 20 to 10?
MR. NETTLETON: Object to the form.
BY MS. STINSON:
Q. You can answer.
MR. NETTLETON: You can answer, if you know.
BY MS. STINSON:
Q. If you understand the question, you can go ahead
and answer.
A. You want to know why it went from a 20-year to a
10-year?
Q. Right. You got it.
A. All right, during the project, I wanted to spend a
lot of time on the first 10 years and from an economist's
perspective, economists feel comfortable forecasting out
five years and 10 years. You know, after 10 years it's
44
like well, you know, you don't feel as confident because
there's a lot of things that can happen. There's a lot of
things that can happen in the first 10 years but there's
also a lot of things that can happen in the second 10
years. So I wanted to put something together that we felt
very, very comfortable about in terms of the economic facts
and I wanted to get it down from 20 to 10 years, I didn't
want to spend a lot of time on the second 10 years.
So I called Paul Muncy and I ran it by him. I
believe I spoke to him, and he said it was okay, he didn't
have a problem with that, so then they amended the contract
to go from 20 years to 10 years.
Q. Do you know whether he discussed that decision with
anybody else at the District or whether that was just his
decision?
A. I don't know. I don't recall.
Q. Were you aware at the time you discussed that that
potential financing plans for the project would last 20
years?
MR. NETTLETON: Object to the form.
BY THE WITNESS:
A. Now that's a potential financing plan borrowing the
money and paying it back over 20 years, but it's not the
only one, it's one of many different financing plans, so,
no, it really wasn't a consideration to me.
45
BY MS. STINSON:
Q. What was the original contract completion date for
the impact assessment?
A. I don't remember. I don't recall. It was four
months -- supposedly -- I think it was like four months
from January. Maybe it was due in May, May 31.
Q. And do you recall what the original --
A. (Continuing) Or maybe it was April 31, I don't
remember.
Q. Do you remember what the original completion date
was for the benefits side?
A. No. I can only give you a guess, ballpark. Maybe
it was due June 31st -- 30th, rather. There is no 31st.
Q. Did you at some point seek and receive an extension
on the impact assessment?
A. The economic impact, yes.
Q. What led up to your decision to request an
extension?
A. We were trying to get information from the growers
and we were talking to them and that was taking up some
time, so that took up a lot more time than I wanted it to
but, you know, what can you do.
So I asked if we could have an extension so that we
could have time to incorporate the responses of the growers
in the EAA.
46
Q. And how many times was it extended, once or more,
do you recall?
A. It was more than once. Maybe it was twice. I
don't remember exactly.
Q. And when was the work under that contract
completed?
A. The entire contract was completed at the end of
September.
Q. Does that include for the benefits side as well?
A. That one was -- okay, we finished the bulk of our
contract by the time we had the governing board meeting in
August. The economic evaluation was completed. It was
completely finished. And so what we reported was the final
conclusions.
But then what happened was the District went
through each and every item in our contract to make sure
that we fulfilled everything in our contract and there were
some things that were not fulfilled and so we spent a
couple months finishing up what they thought we needed to
do to completely fulfill the agreement in the contract. So
you'll see a couple more chapters in the report from the
original, I think it was -- or the final report, there's
now a contract completion report and that has everything in
it. It represents, you know, the totality of the work that
was done from January through September.
47
Q. Is that true for both the benefits and the impact
portions?
A. Yes. Yes.
Q. What role did, if any, did Professor Lonnie Jones
play in your impact assessment?
A. About the -- I don't know when it was in this
project, but he began -- we met with him in a meeting, we
had a meeting with the Justice Department economists, the
Justice Department hired some economists.
Q. Who did you meet with?
A. Lonnie Jones and Ron Lacewell and someone else who
I don't recall at the moment his name, but I didn't
really -- I only met him once at one of the meetings.
Q. Was he someone from Texas A&M also?
A. No, he was from another university.
Q. Was it Dr. Bromley?
A. Yes.
Q. Do you recall when you met with those folks?
A. It was during the project. I don't know exactly
what month it was, to be honest with you.
Q. Why did that meeting happen?
A. The, I think it was Paul Muncy or Pete Rhoades, I
don't recall which one, I think it was Paul. See, he
wanted me to be open with all sides, you know. Like the
Justice Department and the growers, you know, we were
48
supposed to be very open and anybody who wanted to see what
we were doing was welcome to come and see what we were
doing.
And so the Justice Department, the economists hired
by the Justice Department came and met with us at our
office and we showed them what we were doing.
Q. Was that before you had a draft of the report?
A. I don't remember. It was when we had something
down on paper -- or maybe it wasn't --
I don't remember exactly. I can only tell you that
we met with them on about two occasions.
Q. Did you also talk with some of them by telephone
throughout the process?
A. Lonnie would call me from time to time
Q. A couple times a month or every week, do you
recall?
A. No, it wasn't that often. It was from time to
time. Not very frequently.
MS. STINSON: Why don't we have lunch and switch
gears.
(Whereupon, at 12:00 noon a luncheon recess was
taken.)
(Afternoon session continued on following page.)
49
A F T E R N O O N S E S S I O N
GRACE JOHNS, Ph.D.
the Deponent herein, having been previously duly sworn, was
examined and testified further as follows:
DIRECT EXAMINATION
BY MS. STINSON: (Continued)
Q. This is really switching gears for a little bit
here. You produced to us, you and your counsel, a number
of documents as well as 23 computer disks which contain
portions of your files, I presume. What I'm going to ask
you about right now are some questions regarding those
disks just for informational purposes so we can figure out
what's on there to look at them.
Do you know whether the files on those disks
contain only your latest version of the report or would
they also contain, you know, previous drafts of work?
A. To the best of my knowledge, those are every single
analysis we did from the beginning of the project. In
other words, it includes information that was -- it
includes spreadsheets and model runs that were done
throughout the project.
Q. Well, if something were revised, would you have
supplanted, would you have replaced the pre-existing
information or would there be a different version of it, do
you know?
50
A. There might be a little of both in there. I tried
to keep it as up -- I wanted it to reflect as much as
possible, you know, during the study, the final results.
So we tried to do that but I don't think we did -- we might
have old files in there that we started to use but we never
finished using or we didn't need them anymore and they
might still be in there.
Q. But if you had something that went through various
iterations, it would only be the last one that would be
contained on the disks?
A. The one with the most recent date on it, which
should be what's in the report.
Q. There are apparently four disks that are a backup
of files in one or more directories, in order to restore
those files we need to know the name of the directory.
A. Oh, really.
MR. NETTLETON: Object to the form if that's a
question.
MS. STINSON: The question isn't out yet.
BY MS. STINSON:
Q. The question is: What is the name of the directory
that these four are backup to or backup of files to; do you
know?
A. You'd have to show me the file names, the files.
Q. There are several files that have the same name
51
except for the extension, for example SOD11.FM3, SOD11.WK3,
et cetera. And SOD11.XLS. Does the XLS file contain the
same information as the Lotus 1-2-3 files?
MR. NETTLETON: Object to the form.
BY THE WITNESS:
A. I don't -- I don't know. It depends on the file.
BY MS. STINSON:
Q. Would it contain the same as the Excel file; do you
know?
A. Excel file was probably produced first and then it
was read into Lotus 1-2-3 and perhaps more things got done
to that file so it might be a little different than the XLS
file.
The WK3 file might be different than the XLS file
but it probably supersedes the XLS file.
The FMT file is the format file. If you want to
print it or anything, if you want to print it. My
understanding is it produces a FMT file, so that's just a
format file for the spreadsheet.
Q. What is the .ALL extension, do you know?
A. That sounds like it would -- we have a .ALL in
there. That's an extension for what, the alls subroutine,
.ALL? You'd have to show me the exact file name. Really,
from my knowledge of spreadsheets .ALL is an alls file
which is a format file. That's all I can tell you.
52
Q. I am going to show you what I believe contain
printouts of the directories of the four files that are the
backup files to see if that will help you tell me what
directory (handing).
A. Okay. So what I'm reading here is that there's a
file called BACKUP.004 and it's got about 343,000 bytes. I
do not recall a BACKUP.004. I do not recall a file that I
ever named or that Chris ever named called BACKUP.004. I
don't know where that came from.
Q. Okay.
A. Same with CONTROL.004. I've never seen it before.
I don't know what that is. I don't know what these two
files are, I've never seen them.
Q. There are four pages?
A. They're all the same. Never seen BACKUP.002 or
CONTROL.002.
Let me back up a minute. We provided you all with
models that we used or we didn't use, we just happen to
have had, collected during the project. Now those models
might have file names in them called BACKUP.002 or
CONTROL.002 and BACKUP.004 and CONTROL.004, in which case
may be relevant to what we had, but in which case I don't
know anything about them.
Q. Would there be any way for you to check?
A. Yes, all of these.
53
I could show them to Chris Meline, see if he knows
what they are.
Q. There are files of the same name such as
LETP1S1A.OUT and the same .XLS. Is the OUT file the
FLIPSIM output and is the XLS your summary in Excel?
A. That's close. The answer is no, not exactly.
The output file is probably from -- is the
FLIPSIM.OUT. The .OUT is from the FLIPSIM. The Excel file
probably read that output file into Excel.
Q. In the XLS?
A. Yes.
Q. What is the AGSYS budget generator disk one?
Here's another page (handing).
A. This looks like it's the budget generator. That's
what it is. The AGSYS budget generator. Yes, that's what
this is, these are the files from those.
Q. What is that?
A. That is the vegetable budget generator.
Q. How does it need to be loaded into a computer, do
you need some kind of user's manual?
A. Yes. To the best of my knowledge.
In other words, you are trying to get it to run;
right?
Q. Right.
A. I don't know if we gave you enough for you to run
54
it. I thought we did. But apparently you all are having
trouble and I don't know if I can help you in this
deposition, tell you how to run it.
Q. Oh, no, I'm not asking you to do that. Who in your
shop actually runs?
A. Chris Meline was the one that loaded it up. So I
didn't load it up myself.
Q. And that's the budget generator for fruits and
vegetables?
A. That's my understanding AGSYS is the one. We do
have a budget generator for vegetables and I imagine this
is what it's called, AGSYS budget generator.
Q. Do you know what the AUTO123.WKS worksheet is?
A. This looks like the mechanical harvesting model
where it evaluates the cost of mechanical harvesting versus
hand- cut harvesting of sugar cane.
Q. Did you use the results of those?
A. We used this model.
Q. Where does it show up in your report?
A. When we talk about the hand-cutting versus
mechanically harvesting cane, in one of the chapters,
probably the baseline economic projections for sugar cane
chapter.
Q. What type of output does this spreadsheet generate,
what's the product?
55
A. The cost of mechanically harvesting sugar cane
versus the cost of hand-cutting sugar cane.
Q. Per ton or?
A. It could be -- yeah, it could be per ton, per acre.
Q. Back on the vegetable, the AGSYS budget generator,
where in your report is that used?
A. Where we talk about the vegetables in the report,
the baseline economic projections is where we use it.
Q. Do you recall what tables that, the AGSYS
information, is found in?
A. The tables that display the costs of growing
vegetables are in this in the report under -- I don't
exactly recall what page number it's in.
Q. And that's straight out of the AGSYS budget
generator?
A. Pretty much. We do quality control, make sure
everything makes sense.
Q. And are there any tables that the AUTO123.WKS
output is put into, the mechanical versus hand harvesting?
A. We didn't specifically put that in our tables. We
just evaluated it and found that there wasn't much
difference in the costs.
Q. Let me give you (handing) this, the READ ME
document has to do with the RIMS II program; does it not?
A. I don't recall.
56
Q. Did you run the RIMS II program?
A. I didn't. Chris Meline ran it.
Q. Did you in large part rely on Chris Meline to do
the computer operation and running of the programs?
A. For the RIMS II, I asked him to extract the
multipliers, the multipliers that we needed for the study.
Q. Did you tell him which multipliers to extract?
A. Yes.
Q. Do you know whether region one refers only to the
Palm Beach multipliers?
A. I don't recall.
Q. Did you obtain multipliers for any other regions or
counties other than Palm Beach?
A. For Florida. State of Florida multipliers.
Q. But no other individual counties?
A. No.
Q. How does the Modify program work, what does that
program do; is that --
A. Which model are you talking about?
Q. I'm not sure. Did you use a program called Modify?
A. There's a lot of sub -- there's a lot of sub --
Q. Let me show you?
A. -- files that are used automatically.
Is this in relation to RIMS? Yes, it looks like it
is. Is this, what you just have given me, in relation to
57
RIMS?
Q. It's my understanding it is.
A. I didn't specifically use Modify.
Q. Did somebody? Did Chris?
A. If it was necessary to use in order to extract the
multipliers for Palm Beach County, then he would have used
it.
Q. And you are not sure whether that was necessary or
not?
A. Correct.
Q. What software did you use to perform the RIMS
analysis?
A. I asked Chris to extract the multipliers and he
gave me those multipliers and then I put them into our
spreadsheet model.
Q. What computer files, whether output, Lotus or Excel
were created using RIMS data?
A. I can tell you which ones they are. There are two
of them. Let's see if I can remember the exact file names
of them. They're pretty easy to find I thought in the
disks. It's called like SUM ECON.
Q. Would it help, I believe these are the printouts of
the directories, would it help?
A. Sure, if you give them to me to look at I can help
you.
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These files like 9910.XLS, they probably have the
population files. They have information on specific
properties in the EAA or specific businesses in the EAA.
You'll note them by the fact that they're so big. Like
this one has got 1.3 million bytes.
Okay. The file that has the summary for the EAA
area is SUM2ECON.WK3, to the best of my knowledge, at this
time. Let me find you the one for Florida. The one for
Florida has -- it's kind of just like SUM2ECON but it's got
FL in it and I can't find it. In fact, the SUM2ECON.WK3,
to the best of my knowledge, that's the one but it might be
slightly -- have a slightly different name than that, but
look there first.
What you are going to find is if you showed me the
report I could tell you how to find -- there are files that
look just like those detailed tables in the report, so if
you find those, and they have names like SUM2ECON.FL or
things like that, those are the ones that are the exact
replicas of the tables in the report. And on here I cannot
find the one that has FL in it of the Florida one, from
what you've given me.
Q. That's okay.
Which industry codes from the STUBS.PRN file of IO
industry classifications on the RIMS II disks did you use
for your analysis?
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A. Repeat the beginning of that again.
Q. Which industry codes from the STUBS.PRN file?
A. Okay. Now, whether or not they were taken for this
particular STUBS file I do not know but I can tell you that
the multipliers that we used are in the report. We tell
you exactly which ones we used in the report. So if you
look in the report --
Q. For example, RIMS code 11.0703, would that be --
A. What crop name does that correspond to, does it say
there?
Q. New conservation and development facilities
construction.
A. Yes. That came from the RIMS information.
Q. And you are telling me that the industry codes are
found somewhere in your report; are thry in a table?
A. The ones that we used. The industry codes should
be in there.
Q. Would they be listed in a table?
A. Yes.
Q. Or just sort of throughout --
A. Yes.
Q. In a table?
A. Yes, in a table.
Q. There are some survey files I guess on your
disks. Is SURVEY-S.HWD for sugar cane?
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A. Say the name of the file again.
Q. SURVEY-S.HWD then there's a V.HWD, a SD.HWD and
then there's also a SURVEY3.HWD?
A. .HWD, that sounds like something that would be a
WordPerfect file or something like that. We have the
survey results in a spreadsheet but I don't recall those
names.
Q. While he's looking let me ask you another one.
Are any of the spreadsheets linked, in other words,
LINKSTR.WK1?
A. To the best of my knowledge, the spreadsheets are
not linked.
Q. What is LINKSTR.WK1?
A. How big is it? Do you have the size of the file?
Q. Here's the survey ones, go back to that (handing).
A. Okay, those particular files, I don't know what
they are without looking at them.
Q. Is this something, again, Chris Meline would have
run?
A. I don't know. I'd have to look at what's inside
the files.
Q. Here's some more survey files. Can you tell us
what's in these?
A. I can answer these questions better if you showed
me what the files looked like in terms of a printout of
61
them. I'll do the best I can.
SURVEY.WK3 could be the results of the survey of
businesses in the EAA, but without actually looking at the
file itself I can't tell you for sure. Chances are that's
what it is.
Q. And do you not recall what the LINKSTR file is?
A. Like I said, if you showed me the file I could tell
you exactly what it was but trying to go from there, I can
only give you my best guess.
I don't see the file that you are referring to on
this list --
Oh, I see it.
I would only be guessing. If you had even just a
printout of one page of it I could tell you what it was.
If you just printed out the first, you know, you know, A 1
through, you know, E 100, if you could just print that out
for me and you showed it to me, I could tell you exactly
what it is, but I can't for sure tell you what's in that
particular file.
Q. Maybe we'll try that for tomorrow.
Here's something I do have a printout of. What is
the origin of the file SUBSIDEN.WK3?
A. Oh, good, you gave me a printout. This is much
better now.
This is a model that tracks how thick the organic
62
soil is in certain areas of the EAA.
Q. Who developed the model?
A. I did.
Q. Based on?
A. The soil subsidence study, 1988 soil subsidence
study put out by the Palm Beach County Soil Conservation
Service and an IFAS publication authored by George Snyder,
soil scientist at IFAS in Belle Glade.
Q. I'll get into the substance of that after a bit.
Here, again, are printouts of two files,
SUCROSE.WK1 and SUGAR.WK1. Do those refer to sucrose and
sugar yields for sample parcels by yield belt that is
collected by the Palm Beach County appraiser?
A. This information is the sucrose content and yield
on fields in the EAA provided to me by the Florida Sugar
Cane League by yield belt.
Q. Not by the county property appraiser's office?
A. This was provided to us by the Sugar Cane League.
Q. What is the difference between the two files,
between the sugar file and the sucrose file?
A. The sucrose file is the percent of sugar -- sucrose
in the cane and the yield file is the tons per acre.
Q. So sucrose will tell us how much sucrose per ton of
cane, for example?
A. It will tell us the amount of sucrose in the
63
cane.
Q. Per ton or per acre or what's the measurement?
A. Oh, this measurement is, it's percent sucrose --
Q. So it would have --
A. -- in the cane. It's probably an average.
Q. Per amount of cane though, not per acre?
A. That was what was measured in the field -- not in
the field but --
My understanding of these numbers as they were
communicated to me is this is percent sucrose in the cane
grown on a specific field in a specific year.
Q. And the sugar is the net tons of cane per acre?
A. The net -- it's the -- tons or the net tons, I
don't remember which, of sugar cane per acre.
MS. STINSON: Short break.
(Whereupon, a brief recess was taken.)
(Discussion off the record.)
BY MS. STINSON:
Q. Switching gears again.
Somewhere somebody found this old document of
yours. I believe it's of yours. Something called A
Handbook for Economic Analysis of Coastal Recreation
Projects. Is that you who worked on it, Grace Jones,
listed as author?
A. Yes.
64
Q. When was that done?
A. That was done at the University of Florida in
1980, '81.
Q. Were you still a student at the time, an
undergrad?
A. Yes.
Q. What was the project and how did you become
involved?
A. I was a research assistant with Dr. Milon and I
helped him work on the project.
Q. Other than that handbook, do you have any other
published documents, reports or articles?
A. Published, how do you mean?
Q. Well, let's cover all the bases here.
Have you given any professional papers at seminars
or symposia?
A. Yes.
Q. What have you given?
A. You want to know the papers that I've presented?
Q. Right.
A. Okay. Well, there's a number of them, I'm just
trying to go through them in my hand. You want to know all
of them, okay.
There was a -- I don't know where to begin.
I've given a number of presentations regarding
65
solid waste management.
Q. And are these at professional symposia or seminars?
A. Are you talking about at like at the American
Agricultural Economics Association?
Q. Right. That sort of thing.
A. I gave a paper there regarding my dissertation, a
paper that I wrote off my dissertation at one of the
meetings around '86, I'm guessing as an approximate year,
at the American Agricultural Economics Association annual
meetings in August.
Q. What was the topic --
A. It was --
Q. -- of your paper?
A. -- a fisheries management paper.
Q. Okay.
A. That was one of them.
The other one was also at the AJAE, I'm sorry, the
other one was at the AAEA meetings, it was a student paper
back in 1981.
Q. Did that relate to your handbook that you just --
A. No, that related to the spiney lobster industry
in the Florida Keys.
Q. Any other presentations, papers presented?
A. Presented at like the AAEA meetings.
Q. Right. Any kind of professional association.
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