Grace Johns Ph.D.


Deposition from SWIM Challenges

Case No. 92-3038, 92-3039, and 92-3040
 
  STYLE:
   CASE:              92-3038, 92-3039, 92-3040
   REPORTER:  
   DATE:             

   NAVIGATION:

 

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Division of Administrative Hearings

Department of Administration, State of Florida

 

SUGAR CANE GROWERS COOPERATIVE OF
FLORIDA, INC., ROTH FARMS, INC.,
and WEDGWORTH FARMS, INC.,
and
FLORIDA SUGAR CANE LEAGUE, INC.,
UNITED STATES SUGAR CORPORATION,
and NEW HOPE SOUTH, INC.,
and
FLORIDA FRUIT AND VEGETABLE
ASSOCIATION, LEWIS POPE FARMS,
W.E. SCHLECHTER & SONS, INC., and
HUNDLEY FARMS, INC.,

Petitioners,

v.

SOUTH FLORIDA WATER MANAGEMENT
DISTRICT,

Respondent,

and
MICCOSUKEE TRIBE OF INDIANS OF
FLORIDA, the UNITED STATES OF
AMERICA, FLORIDA DEPARTMENT
OF ENVIRONMENTAL REGULATION, and
FLORIDA WILDLIFE FEDERATION,

Intervenors.

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Case Nos. 92-3039
92-3038

        

 

 

DEPOSITION OF:

 

GRACE JOHNS, Ph.D.

 

TAKEN:

 

 

 

Pursuant to Notice Instance
of Sugar Cane Growers
Cooperative of Florida, Inc.,
Roth Farms, Inc., and
Wedgworth Farms, Inc.,

 

DATE:

 

March 29, 1993

 

TIME:

 

Commencing at 11:00 a.m.

 

PLACE:

 

 

AA1 Parliamentary Reporting
3511 West Commercial Boulevard
Ft. Lauderdale, Florida

 

BEFORE:


 

ELLEN N. COHEN, RPR
Stenographic Court Reporter
and Notary Public - State
of Florida at Large

 

 


2

APPEARANCES

HOPPING BOYD GREEN & SAMS
123 South Calhoun Street
Post Office Box 6526
Tallahassee, Florida 32314
BY:    DONNA STINSON, ESQ
                -and-
        CAROLYN S. REAPPLE, ESQ.

Attorney for Petitioners Sugar Cane
Growers Cooperative of Florida, Inc., Roth
Farms, Inc., and Wedgworth Farms, Inc.

PEEPLES, EARL & BLANK
One Biscayne Tower
Suite 3636
Two South Biscayne Boulevard
Miami, Florida 33131
BY:    RICK J. BURGESS, ESQ.

Attorney for Petitioners Florida Sugar Cane
League, Inc., United States Sugar
Corporation., and New Hope South, Inc.

POPHAM, HAIK, SCHNOBRICH & KAUFMAN
4000 International Place
100 S.E. Second Street
Miami, Florida 33131
BY:    PAUL L. NETTLETON, ESQ.

Attorneys for the Respondent

UNITED STATES DEPARTMENT OF JUSTICE
ENVIRONMENT & NATURAL RESOURCES DIVISION
GENERAL LITIGATION SECTION
P.O. Box 663
Washington, D.C. 20044-0663
BY:    KEITH E. SAXE, ESQ.
                       -and-

UNITED STATES ATTORNEYS OFFICE
155 Miami Avenue - Suite 600
Miami, Florida 33130
BY:    ROBERT ROSENBERG, ESQ.,
                          Assistant U.S. Attorney

Attorneys for Intervenor USA

 

 


3

A P P E A R A N C E S: (Continued)

STATE OF FLORIDA
Department of Environment Regulation
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, Florida 32399-2400

BY:    KEITH C. HETRICK, ESQ.,
                        Assistant General Counsel

Attorney for Intervenor Florida Department
of Environmental Regulation

ALSO PRESENT:    RONALD T. LUKE J.D., Ph.D.
                                ANDREW BERNSTEIN

I N D E X

PAGE
DIRECT EXAMINATION BY MS. STINSON ......................... 4
 

E X H I B I T S

 

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..................................... 124
13..................................... 127
14..................................... 128
15..................................... 130
 
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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.


58

 

 

    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?


59

 

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?


60

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.


66