DIVISION OF ADMINISTRATIVE HEARINGS DEPARTMENT OF ADMINISTRATION, STATE OF FLORIDA SUGAR CANE GROWERS COOPERATIVE OF CASE NOS. 92-3038 FLORIDA, a Florida agricultural 92-3039 cooperative marketing association; ROTH 92-3040 FARMS, INC.; and WEDGWORTH FARMS. INC., and FLORIDA SUGAR CANE LEAGUE, INC.; and UNITED STATES SUGAR CORPORATION, and FLORIDA FRUIT AND VEGETABLE ASSOCIATION, LEWIS POPE FARMS, W. E. SCHLECHTER & SONS, INC., and HUNDLEY FARMS, INC., Petitioners vs. SOUTH FLORIDA WATER MANAGMENT DISTRICT, an Agency of the State of Florida, Respondent, and THE UNITED STATES OF AMERICA, MICCOSUKEE TRIBE OF INDIANS, THE FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION, THE FLORIDA WILDLIFE FEDERATION, THE FLORIDA AUDUDON SOCIETY and THE SIERRA CLUB, Respondent-Intervenors. _________________________________________/ DEPOSITION OF: DR. F. LARRY LEISTRITZ TAKEN: March 16, 1994 VOLUME 3 Accurate Stenotype Reporters, Inc. DEPOSITION OF: DR. F. LARRY LEISTRITZ TAKEN AT THE INSTANCE OF: United States of America Respondent-Intervenor DATE: Wednesday, March 16, 1994 TIME: Commenced at 8:00 a.m. Concluded at 2:10 p.m. LOCATION: 315 South Calhoun Street Tallahassee, Florida REPORTED BY: ANITA M. PEKEROL, CCR, RPR, CP, CM. Notary Public in and for the State of Florida at Large. APPEARANCES: REPRESENTING THE PETITIONERS SUGAR CANE GROWERS COOPERATIVE OF FLORIDA, Florida agricultural cooperative marketing association; ROTH FARMS, INC. and WEDGEWORTH FARMS, INC.: CAROLYN S. RAEPPLE, ESQUIRE Hopping, Boyd, Green & Sams 123 South Calhoun Street Post Office Box 6526 Tallahassee, Florida 32314 REPRESENTING RESPONDENT-INTERVENOR UNITED STATES OF AMERICA: KEITH E. SAXE, ESQUIRE United States Department of Justice 601 Pennsylvania Avenue Northwest Room 879 Post Office Box 663 Washington, D.C. 20044 ALSO PRESENT: Lonnie L. Jones, Ph.D. Ronald D. Lacewell Accurate Stenotype Reporters, Inc. I_N_D_E_X _ _ _ _ _ WITNESS PAGE _______ ____ F._LARRY_LEISTRITZ __ _____ _________ Direct Examination by Mr. Saxe 214 CERTIFICATE_OF_REPORTER 363 ___________ __ ________ E_X_H_I_B_I_T_S _ _ _ _ _ _ _ _ DEPOSITION_EXHIBITS: __________ ________ NUMBER DESCRIPTION PAGE ______ ___________ ____ 13 Format for a table 283 14 Memorandum from Ann Orzech to Eric Schubert, 7-28-93 285 15 Handwritten memorandum from Ann Orzech to Eric Schubert, 7-28-93 287 16 Handwritten notes, 7-30-83 289 17 The Agricultural Crisis as it Affects Rural Communites, by Gerald A. Doeksens 296 18 Curriculum vitae of F. Larry Leistritz 347 19 Adequacy of the SWIM Plan's Cost Benefit Analysis 357 Accurate Stenotype Reporters, Inc. 214 1 (VOLUME 3) 2 3 P_R_O_C_E_E_D_I_N_G_S _ _ _ _ _ _ _ _ _ _ _ 4 - - - 5 The following deposition of DR. F. LARRY 6 LEISTRITZ was taken on oral examination, pursuant to 7 notice, for purposes of discovery, for use as evidence, 8 and for such other uses and purposes as may be permitted 9 by the applicable and governing rules. Reading and 10 signing is not waived. 11 - - - 12 Thereupon, 13 DR. F. LARRY LEISTRITZ 14 having been previously duly sworn, was examined and 15 testified further as follows: 16 DIRECT EXAMINATION (Continued) 17 BY MR. SAXE: 18 Q Good morning, Professor Leistritz. We're 19 in day two of the continued deposition. The same rules 20 apply today as yesterday. 21 In your testimony yesterday, we talked at 22 one point about the public facilities and services 23 impact analysis that might have been done by RPC. 24 I believe, if I recall correctly, you 25 indicated that except to the extent of your work on Accurate Stenotype Reporters, Inc. 215 1 things like the function for deriving changes in 2 population from job changes, that you didn't have any 3 involvement in the analysis that RPC might have done 4 about public services and facilities impacts; is that 5 correct? 6 A Yes. 7 Q I believe you, also, indicated that you 8 didn't have any opinions about whatever methodology they 9 ultimately used in any such analysis; is that correct? 10 A That's correct. 11 Q And that you had not reviewed results of 12 analysis that they might rely upon at trial; is that 13 correct? 14 A Not at this point. I have not yet been 15 asked to review the public service and fiscal impact 16 results. 17 Q And you did not have any opinions on 18 whether or not any conclusions that might have been 19 reached were sound or unsound; is that correct? 20 A That's correct. 21 Q With respect to population impact 22 assessment, and by that I mean inmigration and 23 outmigration from and to the EAA caused by 24 implementation of the SWIM Plan or alternatives, you, 25 also, indicated that you had limited involvement in some Accurate Stenotype Reporters, Inc. 216 1 of the component pieces of that analysis? 2 A Yes. 3 Q And you indicated, I believe, that you had 4 a role in determining the distribution of employment 5 impacts from STA construction between local and 6 non-local workers? 7 A Yes. 8 Q That you had had some obvious role in the 9 determination of the relationship between jobs and 10 population loss insofar as the function was concerned? 11 A Yes. 12 Q And that you had had some involvement in 13 the choice of RIMS multipliers for the secondary 14 employment impact; is that correct? 15 A Yes. 16 Q But is it correct that you did not have any 17 other involvement in whatever methodology RPC may be 18 using for estimating population impacts from the SWIM 19 Plan or alternatives? 20 A I think that is correct. I have not looked 21 at their spread sheet model that has been assembled. I 22 have not reviewed that in its entirety. What you 23 summarized, I think, sounds to me, essentially, correct, 24 yes. 25 Q Do you have any other opinions about the Accurate Stenotype Reporters, Inc. 217 1 methodology that may be being used by RPC to estimate 2 population impacts? 3 A The question is beyond the dimensions that 4 we have already covered. 5 Q And, again, those would be the leakage from 6 the STA construction issue, the function for determining 7 changes in population from changes in jobs and the 8 choices of the RIMS multipliers for secondary employment 9 impacts? 10 A Those were my major areas where I was 11 involved, so those would be the areas where I would have 12 a basis for having opinions, yes. 13 Q And are you familiar with the methodologies 14 that are being used by RPC in actual analysis that 15 they're doing on population impacts? 16 A I have had the opportunity to review 17 different memorandums that outline some dimensions of 18 what they were doing. Some of those were things that we 19 identified as exhibits yesterday. So, to that extent, 20 to the extent that I have had an opportunity to review 21 some of the dimensions, I probably have opinions about 22 the appropriateness of what is being proposed. 23 On the other hand, I have not seen the 24 final model in its entirety. 25 Q Just referring, then, specifically, to Accurate Stenotype Reporters, Inc. 218 1 those exhibits that fit that category, looking at 2 Exhibit Number 2, if you would -- 3 A Okay. 4 Q -- that is your February 6th memo to Ron 5 Luke -- 6 A Sure. 7 Q -- the section on local employment and 8 construction of STAs -- 9 A Exactly. 10 Q -- and the selection of multipliers for EAA 11 analysis -- 12 A Yes. 13 Q -- does that describe all of your opinions 14 concerning those two issues as they would relate to 15 RPC's analysis of population impacts? 16 A I would say that summarizes my opinions on 17 those two issues, yes. 18 Q As far as the function for evaluating 19 changes in population based on changes in employment, if 20 you would look at Exhibit 11 -- 21 A Yes. 22 Q -- does the first page of Exhibit 11 23 express your views on the function that was referred to 24 by you in the third, fourth, fifth, sixth, seventh, 25 eighth, through the end of this document on Exhibit 11? Accurate Stenotype Reporters, Inc. 219 1 A Yes. 2 Q Did you submit any other information to 3 RPC, either in writing or orally, on the issue of the 4 function that is referenced in Exhibit 11? 5 A Not that I recall, no. 6 Q Going back to the population impact 7 assessment that RPC may be doing, the three elements 8 that you were involved in, then, were the leakage on STA 9 construction, the population jobs function and the 10 choice of the RIMS multipliers, correct? 11 A Correct. 12 Q And those are referenced in Exhibit 2 and 13 Exhibit 11? 14 A Correct. 15 Q To your knowledge, are there any other 16 materials that you have provided to RPC, either written 17 or non-written, that provide information about your work 18 on those areas of their analysis? 19 A No. 20 Q And that would include any materials that 21 would discuss your opinions concerning those aspects of 22 the analysis? 23 A Perhaps I should make sure that I properly 24 understand the question. Over time, for instance, I 25 have provided to RPC copies of many articles, references Accurate Stenotype Reporters, Inc. 220 1 and the like which bear on the issues that we have just 2 discussed; selection of multipliers, local versus 3 non-local employment, relationship between job loss and 4 population change. Many of those or some of those, of 5 course, are referenced in these documents. But I think 6 these exhibits that we have mentioned really summarize 7 the work, the opinions and so on specific to this 8 situation. 9 Q With respect to the issue of population 10 migration response in a declining area or where there 11 are employment impacts, yesterday we discussed Exhibit 12 Number 10, your article with Alan Schuler on threshold 13 population levels? 14 A Yes. 15 Q Are there other articles that you have 16 identified or provided to RPC that pertain to this issue 17 in particular? 18 A The population change relative to 19 employment change. For instance, the Exhibit 11 20 memorandum then references three other documents, each 21 of which attempts to be a rather extensive review of the 22 literature relative to economic demographic models, 23 relative to socioeconomic resource impact development. 24 And third is a book dealing with farm financial crisis. 25 Basically, impacts of responses to the farm economic Accurate Stenotype Reporters, Inc. 221 1 situation in the midwest. 2 These works and works referenced and 3 reviewed in them represent a relatively large body of 4 literature dealing, generally, with the topic of the 5 relationship between employment change, and population 6 change and these kinds of issues. 7 Q Would the article by Gerald Doeksen, 8 D-O-E-K-S-E-N, titled The Agricultural Crisis as it 9 Affects Rural Communities, be included within that set 10 of materials? 11 A That would, I'm 99 percent certain, be one 12 of the works that would have been referenced, probably 13 in the Murdock and Leistritz book. That would be an 14 example of the kind of articles that were reviewed and 15 referenced in some of those works. 16 Q Another article that has been provided with 17 your production was by Janet Ayres, A-Y-R-E-S, yourself 18 and Kenneth Stone, titled Rural Retail Business 19 Survival: Implications for Community Developers. 20 Would that be another article that you have 21 identified or provided to RPC on this issue? 22 A Yes. And that was included, I'm sure, in 23 our document production. 24 Q Yes, it was. 25 Another article that was included in the Accurate Stenotype Reporters, Inc. 222 1 production was by yourself and a number of other 2 authors, and it is titled Revitalizing the Retail Trade 3 Sector in Rural Communities: Experiences of Thirteen 4 North Dakota Towns. 5 Would that be another one of these 6 articles? 7 A Yes. 8 Q Are there any other articles that are, in 9 your mind, of special significance in relation to an 10 effort to estimate population impacts in the EAA from 11 the implementation of the SWIM Plan or alternatives? 12 A I guess the three that I referenced in 13 Exhibit 11 represented my view of some salient works. 14 Q And there are no others that come to mind 15 as particularly significant? Let me rephrase that. 16 You have indicated that those referenced 17 works in Exhibit 11 anthologize or, to some extent, 18 reference other works. But besides the ones that we 19 have named here today, are there any that you would 20 characterize as particularly relevant to the analysis of 21 the EAA population impacts? 22 A I don't believe so, no. 23 Q In addition to Exhibit 11, are there any 24 other memoranda or conversations that reflect your 25 opinions in this area of population migration response, Accurate Stenotype Reporters, Inc. 223 1 other than the articles that we have just described? 2 A I don't believe so. 3 Q On the issue of critical minimum market 4 sizes for retail and consumer service establishments, 5 Exhibit 10 is your article on threshold population 6 levels? 7 A Right. 8 Q Are there any other materials that you have 9 provided to RPC or identified for RPC, specifically, 10 relevant to this aspect of RPC's analysis? 11 A Earlier in the project, we had talked about 12 gathering data on sales per retail establishment, 13 basically, from the Florida Statistical Abstract and the 14 Census of Retailers, as another item of information for 15 possible use in the analysis. 16 MR. SAXE: Could you read that answer back, 17 please? 18 (Requested portion read.) 19 BY MR. SAXE: 20 Q When you say we talked about gathering 21 data, who had those discussions? 22 A Okay. These were discussions between 23 myself, Eric Schubert and -- myself and Eric Schubert, 24 primarily. 25 Q All right. Accurate Stenotype Reporters, Inc. 224 1 A On or about July of 1993. 2 Q And was data gathered on sales per 3 establishment? 4 A That's my understanding, yes. That's my 5 understanding, that data was gathered on sales per 6 establishment. 7 Q Did you gather that data? 8 A No. 9 Q It was gathered by RPC? 10 A That was my understanding. 11 Q Do you have an understanding of who at RPC 12 was involved in that? 13 A Eric Schubert, and possibly others. 14 Q What was your understanding about the use 15 to be made of that data? 16 A We had, basically, not discussed all 17 dimensions in the analysis in great detail. 18 Q What was your understanding, based on the 19 discussions that you did have? 20 A The thought was that if our impact analysis 21 included, for instance, estimates of changes in sales 22 volumes, then the sales per establishment might be of 23 interest in regard to estimating the numbers of 24 businesses that might be lost. That was the rationale 25 for suggesting that that would be a useful piece of Accurate Stenotype Reporters, Inc. 225 1 information for Mr. Schubert to gather. 2 Q Did you express the opinion that it would 3 be a useful piece of information for Mr. Schubert to 4 gather? 5 A Yes. 6 Q You had indicated in your testimony 7 yesterday, when we were talking about the business 8 impact analysis that may be performed or may have been 9 performed by RPC, that you had given verbal comments to 10 Dr. Luke and Dr. Schubert, and interview notes after 11 your EAA trip; is that correct? 12 A Yes. 13 Q Would this, also, be additional information 14 that you gave to Dr. Schubert -- 15 A Yes, sure. 16 Q -- in that area? 17 A Yes. 18 Q You indicated that, otherwise, you had only 19 worked on the function for deriving business impacts 20 from employment impacts, correct? 21 A Okay. 22 Q Are there any other areas of the business 23 impact analysis work that RPC might have done or be 24 doing that you have interacted with? 25 A Not really. Those are, really, the major Accurate Stenotype Reporters, Inc. 226 1 things. 2 Q Beyond your conversation with Dr. Schubert 3 before data might have been gathered on sales per 4 establishment, did you have any subsequent exchanges or 5 interactions with RPC on this issue? 6 A I think I'll ask you to repeat the 7 question, sir. 8 Q Besides the conversation that you just 9 referred to with Dr. Schubert about gathering data on 10 sales per establishment from the Florida Statistical 11 Abstract and the Census of Retailers, which, as I 12 understand it, was before any such data might have been 13 collected; is that correct? 14 A That is a difficult question, in the sense 15 that our work on the project has been marked by some 16 starts and stops. We started probably in September of 17 '92, as I recall. Some analysis was done in late '92. 18 In fact, we were meeting about a year ago in regard to 19 deposition. We stopped for a number of months, and then 20 started, essentially, again, in the summer of '93, with 21 some additional analysis. 22 So, certain data were collected, I'm sure, 23 in the fall of '92. Updated and additional information 24 would have been collected in the summer of '93. 25 Q So, then, in fact, I believe you indicated Accurate Stenotype Reporters, Inc. 227 1 that you had had conversation with Dr. Schubert around 2 the summer of '93 or July of '93? 3 A Yes. 4 Q So, at that point, did you understand that 5 some data may have been collected on sales per 6 establishment from those sources, the Florida 7 Statistical Abstract and the Census of Retailers? 8 A My recollection on those particular data 9 was that those were data that were yet to be collected. 10 Drawn together, as it were. 11 Q Were to be collected. In other words, had 12 not yet been collected? 13 A That's my recollection. 14 Q And then you, also, indicated that you 15 think that some further collection or some initial 16 collection was done by somebody at RPC after that 17 conversation? 18 A I believe I should say that I really don't 19 know. Really, in terms of meeting with Mr. Schubert in 20 July of '93, we discussed quite a range of data items. 21 We made extensive lists of things that were to be done, 22 checked on and the like. I cannot really say with 23 certainty what the disposition was of all of those 24 items. 25 Q Do you have any further understanding or Accurate Stenotype Reporters, Inc. 228 1 information about the collection of this data, other 2 than what you have just indicated to me arose in your 3 July '93 conversation with Dr. Schubert? 4 A In general, it is my understanding that, 5 basically, the impact analysis did not really pursue 6 that particular approach, that particular data set or 7 approach. And that, in turn, is based on the type of 8 information that is available. The information 9 available from the RIMS multiplier analysis did not 10 really lend itself to the sales per establishment 11 approach to changes in numbers of businesses. 12 Q Now, the RIMS multipliers would have been 13 used to derive the predicate changes in employment from 14 the implementation of the SWIM Plan, correct? 15 A Yes. 16 Q The data on sales per establishment, I 17 believe you indicated, would have been used or was 18 discussed for its potential to be used in determining 19 business impacts? 20 A Yes. 21 Q By that, is it correct to say changes in 22 the number of businesses because of implementation of 23 the SWIM Plan? 24 A Yes. 25 Q So, when you say that in your understanding Accurate Stenotype Reporters, Inc. 229 1 this type of data on sales by establishment from the 2 Florida Statistical Abstract and the Census of Retailers 3 was not used in the methodology employed or being 4 employed by RPC, do you mean not used for business 5 impact analysis? 6 A Yes. At the point where we talked about 7 gathering sales per establishment, this would be prior 8 to final decisions about a number of dimensions of the 9 impact analysis, the multipliers to be used and the 10 like. And depending on the decisions made with regard 11 to one stage of the analysis, then that logically 12 affects the approaches that may be relevant at 13 subsequent stages. 14 MR. SAXE: Could you read that answer back, 15 please? 16 (Requested portion read.) 17 BY MR. SAXE: 18 Q Can you elaborate on that for me? 19 A Well, I guess I'm not quite sure what the 20 question is. 21 Q Okay, let's take it maybe one step at a 22 time. 23 In your understanding, the data on sales by 24 establishment, that you discussed with Dr. Schubert in 25 July of '93, has not formed any part of the analysis, Accurate Stenotype Reporters, Inc. 230 1 the methodology being used in the analysis, by RPC? 2 A Yes, I believe that is correct. 3 Q Why is that the case? Let me rephrase 4 that. 5 Why do you understand that no use is being 6 made of this type of data in their analysis? 7 A Because of the nature of information, the 8 aggregate nature of information, that is obtained from 9 the RIMS multiplier system really would not lend itself 10 to using the sales per establishment data. 11 Q When you say would not lend itself, what 12 does that mean? 13 A Would not be compatible or congruent. 14 Would not be compatible or congruent with using sales 15 per establishment data to try to estimate number of 16 business closings. 17 Q Let me clarify. Did you express any 18 opinions to RPC, either in writing or orally, about what 19 methodologies should or should not be used in estimating 20 business impacts in the EAA? 21 A I think what I might have expressed might 22 have been in the form of data sources to explore, and 23 alternatives that might be considered. 24 Q And what were those opinions? 25 A They would be summarized in some of the Accurate Stenotype Reporters, Inc. 231 1 memoranda, I guess. As I said, lists of data sources to 2 explore, things like that. 3 Q Have we reviewed those as exhibits? 4 A I think we have. 5 Q In the deposition today and yesterday? 6 A To a large extent, I think. 7 Q Could you just draw my attention to which 8 ones describe your opinions about the appropriate 9 sources of data and methodologies for business impact 10 analysis? 11 A As I say, in some of the conversations and 12 memoranda, we had lists of data sources to explore, that 13 sort of thing. I don't know that those really 14 constitute opinions about business impact. We may be 15 having a problem with semantics here. 16 Q Would the selection of data sources for use 17 in analysis be part of the methodology for performing an 18 analysis, in your opinion? 19 A Yes. 20 Q Can you refer me to specific documents that 21 would discuss that aspect of the methodology for 22 business impact analysis? 23 A Once again, I would say that my comments or 24 input on business impact analysis could probably best be 25 described as a few suggestions about possible data Accurate Stenotype Reporters, Inc. 232 1 sources to explore, or the possible alternatives that 2 might be considered, as opposed to laying out a proposed 3 methodology. 4 Q So, would it be safe to say that these were 5 fairly preliminary discussions? 6 A Yes. That would be a very good 7 characterization. 8 Q These were back in around the summer of 9 last year? 10 A Yes. 11 Q Do you have any opinions about the 12 methodology that RPC should have used in doing business 13 impact analysis? 14 A I guess I'm not quite sure I understand the 15 question. 16 Q Do you have any opinions about whatever 17 methodology RPC may have been or are using to do 18 business impact analysis? 19 A Well, I think the memo item Exhibit 11 20 really represents opinion about the relationship that 21 they developed relating to job change, business change. 22 And it is my opinion that that is consistent with the 23 literature in the area. 24 Q If this question is asked and answered, 25 forgive me, I don't intend to. But have you provided Accurate Stenotype Reporters, Inc. 233 1 any other opinions to RPC about the appropriate 2 methodology for the business impact analysis, other than 3 the preliminary suggestion of data sources to explore, 4 the conversation with Dr. Schubert in July about 5 gathering data on sales per establishment and what is in 6 Exhibit 11? 7 A We had, also, discussed the notes from 8 interviews conducted in the EAA. And I think that would 9 summarize my input in that area. 10 Q Do you know what methodology RPC is using 11 to estimate business impact in the EAA? 12 A Well, if we're defining business impact in 13 this case as the number of businesses that might close, 14 then it is my understanding that the material in Exhibit 15 11 would summarize what they're doing. 16 Q Have you reviewed other material that 17 references or contains RPC's analysis of business 18 impacts, other than that referenced in Exhibit 11? 19 A I don't believe so. 20 Q Have you had other conversations with RPC 21 about the results of their business impact analysis? 22 A No. 23 Q Do you know what conclusions RPC may have 24 reached about business impacts in the EAA in terms of 25 quantities? Accurate Stenotype Reporters, Inc. 234 1 A No. 2 Q Do you have any opinions about any 3 conclusions that they might have reached, whether 4 they're correct or not? 5 A I think I'll ask you to restate the 6 question. 7 Q Well, you have indicated that you don't 8 know what business impacts that they have come up with; 9 is that true? 10 A Right. 11 Q So, then, it stands to reason that you 12 don't have any opinions about whether their conclusions 13 are sound or not in that regard? 14 A Since I don't know what the conclusions 15 are, it would probably be premature for me to have an 16 opinion about their soundness. 17 Could I propose a two-minute break? Long 18 enough to get another cup of coffee? 19 MR. SAXE: Certainly. 20 (Brief pause.) 21 MR. SAXE: Back on the record. 22 BY MR. SAXE: 23 Q With respect to property value impact 24 analysis, you worked on the function that you understand 25 is being used to determine property value impacts based Accurate Stenotype Reporters, Inc. 235 1 on changes in employment? 2 A Yes. 3 Q Is that function all that is required for 4 deriving property value impacts, in your opinion? 5 A I guess as I indicated in Exhibit 11, it 6 seems to me that the function is a reasonable approach 7 to relating changes in employment to changes in property 8 values. 9 Q How does one calculate the changes in 10 property value using that function? Does the function 11 yield a dollar number change in property values when you 12 plug in the change in employment? 13 A The application, as I understand it, is 14 illustrated in the tables that are included as part of 15 Exhibit 11. And as we see then at the top of each 16 column, there is percent of jobs lost. And then as we 17 track that down, we see, in the next to the last item in 18 the column, the proportion of assessed valuation 19 remaining, et cetera. 20 Q So, would it be correct to say that the 21 function yields a percentage or a proportion change? 22 A Yes. 23 Q And then that proportion change is 24 multiplied by some multiplier to get the actual dollar 25 change? Accurate Stenotype Reporters, Inc. 236 1 A That's my understanding, yes. 2 Q What is the multiplier that it is 3 multiplied with? 4 A And, again, this could best be termed, I 5 think, speculation. My assumption or speculation is 6 that this percentage would be multiplied by a value 7 which represents the baseline property valuation, to 8 which then the property valuation corresponds to zero 9 percent job loss. 10 Q When you prefaced your answer with 11 reference to speculation, by that do you mean that you 12 don't know for a fact just how RPC may be using this 13 function to actually calculate? 14 A I have not reviewed the model in its 15 entirety, so I do not know for a fact just exactly how 16 this function is applied within the overall modeling 17 system. 18 Q So, then, you don't have an opinion about 19 any methodology that RPC may be using beyond the actual 20 derivation of the function itself; is that correct? 21 A Yes. At this point in time, I don't feel I 22 have the basis to have an opinion beyond that. 23 Q And you don't have an opinion, therefore, 24 about their application of the full methodology for 25 calculating property value impacts? Accurate Stenotype Reporters, Inc. 237 1 A Right. 2 Q Then it is, also, true, is it not, that you 3 don't have an opinion about any results that they may 4 have obtained by applying the methodology? 5 A Correct. 6 Q Changes in local tax or local tax impact 7 analysis that RPC may be performing, I believe you 8 indicated yesterday that you have not had any 9 involvement in that analysis? 10 A Right. 11 Q Do you have any opinions about local tax 12 impact analysis that you have provided to RPC, either in 13 writing or orally? 14 A No. 15 Q Do you know whether RPC is doing social 16 impact analysis involving other elements, like crime and 17 domestic violence? 18 A I don't know to what extent they're 19 pursuing those areas. 20 Q Have you had any involvement in any 21 analysis of crime impacts? 22 A No. 23 Q By RPC? 24 A No. 25 Q So, you don't know whether they're Accurate Stenotype Reporters, Inc. 238 1 performing any empirical analysis of crime impacts? 2 A No, I don't know. 3 Q Do you have any opinions about 4 methodologies or a methodology that should be used to 5 analyze crime impacts in the EAA? 6 A No. 7 Q How about domestic violence impacts? 8 A No. 9 Q No opinions? 10 A No opinions. 11 Q Same for self-esteem impacts? 12 A Right, no opinions. 13 Q How about family impacts? 14 A No, no opinions. 15 Q Is it correct that you have been involved 16 in some study of farmer bankruptcies in the midwest? 17 A Yes. 18 Q Could you tell me something about those? 19 A In North Dakota, I was in charge of, 20 project leader, for two studies of people leaving 21 farming during the 1980s. We did a survey of people 22 leaving farming in 1986, and a second one in 1989. And 23 these represented interviews with well over 200 24 households who had left farming, all of whom had left 25 farming within five years before the time that we did Accurate Stenotype Reporters, Inc. 239 1 the interviews. 2 Some percentage of those, as I recall, 3 between 10 and 20 percent, had actually gone through 4 bankruptcy procedures. But, in any event, they all 5 could be characterized as people who left farming for 6 reasons other than retirement during this period of the 7 1980s. 8 Q And this was in a particular area in the 9 midwest? 10 A North Dakota. 11 Q Have you had any discussions with RPC about 12 the analysis that you performed concerning the 13 bankruptcies during that period in North Dakota? 14 A Yes. 15 Q Okay. 16 A In general terms, I am sure I provided the 17 RPC with copies of the two research reports and at least 18 one journal article summarizing the findings from those 19 studies. For that matter, the book, the Farm Financial 20 Crisis, that is referenced in one of the exhibits 21 contains a good deal of information from those studies. 22 So, I related to them the general findings 23 and, as I recall, we discussed, in general terms, to 24 what extent those findings might be applicable to the 25 situation in the EAA. Accurate Stenotype Reporters, Inc. 240 1 Q You did discuss to what extent those 2 findings might be applicable to the situation in the 3 EAA? 4 A In a general way. 5 Q What did you indicate in those discussions? 6 A Well, I think that one area that we 7 discussed was that the type of farming would be 8 substantially different in this area of North Dakota 9 where those studies had been done, compared to the EAA. 10 And I guess my opinion was that that would limit the 11 direct applicability of our study findings to the EAA 12 situation. 13 Q In your opinion, notwithstanding 14 limitations, do your North Dakota studies from the 15 surveys in '86 and '89 provide some basis for drawing 16 inferences about social impacts that may result in the 17 EAA from implementation of the SWIM Plan alternatives? 18 A They certainly could be one of the things 19 considered, among others, in drawing such inferences. 20 Q Do you have any opinions about any 21 functional relationship between crime and economic 22 impact? 23 A No. Analysis of crime rates and so on has 24 not been something where I have really done previous 25 work. It is not an area where I would feel that I had Accurate Stenotype Reporters, Inc. 241 1 the background to express an opinion. 2 Q Do you have any opinion about any 3 functional relationship between domestic violence and 4 economic impacts? 5 A I would make the same response. That is 6 not an area where I feel that I have the background to 7 formulate an opinion. 8 Q And the same would be true, I take it, of 9 self-esteem and the family? 10 A Yes. 11 Q And yet, you do indicate that the North 12 Dakota studies from the '80s that you discussed with RPC 13 might be used as some basis for inference about social 14 impacts in the EAA, correct? 15 A Again, analysis of social impacts is not 16 really my area, but based on methods that are used for 17 assessing impacts in other dimensions, it would seem 18 that one fundamental approach is often to examine 19 experience in what might seem, in the broad sense, to be 20 analogous cases or situations. 21 So, in that sense, then our North Dakota 22 study could be considered along with other studies 23 involving economic decline, economic restructuring and 24 the like as input to someone's effort to formulate 25 opinions with regard to the dimensions that you are Accurate Stenotype Reporters, Inc. 242 1 talking about. 2 Q Is the key to the suitability of studies 3 like your North Dakota studies as a basis for inference 4 about social impacts in the EAA, the degree of 5 similarity between the conditions in the two areas? 6 A I would think that would be a major factor. 7 Q And you did indicate that because the type 8 of farming is different between the two areas, that 9 would limit the suitability of the North Dakota studies 10 as a basis for inference on social impacts in the EAA? 11 A Although I'm not attempting to formulate 12 opinions about social impacts, it would seem to me that 13 the degree of similarity or difference between the 14 areas, the type of farming, the characteristics of the 15 people involved and so on, would be major factors 16 affecting the applicability, "the transferability" of 17 findings. 18 Q Besides the opinion that I think you 19 indicated that you had expressed in conversations with 20 RPC about that limitation, namely, the differences in 21 the types of farming, did you express any other 22 opinions, that you recall, about the use of your North 23 Dakota studies as a basis for inference on social 24 impacts in the EAA? 25 A I think we pretty well covered it. Accurate Stenotype Reporters, Inc. 243 1 Q Were there particular categories of social 2 impact that were discussed or analyzed in the North 3 Dakota studies that we have been talking about? 4 A We asked the respondents about a variety of 5 experiences that they might or might not have 6 experienced within the past. I believe it was the past 7 two years. And the list was lengthy. It was things 8 like have you been divorced, or have you -- it was a 9 long list. The summarization of those studies is 10 included in my documents somewhere, so rather than try 11 to recall a lot of specifics, if this is important, we 12 can probably find one of the documents that summarizes 13 what we did. 14 I would not characterize what we did as a 15 social impact analysis, per se. 16 Q Then would it be safe to say that you 17 didn't quantify social impacts in any way? 18 A Right. 19 Q Was it a qualitative analysis of social 20 impacts? 21 A I guess, again, I would not characterize it 22 as a social impact analysis, per se. What we did was 23 quantitative, in the sense of we were doing a survey, so 24 that in terms of things like have you been divorced, et 25 cetera, have you gone through bankruptcy, and all of Accurate Stenotype Reporters, Inc. 244 1 these different things, the report then summarizes that 2 "X" percent of respondents said, yes, they had gone 3 through bankruptcy and the rest hadn't. This many had 4 been divorced and this many hadn't. 5 Q So, it was quantitative, not just with 6 respect to the antecedent conditions or the causes, but, 7 also, with respect to some consequences you did, in 8 fact, quantify divorce rates? 9 A Yes. 10 Q Were the samples of interviewees 11 statistically designed to be representative samples or 12 anything like that? 13 A That was the effort, yes. 14 Q To your recollection, I understand that is 15 not something that you necessarily referred to for 16 purposes of this deposition, but besides divorce rates, 17 did you quantify anything else in the way of consequent 18 conditions to the economic distress that these 19 interviewees went through? 20 A We, basically, quantified a good deal of 21 information in terms of what were they doing at present. 22 Were they employed? In what type of occupation or 23 industry? What was their income for the last year? 24 Information about assets, and debts and this sort of 25 thing. So, we were, basically, quantifying what their Accurate Stenotype Reporters, Inc. 245 1 present situation might be in a number of dimensions. 2 Q Employment, income, assets and debts, 3 although those certainly sound socioeconomic, they sound 4 more, in a sense, economic than social. With respect to 5 the social categories that I named, of crime, domestic 6 violence, self-esteem, family, you mentioned divorce 7 statistics that you provided. Were there any other 8 purely social findings that were quantified in the 9 analysis, that you recall? 10 A As I mentioned before, it wasn't really 11 geared as, primarily, a social analysis. Some of the 12 indicators might be of some interest to people doing 13 social impact work, but we had not set out to do a 14 "social impact analysis" in that study. 15 Q So, then, it would be safe to say that you 16 didn't derive any conclusions about a functional 17 relationship between divorce and economic impact? 18 A Right. I did not. 19 Q But the data and the tabulation of the 20 data, in your view, might be used by someone undertaking 21 such an analysis of a relationship between divorce and 22 economic impact? 23 A Again, this area of social effects is not 24 one where I, normally, formulate opinions, et cetera. 25 It seems to me at least conceivable that some of the Accurate Stenotype Reporters, Inc. 246 1 findings from studies like the ones that I have 2 described to you, the two that we did in North Dakota, 3 could be used, along with other information, by 4 individuals seeking to formulate opinions about 5 relationship of economic restructuring, economic 6 distress and divorce. 7 Q Other than the references to the literature 8 on population migration response in a declining area, 9 and the material that is discussed in Exhibit 11, did 10 you apprise RPC of any opinions or pertinent 11 information, in your view, from your research showing a 12 decline in rural communities? 13 A Not that I recall. 14 Q I would like to go back for a minute to a 15 topic that we discussed at some length yesterday; the 16 criteria and other methodology that RPC may be using for 17 determining when agricultural land comes out of 18 production. We had had some fairly extensive discussion 19 about Exhibit 2. If you would, take a look at that 20 exhibit, again. 21 A All right. Agricultural land, et cetera. 22 Q Other than the information and opinions 23 that may be provided in the agricultural land section of 24 this memorandum, did you provide any other input to RPC 25 in their formulation of the methodology with respect to Accurate Stenotype Reporters, Inc. 247 1 when land comes out of production? 2 A No. 3 Q Did you give them any input that may not 4 have been in writing? Significant input in conversation 5 that would supplement this memo? 6 A Not that I recall. 7 Q And this would include the sub-issue of the 8 grower's subsidy from the mill? 9 A Yes. 10 Q On the issue of the allocation of STA 11 construction impacts and operation impacts between local 12 and non-local workers, is it correct to refer to that as 13 leakage, just as shorthand? Let me rephrase that. Is 14 that what you understand is being referred to in 15 references that RPC might make to the term "leakage"? 16 A My feeling is probably not. That probably, 17 as I understand it, the most common use of the term 18 "leakage" in these kinds of analyses often relates to 19 the expenditures which occur outside of the local study 20 area, such as purchases made outside of the EAA, in the 21 surrounding urban areas and that sort of thing. 22 The question of percentage of STA 23 construction workers who might be from outside of the 24 EAA would be related to the "leakage" phenomena, in the 25 sense that those STA workers who live outside of the EAA Accurate Stenotype Reporters, Inc. 248 1 area would probably, normally, be expected to spend a 2 large part of their income outside of the EAA area, as 3 well. 4 Q So, then, it would be correct to say that 5 the allocation of STA construction and operation impacts 6 from implementation of the SWIM Plan in the EAA would be 7 one aspect of leakage, but leakage could include many 8 other aspects? 9 A Yes, yes. 10 Q Focusing on the allocation between local 11 and non-local workers of STA construction and operation 12 impacts, again, in Exhibit 2, there is a section that we 13 discussed yesterday at some length; the local employment 14 in construction of STAs? 15 A Yes. 16 Q This section pertains to the determination 17 of the appropriate distribution of those impacts between 18 local and non-local workers; is that correct? 19 A Yes. 20 Q Did you provide any other input to RPC on 21 this issue? 22 A No. I think this summarizes my input to 23 them on this issue. 24 Q So, you didn't provide anything? If you 25 might have had a conversation with RPC, in addition to Accurate Stenotype Reporters, Inc. 249 1 this physical memo, it wouldn't have provided any 2 significant additional information? 3 A Right. 4 Q Or any significant inconsistent 5 information? 6 A That would be my feeling, yes. 7 Q Did you recommend a ratio to be used in 8 allocating the STA construction and operation impacts 9 between local versus non-local workers in this memo? 10 A Those percentages, I guess, would be 11 interpreted as a ratio between local and non-local 12 workers. 13 Q This section of the memo, as we discussed 14 yesterday, breaks down a local versus non-local worker 15 origin percentage into three different categories? 16 A Yes. 17 Q Do you know if RPC did an analysis of STA 18 operation and construction impacts that was so broken 19 down into those different categories? 20 A I don't know. 21 Q Can you do that with using the RIMS 22 multipliers that you referenced yesterday in exhibit -- 23 I'm not sure of the exhibit number. Let me find that. 24 Let me rephrase the question while I look for an 25 exhibit. Accurate Stenotype Reporters, Inc. 250 1 Can you break down the economic impacts of 2 STA construction and operation into three different 3 categories of skill and function, as you do in this 4 memo, when you are using the RIMS multipliers? 5 A It seems to me that breaking down the 6 local, non-local worker percentages by type of worker is 7 not inconsistent with the use of the RIMS multipliers in 8 the economic impact analysis. 9 Q Professor Leistritz, looking at Exhibit 4, 10 on the second page of this exhibit and the third page, 11 there were a number of references to RIMS II 12 multipliers; is that correct? 13 A Yes. 14 Q And one of them that you had indicated 15 would be the RIMS II multipliers for construction of 16 STAs, correct? 17 A Correct. 18 Q And that's the one referenced as 11.0703? 19 A Right. 20 Q Another one that you indicated would be the 21 multiplier for STA operation, correct? 22 A 12.0213. 23 Q Very good. If you would, tell me how would 24 you distribute the STA construction impacts between 25 local and non-local workers in the three different Accurate Stenotype Reporters, Inc. 251 1 categories that are referenced in your memo in Exhibit 2 2, using the RIMS II multiplier? 3 A In general, my answer would be that there 4 would be several steps in the economic impact analysis. 5 That the assessment of local and non-local split on 6 numbers of workers would be an early step. There would 7 be some subsequent steps prior to application of the 8 RIMS multipliers. And one of those steps in between 9 would be some assumptions or estimates of leakage. That 10 is, how much of the expenditures for payrolls and that 11 sort of thing would we estimate would be retained within 12 the EAA that would be related, of course, to our 13 assumptions about the split of the workers. 14 MR. SAXE: Can we take a three-minute 15 break? 16 MS. RAEPPLE: Fine with me. 17 (Brief recess.) 18 BY MR. SAXE: 19 Q Professor Leistritz, in this memorandum, 20 Exhibit 2, the local employment in construction of STAs, 21 do you make a recommendation of a 50-50 ratio for 22 distributing the economic impacts of STA construction 23 and operation between local and non-local workers? 24 A The short answer is, no. 25 Q Just using one number, rather than broken Accurate Stenotype Reporters, Inc. 252 1 down into the three different categories, would a 50-50 2 ratio for that distribution be the appropriate one, in 3 your opinion? 4 A I guess I would not offer an opinion 5 whether a 50-50 ratio would or would not be appropriate 6 without having perhaps more information. 7 Q In this section of the memo, is your 8 recommendation, effectively, with respect to 9 engineering, design and construction employment impacts, 10 that the ratio be one-to-nine? 11 A Right. 12 Q And with respect to skilled construction, 13 it would be two-to-eight? 14 A Right. 15 Q And with respect to unskilled, it would be 16 four-to-six? 17 A That's what we suggested in the memo. 18 Q Can you point to me any document that shows 19 the skill level data that you used in doing your 20 allocation? 21 A This was really based on information from 22 various interviews and, also, information with regard to 23 experience and other types of water and energy related 24 construction projects, as referenced in the couple of 25 sources that we cite there. Accurate Stenotype Reporters, Inc. 253 1 Q In fact, we did have some discussion about 2 this yesterday? 3 A Right. 4 Q If I am recalling, that first sentence in 5 this section refers to analysis of secondary data, and 6 then interviews and we had some extended discussion 7 about that? 8 A Yes, we did. 9 Q On the secondary data, you had indicated 10 yesterday that there was information on skills, 11 occupations and educational levels that were available 12 through the U. S. Census and the Florida Job Service? 13 A Yes. 14 Q Did you do any analysis of that data that 15 formed a part of your identification or derivation of 16 these local, non-local ratios? 17 A In terms of a quantitative analysis, a 18 formula, something of this nature, no. 19 Q Could you describe for me what was done 20 using that data? 21 A Okay. 22 Q Could you first tell me, specifically, 23 whether the data that you used would be found in any of 24 the document and disk production in some form? 25 A I think the data, the census and the Job Accurate Stenotype Reporters, Inc. 254 1 Service information, is undoubtedly or very likely to be 2 included among the documents produced by RPC, probably 3 in the form of memos and short tables. 4 Q Would that be the form that it came from 5 the U. S. Census Bureau and the Florida Job Service in? 6 A To the best of my recollection, from the 7 census, it would be information compiled from census 8 volumes or tapes. From the Job Service, it would 9 probably be a combination of statistics and perhaps 10 notes on interviews with Job Service personnel. 11 Q So, then, there is some processed form in 12 which the source data from the U. S. Census Bureau and 13 the source data from the Florida Job Service was 14 provided to you? 15 A Yes. 16 Q And those would be documents; is that 17 correct? 18 A That RPC produced sometime ago, I would 19 imagine. 20 Q When you say sometime ago, would it have 21 been before your deposition a year ago? 22 A Quite likely. 23 Q Can you describe it for me? 24 A Okay. 25 Q By this, I mean, the form in which it came Accurate Stenotype Reporters, Inc. 255 1 to you? 2 A My recollection is that the census and Job 3 Service information was summarized in memos and in short 4 tables, showing, for instance, breakdown of the labor 5 force by occupation and this sort of thing. 6 Q Give me some other sorts of things? 7 A I believe I recall a memo, which one of Dr. 8 Luke's colleagues had prepared, which represented a 9 summarization of her interview with the local Job 10 Service office, I believe, in Belle Glade, where they 11 had commented on the skills of the work force, 12 employment, unemployment and related issues. 13 Q There are two breakdowns that you can give 14 me. One, you were describing the different ways in 15 which the data was broken down. I think you indicated 16 that it was broken down by -- what was it? Do you 17 remember the one type of breakdown that you just 18 testified to? 19 A Oh, I said the occupational breakdown of 20 the labor force. 21 Q And then the other, I was actually asking a 22 follow-up on that. I was asking you how else was the 23 data summarized, reported or broken down, besides 24 occupation? 25 A I am reasonably certain that another Accurate Stenotype Reporters, Inc. 256 1 breakdown would be educational level, educational 2 attainment, for the population or the work force. 3 Q And the skills; is that correct? 4 A Yes. 5 Q You testified to this yesterday? 6 A Yes. 7 Q You referred to a memo that had been done 8 by one of Dr. Luke's colleagues? 9 A Yes. 10 Q Based on interviews with Florida Job 11 Service? 12 A That's my recollection. 13 Q Do you remember who that was? 14 A My recollection is that Jean Warner was the 15 person who had done the interview and the memo. 16 Q Any others that you recall in the way of 17 analysis of secondary data in forming these conclusions? 18 A Those are the salient things. 19 Q Does the Bureau of Economic Analysis give 20 any guidance to users about adjustments for workers 21 living outside of the impact area? 22 A I am not familiar with guidelines that they 23 may provide. 24 Q We touched on this yesterday, but I don't 25 think I asked you this question. Let me ask it to you Accurate Stenotype Reporters, Inc. 257 1 now. 2 The number that you selected for STA 3 engineering, design and construction management, that 10 4 percent might be expected to come from the EAA, would it 5 be fair to say that that 10 percent number suggests that 6 there are very few, or one-in-10 engineers, who would be 7 required for STA construction that know anything about 8 digging canals? 9 A That would not be my interpretation. What 10 these percentages are intended to represent is an 11 estimate of the jobs of this category, engineering, 12 design and construction management category, in the STA 13 development, which would likely be filled by people 14 residing within the EAA, as opposed to residing outside 15 of the EAA. 16 A factor that seemed important for this 17 class of workers was, again, based on interviews there 18 in the region. It was my understanding that most of the 19 types of engineering firms, construction firms, that 20 might likely be involved in EAA development, it appeared 21 that most of those firms would be headquartered outside 22 of the EAA. 23 Since, again, experience with other types 24 of projects would suggest that most of the engineering, 25 design and management people involved in a project are Accurate Stenotype Reporters, Inc. 258 1 likely to be long-term employees of the company that is 2 undertaking it, as opposed to people that are hired, 3 specifically, for the project, that was the basis for 4 the estimate of only one in 10 of this category of 5 workers being EAA residents. 6 Q Where would the construction firms that are 7 outside of the EAA likely be headquartered? 8 A Elsewhere in Palm Beach County, or in 9 adjacent counties, as I understand it. And perhaps more 10 widely. But it was my impression that quite a number of 11 these firms were headquartered elsewhere in Palm Beach 12 County, as well as the adjacent counties. 13 Q Thank you. 14 We had started off on leakage, and we got 15 into the subspecies of the 50-50 or other allocation 16 between local and non-local? 17 A Right. 18 Q You, also, indicated that there were other 19 census in which leakage might apply in the analysis that 20 RPC might be doing? 21 A Yes. 22 Q What other kinds of leakage? 23 A A one-dimensional leakage, as we referred 24 to, is if a substantial part of the workers live outside 25 of the EAA, then it would probably be estimated that Accurate Stenotype Reporters, Inc. 259 1 relatively little of their income would be spent within 2 the EAA. 3 A second factor for those who do live 4 within the EAA is that their consumer expenditures will 5 likely occur within the EAA. But it may be that a 6 portion of their expenditures go to retail outlets, 7 shopping centers and the like outside of the EAA. 8 And yet another dimension of leakage would 9 be looking at the expenditures of the firms, be it 10 construction firms, mills and so on. The person of 11 their expenditures for inputs, and services and the 12 like, which go to recipients outside of the EAA, that 13 would be another component of the leakage. 14 Q Is there an increasing number of EAA 15 workers living outside of the EAA? 16 A In some of the interviews summarized in the 17 one exhibit, I was being told that there were a 18 substantial and perhaps increasing number of EAA workers 19 who lived outside of the EAA. 20 Q Is it true that the definition of leakage 21 depends upon where one draws the boundaries for the 22 study area; is that correct? 23 A Absolutely. 24 Q So, to the extent that EAA leakage involves 25 exchange with Palm Beach County and other adjacent Accurate Stenotype Reporters, Inc. 260 1 counties, if one drew the study area around those 2 adjacent counties, instead, the leakage is not existent, 3 at least with respect to that? 4 A Yes. If the study area boundaries the EAA, 5 then the expenditures to other parts of Palm Beach 6 County, et cetera, are leakages. If you draw the 7 boundary to include all of Palm Beach County, then those 8 expenditures to the rest of Palm Beach County, which had 9 been leakages, are now no longer leakages because, by 10 definition, leakages are those expenditures that go 11 outside of the study area. 12 Q So, there is no internal leakage? 13 A So, the larger you draw the study area, the 14 less the leakage, other things equal. 15 Q Does the determination of a significant 16 amount of leakage suggest that the study area is more 17 properly drawn broader than it has been for a given 18 study? 19 A I believe that is not an unreasonable 20 statement. Another approach to this issue is that it is 21 not uncommon in impact studies to have multiple levels 22 of analysis. Perhaps local impact analysis, focusing on 23 an immediate area of communities which seem to bear the 24 brunt of the impacts. And then perhaps a more extensive 25 regional analysis, where the regional study area or Accurate Stenotype Reporters, Inc. 261 1 analysis area is drawn more broadly to capture much of 2 the leakages that are identified as occurring from the 3 local study area. 4 Q Other than your input to RPC on the 5 distribution of STA construction and operation impacts 6 between local and non-local workers, did you provide any 7 other input to RPC on the broader topic of leakage in 8 their economic analysis? 9 A In one of these exhibits that we were 10 looking at yesterday, we talked about at least the 11 concept of doing the analysis at three different levels; 12 our local impact area, a regional analysis and the State 13 level impact. That would be the other significant input 14 that would come to mind. 15 Q Any others that come to mind? 16 A Not really, no. 17 Q Let me see, just for accuracy, if I can 18 find where you were discussing that. If you could take 19 a look through the exhibits. 20 A Actually, it looks like it is good old 21 Exhibit 2. And it is the page after the page that we 22 were just talking about. 23 Q All right. 24 A And it is the first full paragraph. It was 25 determined that three different levels of analysis would Accurate Stenotype Reporters, Inc. 262 1 be appropriate. 2 Q I'm sorry if I asked you this question 3 yesterday. Excuse the repeat. Is RPC, to your 4 knowledge, analyzing impacts at those three different 5 levels; state, regional and local? 6 A I cannot say for sure. 7 Q In your opinion, is that the appropriate 8 methodology to use to address this leakage phenomenon 9 that inheres in the local impact assessment? 10 A Yes, I think so. 11 Q Referring back to the Federal principles 12 and guidelines that we had some reference to yesterday, 13 the principles and guidelines identified various 14 different levels of geographic focus for economic impact 15 assessment; is that correct? 16 A Yes. 17 Q What is meant by in NED? 18 A National Economic Development. There are 19 multiple accounts referred to in the principles and 20 guidelines. NED is the National Economic Development 21 account. 22 Q In your opinion, does addressing the 23 economic impact for the SWIM Plan at the State and EAA 24 level only satisfy the NED account aspect or requirement 25 of the principles and guidelines? Accurate Stenotype Reporters, Inc. 263 1 A I don't know if I have enough information 2 to offer an opinion on that at this point. 3 Q In your literature, I believe it is in what 4 is marked as Exhibit 10, your threshold population level 5 article, you describe a phenomenon in the first 6 paragraph of increasing tendency for rural residents to 7 bypass nearby small towns for shopping centers, and 8 discount stores and larger trade centers? 9 A Yes. 10 Q Is there a trend in EAA residents bypassing 11 EAA cities to shop in larger trade centers? 12 A I have not had access to detailed retail 13 sales data by community to really give me a basis to 14 offer an opinion on that question. 15 Q Do you recall if that topic came up during 16 the interviews, of which you took notes, reflected in 17 Exhibit 3? 18 A My recollection was that one or more of the 19 people that I talked to discussed, for instance, 20 relatively limited retail, a relatively limited retail 21 sector in Belle Glade, and the impression that many 22 people went to the shopping centers of West Palm Beach 23 urban area for a substantial amount of their shopping. 24 Again, this was non-quantitative types of comments. 25 Q To your knowledge, are you aware of any Accurate Stenotype Reporters, Inc. 264 1 factors that would distinguish the EAA from the North 2 Dakota areas that are referenced in the threshold 3 population article, in Exhibit 10, as far as this 4 phenomenon of bypassing local cities for remote larger 5 trade centers is concerned? 6 A Yes. 7 Q What would those be? 8 A Some factors that come to mind are factors 9 that distinguish the EAA study area from the North 10 Dakota and adjacent states that we referred to in the 11 article. 12 Q With respect to this type of leakage? 13 A With respect to this type of leakage. 14 Some things that come to mind, that I think 15 were mentioned in some of the interviews, was that on 16 the one hand, a certain portion of the EAA population 17 being seen as having limited mobility, hence, more 18 likely to purchase locally. And I believe these H2A 19 workers were mentioned in that regard. That they were a 20 major source of support for local businesses, because 21 they didn't in many cases have automobiles and so on, so 22 they couldn't go running off to West Palm Beach. 23 And on the other hand, also, discussion 24 about the fact of a significant portion of the EAA 25 people currently working in the EAA in the sugar Accurate Stenotype Reporters, Inc. 265 1 industry, apparently, living outside of the EAA, in the 2 western suburbs. Wellington was a place that was 3 mentioned as a place of residence for a number of these 4 people. 5 And probably the general differences -- 6 well, I'll just leave it there, as a couple of 7 differences. 8 Q Are H2A workers included in RPC's 9 employment and earning impact projections? 10 A That's a good question. I cannot say 11 without having a chance to study their analysis in its 12 entirety. 13 Q Should H2A workers be included in RPC's 14 employment impact projections? 15 A I don't think I would offer an opinion on 16 that without understanding the full context. 17 Q Would you have an opinion about whether H2A 18 workers should be included in RPC's earnings impact 19 projections? 20 A I don't think I would offer an opinion at 21 this time. 22 Q How about fiscal impact projections? 23 A Again, I don't feel that I have information 24 necessary to offer an opinion at this time. 25 Q Would that, also, be the case for Accurate Stenotype Reporters, Inc. 266 1 demographic and social impact analysis that RPC might 2 be doing? 3 A Yes. 4 Q I had been asking you about inputs or 5 submittals that you might have made to RPC on the 6 broader issue of leakage, and you pointed me, again, to 7 Exhibit Number 2. Are there any other inputs that you 8 can think of? 9 A Not that I can think of right now. 10 Q Back to the documents. 11 A All right. 12 Q What is Exhibit Number 3? We haven't 13 gotten there yet, but we will get to that document. 14 Those are the handwritten interview notes and things? 15 A Yes. 16 Q Would you refer, please, to Exhibit Number 17 11? 18 A All right. 19 Q This exhibit deals with the memo to you 20 from Dr. Schubert concerning the proposed function and 21 your memo back concerning that function? 22 A Yes. Right. 23 Q It is correct, is it not, that population 24 decline begins immediately with the loss of a job, the 25 first job, by application of this function? Is that Accurate Stenotype Reporters, Inc. 267 1 correct? 2 A That's the way it appears, yes. 3 Q In your previous models, did you make this 4 same assumption about an immediate population impact 5 from a very low level of employment impact? 6 A As I can recall, I have done a number of 7 these analyses using various types of models and 8 systems. In some of the analyses that we have done, I 9 think we have had a direct correspondence, as is shown 10 here. In others, as I recall, we allowed for a 11 fluctuation in, essentially, unemployment to occur; 12 which would probably mean that job loss would have to 13 reach a certain threshold, if you will, before migration 14 occurred. 15 Q Do you, usually, assume that there would be 16 some such threshold of unemployment before migration 17 occurs in the analyses that you have performed? 18 A We certainly have done it both ways. I 19 think one factor to be considered is what is the 20 baseline situation? I think both approaches have 21 considerable precedent in the literature. 22 Q With respect to the analyses that you have 23 done, as opposed to the literature on the topic, though, 24 have your analyses, usually, provided for some threshold 25 of unemployment before outmigration occurs? Accurate Stenotype Reporters, Inc. 268 1 A As I say, we have done analyses and used 2 models that did both. We have used some models that had 3 unemployment threshold built in. We have used other 4 modeling systems that really did not have the 5 unemployment threshold. And population change, 6 essentially, was related to job change, from job one on. 7 Q Can an unemployment threshold of this sort 8 be provided for in an exponential function, or does that 9 require a quadratic function, or some other -- 10 A I don't think I have an opinion on that, 11 without more information. 12 Q Which method would be most common in terms 13 of either providing an unemployment threshold, versus 14 assuming an immediate outmigration response, to a low 15 level of unemployment? 16 A I really believe an answer on that question 17 might require somebody to actually do a review of the 18 literature. And we have done some of those reviews in 19 the past, but that was probably several years ago, so I 20 don't think I have enough information to really offer an 21 opinion about what is most common. 22 Q How about in power generating plant models? 23 A Certainly, in some of the modeling that we 24 had done with regard to power plant construction, we did 25 a number of analyses, including some in North Dakota and Accurate Stenotype Reporters, Inc. 269 1 some in Texas, using a particular type of modeling 2 system which has been sometimes referred to as the 3 T-A-M-S model, TAMS, or SEARS, S-E-A-R-S. And those 4 models incorporated an unemployment threshold. 5 So, probably quantitatively, in terms of 6 the total number of impact studies that I have been 7 involved in, the majority probably used that modeling 8 system. So, by definition, the majority would 9 incorporate an unemployment threshold. 10 Q Is there a model known by the acronym of 11 RED? 12 A Yes. 13 Q Does it incorporate an unemployment 14 threshold? 15 A Yes. The RED model was the basis for the 16 TAMS and the SEARS. 17 Q How about the REAP model, is that another 18 such model? 19 A That might, also, be viewed as a different 20 name for the RED model. 21 Q So, again, it would include an unemployment 22 threshold? 23 A Yes. 24 Q It sounds like these models are rather 25 incestuous. Accurate Stenotype Reporters, Inc. 270 1 A Yes. 2 Q How do factors such as unemployment 3 insurance affect the decision whether to migrate from 4 the EAA in the face of unemployment? 5 A I don't think I have an opinion on that, 6 without more information. 7 Q Do you know whether the availability and 8 possible effect on outmigration of unemployment 9 insurance is considered in the RPC model? 10 A I don't know. 11 Q Was it discussed at all in model 12 construction, so far as you are aware? 13 A I was not party to discussions where that 14 was a major topic. 15 Q Did you make any account for unemployment 16 insurance in previous models or previous analyses that 17 you have done? 18 A To the best of my recollection, that was 19 not a major issue that we dealt with in those efforts. 20 Q How about other public assistance programs? 21 A Not really. 22 Q Would you consider unemployment 23 compensation to be a transfer payment, to the extent 24 that it is provided through EAA unemployed workers 25 living there? Accurate Stenotype Reporters, Inc. 271 1 A I think it would be properly termed a 2 transfer payment. 3 Q Would funds transferred through such 4 transfer payments likely be spent within the EAA? 5 A At least to some extent, subject to the 6 same leakage phenomena that we discussed earlier. 7 Q Does outmigration occur symmetrically with 8 inmigration? 9 A I guess I'll ask you to repeat the 10 question, or tell me what symmetrically means. 11 Q Okay, I'll repeat it first. Does 12 outmigration occur symmetrically with inmigration? 13 A Then I guess I'll ask you to tell me what 14 symmetrically means in this context. 15 Q All right. Is there a common relationship 16 between outmigration and inmigration? 17 A I'm not sure if that question lends itself 18 well to a yes or no answer. I will say, yes. And then 19 say that to the extent of my understanding of the 20 literature, basically, literature on migration indicates 21 that outmigrants and inmigrants tended to share a 22 considerable number of characteristics, basically, with 23 migration being selective towards the certain age 24 groups, higher educational levels and the like. 25 The younger portion of the work force, Accurate Stenotype Reporters, Inc. 272 1 typically, being more mobile. Generally, the more 2 highly-educated portion of the work force would be more 3 mobile. 4 Q I think I'm going in a different direction. 5 Let me rephrase the question. 6 Is there, usually, some creation of new 7 jobs associated with periods when there are losses of 8 existing jobs in a given area? 9 A I think I'll ask you to maybe clarify that 10 question a little bit. 11 Q That's okay. I'm not sure I will do that, 12 so we'll move on. 13 I am showing you what has been marked for 14 identification as Exhibit Number 12. Could you please 15 identify that, for the record? 16 A Yes, this is a handwritten memo to Eric, 17 referring to Eric Schubert, from Larry, myself. 18 Subject, data on sales per establishment. It is a 19 one-page memo, and then there are a collection of 20 attachments which, apparently, at least in someone's 21 view, bears some relationship to each other, I guess. 22 Q Do they bear any relationship to each 23 other, in your opinion? 24 A I think it was perhaps a collection of 25 notes and information that Mr. Schubert had put Accurate Stenotype Reporters, Inc. 273 1 together, all relating in some way to data for 2 information relating to the EAA analysis. 3 Q Well, that is a relationship. 4 A Yes. 5 Q On the first page it has a sequence number 6 at the bottom, DLL 5167. 7 A Okay. 8 Q This is a memo from you to Dr. Schubert; is 9 that correct? 10 A Yes. 11 Q The first sentence says, "As we've 12 discussed, it would be helpful to have data on the 13 average sales per establishment for the major industry 14 aggregations represented by the RIMS 39 sector model 15 (see attached table)." 16 Was this the discussion of -- 17 A Sales per establishment. Sales per 18 establishment that we related to a bit earlier today. 19 Q So, so far as you know, this was abandoned 20 from the standpoint of the methodology? 21 A I don't know for sure, but quite possibly. 22 Q But you had indicated that there were some 23 incompatibilities between the RIMS and such an approach? 24 A Potentially, yes. 25 Q On the second page, could you describe for Accurate Stenotype Reporters, Inc. 274 1 me what these are, please? 2 A This is a list of the RIMS 39 sector, the 3 "RIMS 39 sector model", which is the broad industrial 4 categories included within RIMS. And many of those are 5 broken down for their more detailed model into -- well, 6 construction, for instance, here they have new 7 construction, maintenance and repair construction. That 8 other table that we looked at a little earlier today had 9 new construction broken down into a whole number of 10 categories. And, likewise, maintenance and repair 11 construction was broken down into a whole number of 12 categories. 13 Q I believe you indicated in your testimony 14 earlier that, to your knowledge, the particular rows, 15 not columns, but the particular industrial 16 classifications of the RIMS two multipliers that you 17 selected were the same that Hazen & Sawyer selected? 18 A That's my understanding. 19 Q The difference being Hendry County versus 20 Palm Beach County? 21 A Correct. 22 Q But, otherwise, they should be the same? 23 A That's my understanding, yes. 24 Q Would it be correct, then, that you did not 25 use these 39 sector multipliers? Accurate Stenotype Reporters, Inc. 275 1 A Correct. 2 Q And why did you not? 3 A The reason that we did not use 39 sector 4 multipliers was because it was felt that the more 5 detailed breakdown would provide more accurate analysis. 6 Q The next page, DLL 5169, is this a work 7 table for what we looked at in another exhibit? 8 A Yes. 9 Q I guess that was Exhibit Number 2, this 10 information here? 11 A Yes. We would have to compare the numbers, 12 but that's what it should be, yes. 13 Q If you would, look at page DLL 5172, and 14 just take a look at that page. 15 A Maybe 62? 16 Q No. The DLL number. There are two sets of 17 numbers there. 18 A All right, 72, I've got it. 19 Q Thank you. 20 A My first comment is, these are not my 21 notes. 22 Q Could you identify for me whose notes they 23 are? 24 A Not with any degree of certainty. I could 25 speculate, but I don't know whose notes they are. Accurate Stenotype Reporters, Inc. 276 1 Q Whose notes do you think they are? 2 A I would speculate that they might be Mr. 3 Schubert's notes. 4 Q There is a reference at the top. It says, 5 "Florida statistical" -- by abbreviation, does this look 6 like "Florida statistical abstract," and an arrow to the 7 right, and then, "Sales/firm ratio may be there to help 8 RPC to estimate loss." 9 Does that look right? 10 A Yes. 11 Q How would you understand that statement? 12 What does that mean to you? 13 A I think that probably that is Mr. 14 Schubert's understanding of, essentially, the comment 15 from the first page about maybe we could gather together 16 the information on average sales per firm. And one 17 source, the first source to look at, might be the 18 Florida Statistical Abstract. 19 Q Further down there is a reference, kind of 20 in the middle of the page. It looks like it says, 21 "Black woman," underlined, and then there is a number of 22 sentences. 23 A Yes. 24 Q Would you read the second line into the 25 record? Accurate Stenotype Reporters, Inc. 277 1 A Okay. The second line, the one that begins 2 with "business"? 3 Q Yes. 4 A "Businesses already leaving the area, 5 (i.e., gas stations closings)." 6 Q Does this sentence have any significance, 7 in your view? 8 A Again, I think that was this gentleman's 9 notes from -- I was probably relating to him what I had 10 been told in an interview with a woman named Cartheda 11 Conchella, I believe is the pronunciation of the name. 12 She was introduced to me as an individual 13 who was to be described as a spokesperson or a person 14 quite knowledgeable about the local black community. 15 She had indicated that a high percentage, 80 percent was 16 probably her figure, of the black population in the EAA 17 or in the Belle Glade area, was, in her view, dependent 18 on agriculture. 19 She, also, mentioned that some businesses, 20 in her view, were already closing, leaving the area. 21 She mentioned, I believe, that more than one gasoline 22 station in Belle Glade had closed in some recent time 23 period. 24 So, essentially, I think this was Mr. 25 Schubert's notes as I had related to him what I thought Accurate Stenotype Reporters, Inc. 278 1 were some salient observations from my interviews in the 2 EAA. 3 Q If that were true, namely, the phenomenon 4 of businesses currently leaving the area, that would be 5 the kind of thing that should be accounted for in the 6 baseline; is that correct? 7 A Yes. The baseline represents the current 8 and projected situation in the absence of proposed 9 actions. So, if businesses are already leaving the 10 area, that, by definition, should be reflected in a 11 baseline. 12 Q And if population were leaving the area, it 13 should be reflected in the baseline for population 14 impact analysis? 15 A It would seem so. Kind of by the 16 definition of baseline. 17 Q And that would, also, be true with respect 18 to property values; is that correct? 19 A Yes. 20 Q And local tax revenues? 21 A Yes. 22 Q And public facilities and services? 23 A What I am agreeing with is the proposition 24 that the baseline should reflect current conditions and 25 reasonably foreseeable future changes, in the absence of Accurate Stenotype Reporters, Inc. 279 1 the proposed action. 2 Q And if those reasonably foreseeable future 3 changes included a continuation of a pattern of 4 outmigration of population, or lost businesses, or 5 diminishing property values, those should be reflected 6 in the baseline? That was my question. 7 A Yes, as a general concept. 8 Q Down at the bottom of this page, there is a 9 reference to the "Glades area" in quotes. 10 A Yes. 11 Q And then underneath that, it says, "As it's 12 called by locals"? 13 A Yes. 14 Q In the lexicon of the locals, is the Glades 15 area a synonym for the EAA? 16 A That was my impression, yes, that the 17 Glades area and the EAA were pretty much synonymous. 18 Q Do you know what the trend in school 19 enrollment is in the EAA? 20 A I haven't been asked to study the 21 statistics on that in any detail. 22 Q Would you look at DLL 5174 page number in 23 that Exhibit 12? 24 A All right. 25 Q Can you read what is on the top of this Accurate Stenotype Reporters, Inc. 280 1 page, the underlined captioned? 2 A Only part of it. Again, these are not my 3 notes. 4 Q The page that we were talking about just 5 previously, 5172, did those look to be notes that the 6 author had created concerning your report to the author 7 about your interviews in the EAA? 8 A Yes. At least some of page 5172 would be. 9 Q And that would be the middle section on the 10 Okeechobee -- 11 A Right the Okeechobee County contact, yes. 12 Q And the section at the bottom? 13 A Yes, et cetera. 14 Q Looking at this page, do you recognize the 15 context for these notes? 16 A Not particularly. As compared to 5172, I 17 don't think that this is a summary of something that I 18 was telling the individual. 19 Q The reference two lines down, it says L/SC 20 land," or assume it does. It is not very legible. What 21 would that mean, L/SC land, if that's what it says? 22 A I'm not sure. 23 Q Does anything on this page have any meaning 24 to you? Not particular words, obviously, but sentences? 25 A Not particularly. I would be speculating Accurate Stenotype Reporters, Inc. 281 1 on what these notes really mean. 2 Q If you would, turn to page 5176. 3 A All right. 4 Q Could you identify this page for me? 5 A 5176, a memo to Ron Luke from Larry 6 Leistritz, dated July 12, 1993, regarding information 7 from CH2M Hill. 8 Q Do you recognize this document? 9 A Yes. 10 Q Could you tell me what this is? 11 A CH2M Hill, apparently, was involved in some 12 way in -- Dr. Luke had asked me to give him a summary of 13 information that he should seek to obtain from CH2M Hill 14 relative to, I believe, alternative STA scenarios. And 15 so this memo is my attempt to, basically, provide Ron 16 with a list of some of the information that would be 17 desirable to have from the CH2M Hill people. 18 Q Did you have any role in the collection of 19 any such data from CH2M Hill concerning alternatives? 20 A No. This memo, I guess, was the extent of 21 my involvement. 22 Q Would that be true, also, with respect to 23 other sources of information about alternative treatment 24 technologies, like other contractors? 25 A Yes. Accurate Stenotype Reporters, Inc. 282 1 Q There is a reference at the top, the first 2 sentence of your memo, that says, "Pursuant to our 3 earlier discussions, it would be desirable to obtain," 4 then it goes on. 5 Had you had discussions with RPC, before 6 this memo, about getting data from other sources 7 concerning alternative treatment technologies? 8 A I believe pretty much the essence of the 9 discussion had been Ron calling me and explaining that 10 CH2M Hill was involved somehow in designing or planning 11 of the STA alternatives and could I develop kind of a 12 summary of the kind of information that we should ask 13 them for. 14 Q In the first sentence, what did you mean by 15 "estimated previous land use"? 16 A The land that is taken for the STAs, what 17 crops were being grown, and in what proportions? What 18 acreages of sugar cane, vegetables, sod, whatever the 19 crops might be? 20 Q Do you know what alternative agency 21 actions, potential agency actions, by the Water 22 Management District RPC might be analyzing from the 23 standpoint of socioeconomic impact or cost benefit 24 analysis? 25 A No, I don't know. Accurate Stenotype Reporters, Inc. 283 1 Q Have you had any involvement in any such 2 analysis? 3 A Not beyond the things that we really talked 4 about earlier in the deposition. 5 Q Which things? 6 A Selection of multipliers, review of 7 functions. 8 Q Have you had any interaction with RPC about 9 those things that we have discussed that were, 10 specifically, referenced to the analysis of 11 alternatives? 12 A No. 13 Q So, then, except for the extent to which 14 you have been involved in things with their analysis of 15 the SWIM Plan, and the extent to which those might be 16 applied to their analysis of alternatives, you had no 17 other involvement with their analysis of alternatives? 18 A Right. 19 Q Would it be fair to say that you haven't 20 formulated any opinions about any analysis that they 21 have done concerning alternatives to the SWIM Plan? 22 A Yes, that would be fair to say. 23 (Brief recess.) 24 (Deposition Exhibit 13 marked for 25 identification.) Accurate Stenotype Reporters, Inc. 284 1 BY MR. SAXE: 2 Q Professor Leistritz, showing what you what 3 has been marked for identification as Exhibit Number 13, 4 would you please identify that, for the record? 5 A Okay. What we have is a handwritten -- it 6 looks like a format for a table to present certain data. 7 It shows years across the top, and then down the side it 8 shows population, total revenues, property taxes, other, 9 total expenditures and balance. And then it shows 10 change from baseline population, total revenues, 11 expenditures, balance, assumptions, property taxes, 12 assessed valuation and so on. So, apparently, someone's 13 outline for a potential table to present data. 14 Q Have you ever seen this document before? 15 A I don't believe I have. I couldn't swear 16 that I have not, but it is certainly not one that I 17 produced. It is not one that I was asked really to 18 review. 19 Q Do you recognize what it is from its 20 contents or context? 21 A From its content or context, I would 22 speculate that it is an outline of a format for 23 presenting some of what we would refer to as the fiscal 24 analysis, because they talk about tax revenues, and 25 expenditures and balance. So, that would be my Accurate Stenotype Reporters, Inc. 285 1 speculation. It is sort of an initial attempt to 2 specify a format for reporting some of the fiscal 3 analysis results. 4 Q Do you know whether RPC is using an 5 inflation rate in any of its economic or fiscal 6 variables? 7 A I don't know. 8 Q Would it be correct that you don't know 9 whether this outline reflects methodology that is being 10 used by RPC or not? 11 A That would be correct. I don't know what 12 this is. If this is what is being used now or not. 13 MR. SAXE: Would you mark that, please? 14 (Deposition Exhibit 14 marked for 15 identification.) 16 BY MR. SAXE: 17 Q Professor Leistritz, handing you what has 18 been marked for identification as Exhibit Number 14, 19 would you just identify that document? Just kind of, in 20 terms of the title, just something sufficient to 21 identify it? 22 A It is a memo from Ann to Eric. Subject, 23 sugar cane agricultural property tax analysis, methods 24 and assumptions, date July 28, 1993. 25 Q And have you seen this document before? Accurate Stenotype Reporters, Inc. 286 1 A Like the previous document, I can't say for 2 sure. I did not produce it. I was not asked to provide 3 a review of it. It's possible that I was provided a 4 copy for informational purposes. I can't say for sure. 5 Q Do you recognize what the purpose of this 6 document might be? 7 A It appears to be Ann, which is Ann Orzech, 8 Ann's outline of methodology, as she says, and 9 assumptions for a portion of the fiscal impact analysis, 10 which would be the sugar cane agricultural property tax 11 component. 12 Q In the second paragraph, there is a 13 sentence a little more than halfway down, that starts on 14 the right side. It says, "In estimating net income, 15 drainage district assessments are counted, but real 16 estate taxes, and Federal and State taxes are not." 17 Do you know what the drainage district 18 assessments that are referred to in this sentence are? 19 A No, I don't. No. 20 Q Are you familiar with an average drainage 21 district assessment of $17.58, by any chance? 22 A I really have not been asked to get into 23 the details of the fiscal impact analysis, and in 24 particular the agricultural land analysis. That was not 25 part of my responsibilities, so I am really not Accurate Stenotype Reporters, Inc. 287 1 familiar. 2 Q I won't belabor it. Just let me ask you 3 one other question. The fourth paragraph up from the 4 bottom, it is a one-sentence paragraph, would you read 5 that into the record for me, please? 6 A Okay. The one that begins, "The average 7 net income"? 8 Q No. It actually begins, "If the average 9 income." I'm sorry, it is the next page. 10 A "If the average" -- okay. 11 Q It is page DLL 5182. 12 A Reading into the record: "If the average 13 income per acre for a given year is negative for land in 14 production, the valuation for tax purposes equals zero." 15 Q As far as land valuation in the EAA is 16 concerned, do you concur with this assertion? 17 A Again, really, land valuation for tax 18 purposes is not one of the aspects that I have been 19 asked to form opinions about. 20 Q Never mind. 21 MR. SAXE: If you would mark this, please. 22 (Deposition Exhibit 15 marked for 23 identification.) 24 BY MR. SAXE: 25 Q Professor Leistritz, showing you what has Accurate Stenotype Reporters, Inc. 288 1 been marked for identification as Exhibit Number 15, 2 could you just identify this, briefly, for the record 3 for me? 4 A Okay. A handwritten memo to Eric from Ann, 5 regarding State, corporate, and sales and PBC sales tax 6 analysis. PBC is Palm Beach County, I would speculate. 7 Date July 28, 1993. 8 Q Have you seen this document before? 9 A I don't believe so. 10 Q Do you recognize the nature of the document 11 from its contents? 12 A The nature of the document seems to be that 13 Ann is specifying for Eric some of the dimensions, 14 methodology procedures, to be used in some portions of 15 the fiscal impact analysis. She has formulas and this 16 sort of thing, data sources, contact. 17 Again, I really had no hand in producing 18 the document. I was not asked to review it, and this is 19 really -- 20 Q Do you know whether this reflects the 21 methodology that is being used by RPC to tax their 22 fiscal analysis? 23 A I don't know. 24 Q Did you have input, earlier on in the 25 history of this case, in the formulation of Ann's basic Accurate Stenotype Reporters, Inc. 289 1 methodology for these purposes? 2 A Only in a very general context. 3 Q How about with respect to these formulas? 4 A Specific formulas, no. 5 MR. SAXE: Would you mark this, please? 6 (Deposition Exhibit 16 marked for 7 identification.) 8 BY MR. SAXE: 9 Q Professor Leistritz, showing you what has 10 been marked for identification as Exhibit Number 16, 11 would you, just briefly, identify this for the record 12 for me? 13 A Okay. Exhibit 16 is handwritten notes. 14 There is a date up in the corner. It looks like 15 7-30-93, which would be the 30th of July, if that's the