STATE OF FLORIDA
             DIVISION OF ADMINISTRATIVE HEARINGS


                                                CASE NOs.  92-3038
                                                           92-3039
                                                           92-3040

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.,
                                                VOLUME I     
and

FLORIDA FRUIT AND VEGETABLE 
ASSOCIATION, LEWIS POPE FARMS,
W.E. SCHLECHTER & SONS, INC., and 
HUNDLEY FARMS, INC.,

               Petitioners,
vs.

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.

_____________________________________________________________

                       DEPOSITION OF 
                    DR. LEO C. POLOPOLUS

_____________________________________________________________




                     ACCURATE REPORTING
                            A/K/A
              MACDONALD COURT REPORTING SERVICE
   204 West University Ave., Suite 7, Gainesville FL 32601
    (904) 373-1126 ù (800) 329-1133 ù FAX (904) 375-6249


     Pursuant to due notice, the deposition of the above-
named witness was taken by the Respondent-Intervenor, the
United States of America, before Mary Macdonald, Court
Reporter and Notary Public, State at Large, at 204 West
University Avenue, Gainesville, Florida, on Wednesday, April
14, 1993, commencing at 9:00 a.m.

APPEARANCES:

     KEITH E. SAXE, Esquire, United States Department of
Justice, Environment & Natural Resources Division, General
Litigation Section, Post Office Box 663, Washington, D.C. 
20044-0663;

     RICK BURGESS, Esquire, and SCOTT D. LIEBERMAN, Esquire,
Peeples, Earl & Blank, One Biscayne Tower, Suite 3636, Two
South Biscayne Boulevard, Miami, Florida  33131;

     PATRICK S. COUSINS, Esquire, Popham, Hail, Schnobrich &
Kaufman, Ltd., 4000 International Place, 100 Southeast Second
Street, Miami, Florida  33131;

     CAROL RAEPPLE, Esquire, Hopping, Boyd, Green & Sams,
Post Office Box 6526, Tallahassee, Florida  32314;


ALSO PRESENT:  Lonnie L. Jones, Ph.D.
                    Grace Johns, Ph.D.
                    William Boggess, Ph.D.

     Thereupon,
                    DR. LEO C. POLOPOLUS,
     being first duly sworn, testified as follows:

                     DIRECT EXAMINATION
BY MR. SAXE:
     Q    Dr. Polopolus, I'm Keith Saxe, I'm an attorney with
the United States Department of Justice and I represent the
United States in the action Sugar Cane Growers Cooperative of
Florida versus South Florida Water Management District.
               I'll be taking your deposition for this case today
through Friday, and if necessary on some other date to be
scheduled in the future.
               During this deposition I will be asking you a
series of questions.  You are required to give me your
complete and honest answer to each question, unless your
attorney instructs you not to answer.  If for any reason you
don't understand a question, please tell me and I'll try to
clarify it.
               Dr. Polopolus, would you please state your full
name and home address for the record.
     A    Yes.  My name is Leo Polopolus and my address is
4741 Northwest 8th Avenue, Gainesville, Florida, 32605.

                         MR. SAXE:  Ms. Court Reporter, would you mark
          those for identification, please?

          (Document entitled Memorandum, to Ms. Susan
          Pacheco, from Leo Polopolus, dated August 18, 1992,
          so marked as Polopolus Exhibit No. 1; 
                         Document entitled Biological Sketch, Leo C.
          Polopolus, so marked as Polopolus Exhibit No. 2;
                         Document entitled Leo C. Polopolus, Selected
          Programs and Publications:  Economics of Sugar,
          Vegetables and Fruit, so marked as Polopolus
          Exhibit No. 3.)

BY MR. SAXE:
     Q    Dr. Polopolus, I'm handing your three documents
that have been marked for identification, Exhibits 1, 2 
and 3.  
               If you would take a look at the first document, No.
1, and identify it for the record.
     A    This is a memorandum from me to Susan Pacheco of
Peeples, Earl & Blank, just a transmittal letter that
indicates enclosed are my biographic sketch and a Selected
List of Publications.
     Q    And would that be the documents that have been
marked for identification as Nos. 2 and 3?
     A    Yes, sir.
                     Q    Does Document No. 2 represent a relatively complete
and current version of your Curriculum Vitae?
     A    I believe it's the last one that I have prepared. 
     Q    Okay.  And you've indicated that Document No. 3 is
a list of publications?
     A    It's a selected list of publications of mine
dealing with the economics of sugar, vegetables and fruits,
completed while at the University of Florida or with the
Florida Department of Citrus.
               It does not include my earlier publications in
these subject areas, while on the faculty at Louisiana State
University.
     Q    And I understand that if we need to take a look at
copies of any of those omitted publications that you will
check to see if you have copies for us.
     A    If they're in print I'll be happy to provide them.
     Q    That's great.
               Dr. Polopolus, what is your occupation?
     A    I'm an agricultural economist.
     Q    How long have you been an ag economist?
     A    I've been an agricultural economist for thirty-
three years.
     Q    Would you describe your educational background,
starting with high school?
     A    Yes.  I completed high school at Colton Union High
School, Colton, California.  I'm a life member of the
California Scholastic Federation.
               From there I went to the University of California,
Davis, where I obtained a Bachelor of Science degree in
agricultural economics, with highest honors.
               Then I went to the University of California at
Berkeley, and I received a Ph.D. in agricultural economics in
1960.
     Q    Do you hold any other undergraduate degrees, other
than the B.S. from U.C. Davis?
     A    No.
     Q    Any other graduate, advanced or professional
degrees, besides the Ph.D. from U.C. Berkeley?
     A    None.
     Q    Do you specialize in any particular aspect or did
you specialize in any particular aspect of ag economics in
your education?
     A    I'm fairly broadly trained in agricultural
economics and management production economics, marketing,
econometrics, policy.
               The Ph.D. dissertation focus was ÄÄ which dealt
with the U.S. beet sugar industry, by the way ÄÄ had a focus
on policy, public policy, and industrial organization.
     Q    Have you received any other training that relates
to the work you're doing in this case, besides the
educational background that you have described?
     A    It depends on what you mean by training.
     Q    Any formal courses, any organized seminars, things
of that nature?
     A    There's been countless numbers of conferences,
seminars, experiences with organizations, with groups, and
I'll be happy to discuss them.
     Q    Any that come to mind as being particular germane
to the work that you're doing in this case?
     A    Yes, some of them would be.  For example, I was a
member of the IFAS Water Resources Council for three years. 
               I was Chairman of the University of Florida Water
Research Center, which encompasses the College of
Engineering, all the academic units at the University of
Florida.
               I was previously on the Aquatic Weed Resource
Council of IFAS.
               IFAS stands for the Institute of Food and
Agricultural Sciences at the University of Florida.
               In the area of sugar, I have been involved in work
and conferences, meetings and consulting and advising,
teaching, in a variety of contexts.
     Q    Are these involvements, that you have just
mentioned, listed on this Selected Programs and Publications,
that's marked as Exhibit No. 3?
                     A    Some of them, yes.
               In addition to the sugar, I should also mention, I
have been involved in, since vegetables are also an area of
interest here for this particular project, I could say the
same thing about vegetables involved in, like, for example, I
was a consultant to the National Commission on Productivity,
under President Nixon.  In that respect I was involved in not
only statewide but national issues of productivity that
involved the fruit and vegetable industry.
     Q    When was that?
     A    That was the National Commission on Productivity
experience, was in '72, '73 ÄÄ 1972/1973 period.
     Q    Your reference to the IFAS Resources Council, is
that what is listed here on Exhibit No. 3 as 3(g), the IFAS
Marketing Task Force?  Is that the same thing?
     A    No, not at all.
               The IFAS Water Resource Council was formed in the
early ÄÄ I should say mid-1970s and was operative through, I
think, the early 1980s, to bring together all of IFAS
resources on water quality and water resource issues.  
               We had a special effort and my role, as Chairman of
the Department of Food and Resource Economics at the time,
was to try to muster and organize and recruit and carry out
an economics program as part of the statewide effort in water
resources.
                     Q    Your involvement with the resources council was
from its inception through the early '80s, or. . .
     A    Pretty much from its inception until the early
'80s, yes.
     Q    Are any of the particular involvements that you
have been talking about present involvements, things that
you're doing presently, or are they all things that you have
done in the past?
     A    Those particular activities are things in the past
and not current.
     Q    Okay.
     A    I'm not currently involved in ÄÄ I'm not even aware
that there is currently an IFAS Water Resources Council.  I'm
not involved if there is one.
     Q    Okay.  What were your duties with the Water
Resources Council?
     A    Again, as I indicated, my role, as the Chair ÄÄ the
resource economist of the Department of Food and Resource
Economics and my role was to assist in carrying out the IFAS
mission in water resource economics.
     Q    Were you involved in research in that capacity?
     A    No, I was not directly involved in research, but in
organizing research.
     Q    So would you say it was administration?
     A    It was more administrative and policy than it was
in directly conducting the work.
     Q    Did you review research?
     A    Oh, yes, indeed, and one of the roles that I played
in IFAS, in my tenure as chairman, was to develop a teaching,
research and extension program in the natural resource and
environmental quality area.  For example, I brought together
a team of people that we developed a specialization in a
teaching program, in natural resource environmental
economics; we developed, we think, one of the finest, at that
time, one of the finest extension programs in Natural
Resource and Economics in hiring Dr. Carriker, Dr. Comer, and
other people, and I'm responsible for hiring such people as
Dr. Boggess, Dr. Lini, Dr. Clouser, Dr. Mulkey, and many of
the current players in the University of Florida's Natural
Resource Team.
               So, I was not the researcher, but I was very much
involved in the development of the program.
     Q    Okay.  Are there any other programs or affiliations
that, besides the ones that you have mentioned, that you
think have provided you experience or opportunities that are
particularly germane to your work in this case?
     A    My own research experience and my continuing
interest in sugar economics, which culminated in a book I
wrote on the subject, and also a continuing interest in
vegetables and vegetable policy, which one piece of that was
my role as editing a book recently released on vegetable
trade.  
     Q    The sugar economics book that you're referring to,
is that listed on Exhibit No. 3?
     A    Yes.
     Q    Would that be 3(o) on the second page of the
document?
     A    Which document, sir?
     Q    Exhibit No. 3, the second page.
     A    Yes.
     Q    Is that the book?
     A    Yes.
     Q    Did the book deal with the sugar industry and
environmental problems in the Everglades?
     A    The sugar book was primarily oriented to the
natural sugar and sweetener industry, which Florida was a
part.  It included cane sugar, beet sugar and high fructose
corn syrup.  
               It, in discussing both the cane production,
domestic cane production and domestic cane milling and
domestic cane refining, it obviously dealt with Florida.
     Q    Did it deal with the environmental issues of South
Florida?
     A    No, it did not.
     Q    Would you describe your employment history for me
in chronological order, starting with your graduation from
Berkeley?
     A    Yes.  My first full-time employment, except for
that at the University of California, Berkeley, when I was a
full-time research associate my last year there, but I went
to my first academic appointment at Louisiana State
University as Assistant Professor for three years and then
was promoted to Associate Professor for the next two years,
at which point ÄÄ that's the period, giving specific dates,
Assistant Professor, LSU, 1960-63; Associate Professor, LSU,
1963-65.
               At that time I took an appointment with the Florida
Citrus Commission, on the campus of the University of Florida,
as a research economist for the Florida Department of Citrus.
               Within less than a year the director of the
Research and Marketing Department of the Commission, located
in Lakeland, resigned and I was appointed director.  We split
off the marketing from the economic research.  I asked to be
maintained in my directorship in Gainesville and for the
remaining two or three years I was Director of Economics for
a state agency, a state regulatory agency, and also had other
marketing responsibilities.  It was called Economic Research
Department, the Florida Citrus Commission.  Subsequently it's
been changed to the Florida Department of Citrus.
     Q    The distinction you described there, when you said
the Commission split between the marketing function and what
was the other one?
     A    The economic ÄÄ at one time the agency had an
Economic and Marketing Department.
     Q    Okay.
     A    When I became the director I became the Director of
Economic Research, and Marketing Research continued to be
headquartered in Lakeland.
     Q    Okay.
     A    So there was sort of a bifurcation there of
responsibility.
               Then I left the Florida Department of Citrus, but
remained at the University of Florida, became Professor of
Food and Resource Economics for the University of Florida in
1969, January of 1969.
     Q    So you were with the Florida Citrus Commission
between '65 and '69?
     A    That's correct, until December 31, 1968.
               January 1, 1969, I became a Full Professor of Food
and Resource Economics at the University of Florida.
     Q    Okay.
     A    Within a matter of a few months I was asked by the
new dean for the graduate school, an eminent physicist,
University of Texas, to be a part-time assistant dean for the
graduate school for the University of Florida.
                                               So in 1969, for a four-year period, I had a half-
time appointment as Assistant Dean of the Graduate School
with responsibilities across the whole campus, and Professor
of Food and Resource Economics.
               In 1973 I resigned my role as assistant dean, half-
time, it was like having two full-time jobs, to becoming the
Chairman of the Department of Food and Resource Economics as
Professor of Food and Resource Economics, and I was Chairman
of that department for a ten-year period, 1973 through 1983.
               In 1983 I stepped down as Chair of the department
and resumed my role as Professor of Food and Resource
Economics at the University of Florida.
     Q    Okay.  And you have been with the University of
Florida since 1983 in that capacity?
     A    In that capacity, that is correct.
     Q    Okay.  During the course of your employment. . .
               Well, before I move off your chronology here, I
asked you about employment after your graduation from
Berkeley and you mentioned you were a full-time research
assistant at Berkeley.
     A    Yes.
     Q    Was there any employment, between and during your
undergraduate and graduate years, that was related to the
subject matter of your work on the case?  I don't need you to
tell me, you know, your part-time jobs at McDonald's, that
kind of thing, if any, but is there anything that comes to
mind that you worked on?
     A    No, except my full-time role as graduate research
assistant, or whatever the title was, at Berkeley, in my last
year there, 1959-1960, was to work on sugar policy and sugar
marketing, and I spent full-time on that, and that also
became my dissertation on the U.S. beet sugar industry and
the structure and performance of that industry under
government regulations and control.
               So in that context, I very intimately became
familiar with sugar policy, as it affected both cane and beet
industries in the United States.
     Q    During the course of your professional and academic
involvements, have you worked on any project that involved
either economic or socioeconomic impact analyses of resource
management actions that are proposed to remedy environmental
problems?
     A    With the construction of that question, as I
understand it, and with some difficulty in scanning over
thirty-three years of effort, when you add the word
environmental problems, then I would have to say no to the
question.
     Q    All right.  Let's work ÄÄ rather than going to
fully qualified, let me work back from the basic end.
               Have you worked on any projects that involved
economic or socioeconomic impact analyses, period?
     A    Yes.
     Q    Would you list them for me?
     A    Well, there was a period of time in that period of
time at LSU when my role was a regional economist and I had
federal grants from the U.S. Department of Commerce and had a
group of graduate students and others as staff members, and
the concern there was ÄÄ if you recall, the economy, the U.S.
economy, in the early '60s, was one of high unemployment rate
and low economic development, and the Economic Development
Administration in Washington and in state areas were trying
to develop ways to deal with problems of unemployment and
promote growth, economic growth, and in that capacity, in my
role, both in teaching, graduate teaching, and in research, I
carried out research for the area of Redevelopment
Administration on how agribusiness or agriculture could be
used to value added activities to promote the economy of a
particular region, and that particular application happened
to be south/central Louisiana, and how one could take
agricultural production in that area and generate employment
and income and growth.
               So I have a number of publications and other work
that related to that effort.
               So that is one application of that.
     Q    So, if I understand your testimony, this project to
promote economic growth involved proposals, developmental
proposals, some involving agribusiness and other agricultural
undertakings.
     A    It involved proposals, it involved theses work,
dissertation research, publications, chapters in books, it
involved theoretical pieces, it involved a whole series of
effort that would be under my supervision and with some joint
authorships and so forth.
     Q    Did it involve any economic impact assessment
projects, strictly called?

                         MR. BURGESS:  Object to the form.

BY MR. SAXE:
     Q    Do you understand the question?
     A    Not well.
     Q    Okay.  Did the work involve any projects
quantifying economic impacts of a particular proposal?
     A    It involved the economic impact of creating or
adding value to agriculture product.  It involved primarily
investment feasibility:  would it be feasible, economically
feasible, to expand into the use of new technology?
               Let me give you an example of what was involved.
     Q    Okay.
     A    The U.S. Department of Agriculture was developing
new technology and the development of new products.  One
product was sweet potato flakes.  Okay.  Brand new
technology, wasn't applied, we took the research of the U.S.
Department of Agricultures' Food Utilization Lab in New
Orleans, where they developed a technical feasibility for
utilizing the processes of manufacturing sweet potato flakes,
and we applied that technical feasibility to whether or not
that was economically feasible to actually produce sweet
potato flakes and recover the investment of that facility by
using locally grown sweet potatoes.
               Now, what's involved there is the determination of
quasi-rents, total revenue streams, total operating costs,
and so forth.
     Q    Is there a difference between economic feasibility
assessment or analysis, and an economic impact analysis?
     A    There could be.
     Q    What I'm looking for here is whether or not, in
your role in this particular project or set of projects, you
quantified the economic impacts in terms of changes in sales,
income or employment of any of the proposed actions.
               The one you mentioned is applying sweet potato
flake technology to develop that product, using local
potatoes.
     A    Yes.
     Q    My question is, did you undertake to assess the
economic impact of such a project?
     A    Not in the sense that maybe you're leading to.
               That particular project did not then take that
result and use multiplier analysis to determine what the
community impact, let's say, would be.  We were looking at
the economic feasibility.
               But at about the same time we were looking at other
projects in the Caddo-Bossier Parish to develop ÄÄ we
developed a proposal and began the research to actually
estimate employment and sales multipliers through original
research and at teaching the graduate level at Louisiana
State University I taught Leontief multiplier analysis and we
did develop a research proposal that was funded by the Caddo-
Bossier Parish Agribusiness Council, if I recall, and we had
the cooperation of industry, broadly speaking, to undertake
this kind of analysis.
               The problem with that was that in order to do and
develop primary employment and income multipliers it became
an accounting nightmare for many of the respondents and so we
never got an adequate completion of that.
               I may say, in connection with economic impact, and
I guess that the gist of your question is whether I had
experience in doing economic impact analyses, and maybe a
better way of characterizing that would be the work that I
did with the Florida Department of Citrus.  Where there is a
state agency it has regulatory advertising and marketing
research responsibility and as chief economist, in going
before a state regulatory authority on numerous occasions, I
presented the results of my work on what you might call an
economic impact statement.  
               What would be the economic impact of changing a
regulation, with respect to a school lunch program?  A
diversionary program.  What would be the economic impact of
permitting importation of more foreign orange juice
concentrate?  Et cetera, et cetera, et cetera.
               So in that context I did conduct, or under my
supervision had conducted studies of that nature.
     Q    So in your involvement in the Florida Department of
Citrus then you did quantify the economic impacts in terms of
changes in sales, income and/or job employment, the proposal,
concerning the school lunch program?
     A    We did not look at the employment implications, but
we looked at the sales implications.
     Q    How about with respect to importing the frozen
citrus?
     A    Again, we usually did not, other than to ÄÄ you
know, the question there was what would changes in tariff
policy do to production levels, which then would have an
impact on employment, and at that time we had employment
multipliers in the citrus processing industry and they were
estimated to be about. . . 

               (Short interruption)

BY MR. SAXE:
     Q    Dr. Polopolus, in your understanding of the terms,
would you call the analyses that you did at the Florida
Department of Citrus, that you just mentioned, economic
impact analyses?
     A    Maybe, maybe not.  It depends on how you define
economic impact analyses.
     Q    I guess what I'm asking is, given the way you would
define economic impact analysis, would you call those
analyses economic impact analyses?
     A    Well, the question is whether we're talking about
economic analyses, economic impact analyses.  Certainly
they're economic analyses.
     Q    Okay.  I'm asking about economic impact analyses.
     A    They may or may not be.
               I think the more standard definition would include
or could include employment implications.
     Q    When you say the definition could include
employment implications, would you consider an economic
impact analysis, done in the circumstances of this case, to
be an adequate one if it did not include employment impacts?
                     A    I think with respect to, say, the economic impact
analysis, as I understand it under state law and under state
regulations, and so forth, those analyses can be rather
cursory and not too analytical and not, you know, not much
research based on it, but in the context of this particular
application that we would say economic impact would more
appropriately include employment impact.
     Q    Okay.  So then would it be fair to say that the
analyses that you did at the Florida Department of Citrus
were not appropriate economic impact analyses?
     A    No, I'm not saying that, that they're not
appropriate.  I'm saying in the context of what the
application there ÄÄ for example, what is the impact of
having a diversionary program, which sets aside X percent of
the crop or X percent of the process product into a reserve
pool, which is the secondary market; what is the economic
impact of that?  And there we use what we call price
discrimination analysis and where we establish marginal
revenues, we set the net marginal revenues equal to zero, we
determine the impact of what that would be on lower revenue,
we then turn around and look at that impact on consumers and
what would that do to prices, and so on and so forth.
               So that's an economic impact analysis, in the sense
that we're determining the impact on growers and impact on
consumers and impact on the trade.
                                               Now, in the context in which we're talking about
this project, we may have a different definition of economic
impact, in the context of the particular problem.
     Q    As a professor of agricultural economics or food
and resource economics, does economic impact analysis have
any special meaning or definition?
     A    It's not in the standard textbook of agriculture
economics.  I mean, if you read a textbook of agriculture
economics, in the beginning course in agriculture economics,
to my knowledge, you can take the books that I have read or
seen, economic impact analysis would not be something that
would be a chapter heading or even a major sub-heading of a
textbook.  It may be included in a course, in some other kind
of course, but not in general agriculture economics.  It
wouldn't have any special meaning.
     Q    Are you aware of any scholarly texts, any
textbooks, within the discipline, that are either wholly or
partially devoted to the procedures for doing economic impact
analyses?

                         MR. BURGESS:  In the discipline of agriculture
          economics?
                         MR. SAXE:  Yes.


BY MR. SAXE:
     Q    Or food and resource economics.
     A    I'm not aware of any title of a book that says
"Economic Impact Analyses", offered by, you know. . .
     Q    Are you aware of any textbooks that have chapters
on economic impact analyses?
     A    I'm certainly aware of books that deal with
Leontief input/output analyses.
     Q    Would you spell that, please?
     A    V-a-s-s-i-l-y  L-e-o-n-t-i-e-f.
     Q    Thank you.
     A    Vassily Leontief was a guest of ours a few years
ago, he's a Nobel Laureate in economics.  
               Vassily is the author of what is known as
"input/output analyses".  He's the father of the technique,
which shows the interdependencies of economics within an
international economic framework.  He's the economist that
developed the primary concept of a multiplier and he's the
father of that.
               Now, are there textbooks, chapters in textbooks,
that deal with input/output analyses, as we know it from
Leontief?  There are dozens, hundreds.
               Are there similar books that are titled "Economic
Impact Analyses"?  I don't know of any.
     Q    Okay.
                     A    Certainly there has been no Nobel Laureate, to my
knowledge, on economic impact analyses.
     Q    You mentioned the Leontief multiplier analysis in the
context of what I think you called a Caddo-Bossier situation.
     A    Yes.
     Q    You said that, if I recall your testimony, that
although you may have been involved in an initial attempt to
do input and output analyses, in that context, that it turned
into an accounting nightmare and it wasn't completed.
     A    Right.
     Q    Are there any other projects that you have worked
on that have undertaken input/output analyses to quantify
economic impacts, in terms of changes in sales, job income
and employment?
     A    I think the answer to that is we would all love to
do that.  As scholars we would love to have the opportunity
of developing our own Leontief type input/output
coefficients.  The problem is the cost and the resources that
are required to develop those original estimates.  
               So what university economists have tended to do is
rely on the U.S. Department of Commerce and to rely on them
to develop the basic input/output multipliers, and so what
you find is the adaptation of those multipliers for the
purpose of developing estimates of inter-industry
relationships from a set, you know, or given reference base.
                                               We had, when I was Chairman of the Food and
Resource Economics Department, we had a major effort in this
area and our department were probably the leaders in the
State of Florida in working with the State of Florida
Department of Commerce and other university economists in
developing ÄÄ trying to develop better coefficients at a
micro level.
               One of the problems that you have with the Leontief
input/output coefficients is that they tend to be very
aggregative, they tend to aggregate a two-sector SIC code as
opposed to a four-sector or five-sector ÄÄ in other words,
they tend to aggregate agriculture in general, and what we
found, those of us in agriculture economics, at least in
Florida, that have attempted to use input/output multipliers,
we have found that sometimes the federal government's
multipliers, as they apply to agriculture, do not dis-
aggregate to the level by industry or they do not dis-
aggregate to the level by county or by sub-region to the
level we would like, and we try to do the best we can with
the available data and make reasonable estimates from what is
available.
     Q    Are you familiar with the Rims 2 multipliers?
     A    Generally.
     Q    Are those among the U.S. Department of Commerce
multipliers that you're referring to?
                     A    Yes.
     Q    Have you ever used the Rims multipliers before this
case?
     A    I have utilized the work of others and I don't
regard myself as presently a regional economist.  So when it
comes to multipliers, and even in this case I defer the
specific estimate of multipliers to those experts who spend
much of their career in ÄÄ so I defer to those, and in this
particular application we also defer to those references of
those individuals that have developed what we think are
reasonable estimates.
     Q    Let me see if I can close in on what I'm trying to
get at in my questioning here.
               Have you ever developed an input/output model?
     A    Yes, I did, in Caddo-Bossier Parish.
     Q    That was the one you commenced the analysis, but
did not complete it?
     A    And I might explain why it was not completed, give
you the reason for it.
               We were trying to determine the inter-industry
relationship to agriculture, to non-agriculture, in northwest
Louisiana.  One of the key industries in northwest Louisiana,
in addition to agriculture, happens to be natural gas and
petroleum.  
               What we were asking the natural gas and petroleum
industries, of northwest Louisiana, was to give us the data
in an accounting sense that bifurcated their data for just
those two parishes, Caddo and Bossier Parish, and their
relationship of buying inputs or selling supplies to
agribusiness components.  So it didn't work out.  
               Also I think that I mentioned that I have taught
Leontief input/output multipliers.  I have had Mr. Leontief
as my personal guest.  I mean, I have listened to him in
lectures.  I have been trained by Mr. Leontief.  I don't feel
I'm a stranger to the analysis.
     Q    And other than your work in the Caddo-Bossier case,
you have never completed an input/output analysis of economic
impacts on sales, income and employment?
     A    Not directly.
     Q    Okay.  I asked you about Rims before and you
testified that you used the work of others concerning Rims
and you don't consider yourself a regional economist, but
have you ever used Rims multipliers to estimate indirect or
induced impacts?
     A    Yes.
     Q    In what?
     A    In citrus.
     Q    Could you tell me about that?
     A    That's the application I think I mentioned with
respect to what is the employment impact of a particular
policy action in citrus and how that might impact employment
and sales, and I don't have publications on this, but I have
given papers and made presentations where, if I recall, the
coefficient was ÄÄ unemployment, I can't recall the
coefficient, but I can recall the sales coefficient on
processing of citrus to be above 2.4, and the point we made
with the industry and others, about value added agricultural
industries, is that when there is a processing activity or a
packing activity the sales and employment multipliers are
much larger than when the agricultural product is not
processed or packed locally.
     Q    So the work that you have done, doing input
analyses of the impact of citrus policies, looked not only at
employment impacts, but also at sales impacts?
     A    Yes.
     Q    Okay.  And I'm sorry, but did you indicate that you
had used Rims multipliers?
     A    Well, those are multipliers that are basically
Rims.  They are authored by other individuals.  You know,
they're in publications of other individuals.
     Q    Are they taken from Rims multipliers?
     A    I believe they are.
     Q    Okay.
     A    My understanding is that they are.
     Q    Have you ever estimated indirect or induced impacts
by any other techniques?
     A    Well, I have estimated economic impacts within.
               Is the question in the context of Leontief
input/output analyses?  Is that the question?
     Q    Yes.
     A    I don't recall.
     Q    Okay.  Moving back up to my initial question in
this colloquy, about work you might have done on economic
impact and assessment of resource management actions,
proposed to remedy environmental problems.  
               Your testimony so far sounds to me like it's
concerned only with developmental proposals, proposals to
stimulate economic growth or develop a particular industry;
is that a fair characterization of your testimony?

                         MR. BURGESS:  Object to the form.
                         ANSWER BY DR. POLOPOLUS:  Well, within the ÄÄ
          I'm not sure I understand the question, but it's
          not a characterization, it doesn't adequately
          characterize my output, all of my output.

BY MR. SAXE:
     Q    Would you identify for me any input/output analysis
of economic impacts that you have done that pertained to
proposed actions involving environmental remedies, as opposed
to economic development?
     A    Placed in the context, as I understand your
question, when you constrain it to input/output analysis, the
answer is I can't recall having done input/output analyses in
that context.
     Q    Have you. . .
     A    Other than what I have indicated.
     Q    Which of the projects that you worked on would you
say did involved ÄÄ when you say other than what you have
indicated, I'm not recalling whether you indicated any of
your work so far dealt with environmental remedies as opposed
to. . .
     A    Oh, environmental remedies, I'm sorry if that's
part of your question. . .
     Q    Okay.  The focus of my question is economic impact
analyses or input/output analyses of economic impacts of
proposed environmental remedies.
     A    No, that's not an area ÄÄ that's not my bag.
     Q    So your work, as I am attempting to characterize
your testimony before, your work involves, to the extent that
you had done input/output analyses or economic impact
analyses, it's been of economic developmental activities?
     A    Economic activities, maybe.
     Q    Okay.  That's fine, thanks.
               Are you familiar with the term benefit cost
analysis or cost benefit analysis?
     A    I have heard the term.
     Q    Does it have a specialized meaning in your
profession?
     A    Very specialized meaning.
     Q    Have you ever done any benefit cost analysis or
cost benefit analysis?
     A    Again, that is in the province of natural resource
economists and I'm not prepared to testify, nor am I actively
involved in "benefit cost analyses".
     Q    Okay.  Dr. Polopolus, I'd like to talk a bit about
your retention as a potential expert witness in the case.
     A    Yes.
     Q    You have been designated by the League to give
potential expert testimony in a case on the South Florida
Water Management District's ongoing economic study and on
regional and statewide economic impacts of the SWIM Plan.  
               Is that consistent with your understanding of the
potential scope of your expert testimony?
     A    Yes, it is.
     Q    Are there any additional areas you might be giving
expert testimony?
     A    Would you restate what you just said?
     Q    Yes.  As a matter of fact, if you would like to
take a look at the League's expert witness designation, that
would be fine. . .
               Let me grab that.  
               There you go.
     A    All right.  
     Q    My question is, are there any areas, besides the
District's ongoing economic study and regional and statewide
economic impacts of the SWIM Plan, that you might give expert
testimony on in this case?
     A    I don't intend to.  I'm not aware of.
     Q    What do you understand by the reference to the
District's ongoing economic study?
     A    What that refers to, I believe, is the Hazen and
Sawyer contract to conduct a study of economic impact, and my
role is to evaluate that study and their results.
     Q    Would that include economic benefit analysis that
Hazen and Sawyer might have been contracted to do?
     A    I may have seen some of their earlier work on that,
but I'm not ÄÄ I don't believe I have been asked to be
responsible for professional critique of benefit analysis.
     Q    Have you ever served as a litigation expert in a
case, other than this one?
     A    Yes.
     Q    Can you tell me about them, starting with your most
recent?
     A    I don't do a lot of this, so I have to go back over
some time, but the most recent was in a Federal District
Court of Danville, Virginia, where I was an expert witness in
a federal case involving the Immigration Reform Act, in
particular the H-2 Program of temporary foreign workers in
tobacco industries in Virginia and North Carolina.
     Q    Did your testimony involve economic impact issues?
     A    Yes, it did.
     Q    Could you tell me about that?
     A    The issues had to do with the adverse effect wage
rate and that was the primary focus of the litigation and the
setting of the adverse effect wage rate as it might affect
the number of foreign workers that would be available, and it
had to do, therefore, with the cost of production in tobacco
and economic viability of those industries vis-...-vis
immigration policy.
               Economic impact, definitely, but economic impact in
the context of the South Florida case, not really.
     Q    Okay.  Did you testify concerning the effects of
that policy or potential effects of the policy on sales for
the industry?
     A    That was one part of it.
               I was a part of a team and I was not the major
economist player in that particular effort.  Dr. James Holt,
consulting labor economist, in Washington, D.C., was the
primary economist that I worked with and I worked with him as
an agricultural economist, someone familiar with agricultural
industry, agricultural economics, things of that nature.
     Q    Who retained you in that case?  I don't mean the
name of the person, I mean the name of the party or entity.
     A    To be honest, I can't recall the exact name, but it
was an organization of tobacco growers in North Carolina and
Virginia.
     Q    And what was the position of the tobacco growers in
the litigation?  
               Let me ask you this first.  Who were the other
parties in the litigation?
     A    The other party, I believe, was the U.S. Department
of Labor, but it's been about eight years and I cannot recall
the details.
     Q    So this was about '85?
     A    Something like that, '84, '85.
     Q    So it was basically a case in which the government
and the industry were on opposite sides of the controversy?
     A    Right.
     Q    Okay.  Any other cases in which you have given
expert testimony?
     A    In a ÄÄ I'm restricting this to actual courtroom
situations, right?
     Q    If you would, you can broaden that to include not
only a courtroom, but also administrative hearing form, like
the one involved in these SWIM proceedings.
               Are you familiar with the distinction?
     A    Yes, I'm familiar with the distinction.
     Q    Okay.
     A    Most of the work that I have done, as an
agriculture economist, has involved legal proceedings that
never went that far.  They were settled out of court or
something happened, you know, you do the work and so on and
so forth, and I can talk about a recent one that I'm involved
in or was, I don't know whether I'm still involved in it or
not, where I'm an expert for the U.S. Department of Justice.
     Q    What would that one be?
     A    That one involved the tax credit policy, under tax
law of the sixty cent a gallon tax credit that is available
to manufacturers of a product called ETBE, a derivative
product which oxygenates a fuel and one of the basic raw
materials of that is ethanol.
               So I was retained by the U.S. Justice Department a
couple of years ago to look at the economic impact of that
regulation.
     Q    Do you know the name of the attorney at the Justice
Department?
     A    Stewart Gibson.
     Q    Do you know the name of the case?
     A    No, not really.  I do know that it's an action
brought by a group of organizations, including certain
individuals, against the Justice Department.
     Q    What kind of organizations?
     A    I may misstate the names, but it's like the Sierra
Club and Defenders of the Environment, it goes on and on and
I'm not sure of all of them, and there are certain
individuals in Minnesota and different places that are the
plaintiffs.
     Q    Would it be fair to say that the challengers or
plaintiffs in the case are suing the Federal Government,
alleging environment grievances?
     A    They're alleging potential environment grievances
over the administration of this policy.
     Q    And what is the nature of your proposed expert
testimony in the case?
     A    Well, here again, I'm working with a colleague, in
this case Professor Schmitz, Professor Andrew Schmitz,
Chairman of the Department of Agriculture and Resource
Economics, University of California at Berkeley, and he and I
are working together evaluating the likely impact of this
policy.
     Q    Okay.  The likely impact of the tax credit policy?
     A    The tax credit policy.
     Q    That would be the economic impact?
     A    The economic impact, yes.
                     Q    Okay.
     A    Or would it have an economic impact?
     Q    Are there any other controversies, in which you had
been retained as a potential expert witness, whether or not
they went to trial, and you actually gave testimony?
     A    When you have a thirty-three year history. . .
     Q    You can start with the most recent. . .
     A    I don't have. . .
     Q    . . .ten-year period.
     A    We don't write these things in our r‚sum‚s and they
don't become part of our pedigree and we don't utilize them
for tenure or promotion or anything else, so. . .
     Q    So they fade from memory?
     A    Yes, they fade from memory, but let me throw out a
few.
     Q    Okay.
     A    One of them, which was my experience, I did file an
affidavit in the Northern California Federal District Court,
about 1975, involving the private action under antitrust law,
Federal Antitrust Law, dealing with pricing policy and in
particular allegations of price fixing against a group of
sugar companies in California and Hawaii.  
               I say private action, because the public action ÄÄ
it's my understanding that in the public action the
defendants in this case, the sugar industries, pleaded nolo
contendere to the federal charge and then they were facing
the private charges of industry members, namely the buyers,
and the vertical structure.  The buyers of sugar then filed a
trouble damage suit against the sugar companies.
     Q    Do you know who the manufacturers were in the case?
     A    It was a class action suit and there were literally
hundreds of plaintiffs.
     Q    What was the class?
     A    The class was the class of users of sugar.  They
were sugar ÄÄ at that time they were still using ÄÄ this was
in the 1970s ÄÄ they were still using sugar in soft drinks,
so I think there were some soft drink manufacturers, there
were canners, a whole variety of firms, candy manufacturers,
other users of sugar, who filed this class action against 
the. . .
     Q    Had you been retained by the industry defendants?
     A    I was, again, part of a team of economists that
were involved in looking at the economic impact and looking
at the economics of markets, sugar markets, and I was, I
guess, retained ÄÄ I guess you might say, I don't know how to
use the word retainer, but I was employed as a consultant by
the industry.
     Q    By the defendants?
     A    By the defendants.
     Q    Okay.  In the tax credit case for ETBE, I
understand you don't recall the name of the case, but do you
remember what court it's in?
     A    I believe it's in a Washington, D.C. court, but I
can't say for sure.
     Q    Okay.
     A    It hasn't, to my knowledge, gone that far and I'm
just doing some background economic work.
     Q    Okay.  You're doing well with remembering these
faded cases, but you indicated a few moments ago that you
would throw a few out.
     A    Yes.
     Q    What are the other ones, besides the private
antitrust action?
     A    Okay.  Another one had to do with a case in the
federal ÄÄ a likely case in the federal court in Boston, and
that was also an antitrust action brought about by one
private party against another party, and it had to do with
cranberries and it had to do with the provision of antitrust
law that dealt with sales below cost, and one rival was
alleging to another rival that:  You're driving me out of
business, because you're pricing below cost and I believe
that's a violation of the antitrust law and, therefore, I am
seeking damages and remedies and so forth.
               In that particular case what became important was
the economics of cranberry marketing or cranberry packing,
cranberry harvesting, cranberry production and cranberry
juice processing.  
               So I began an analysis of using economic
engineering techniques to look at the economics of those
activities involved in the production, harvesting, packing or
processing of cranberries.
     Q    Who were the parties in the case?
     A    The parties were ÄÄ I think the plaintiff in the
case was a firm called Dekus and the defendant was Ocean
Spray Growers Cooperative.
     Q    And who did you work for?
     A    I worked for Ocean Spray.
     Q    About when was this case?
     A    This was about ÄÄ I recall it was the time of the
last presidential election, so it would have been 1988.
     Q    The California sugar company private antitrust case
was about when?
     A    That was '74/'75 era, in that vicinity.
     Q    And the ETBE tax credit case?
     A    That began about two years ago, a year and a half
ago.
     Q    Are there any other cases in which you were
retained as an expert witness?
     A    There was one in Gainesville, and I believe I had a
deposition in this office, and it involved transportation law
in trucking and at the time we had strict regulations on
trucking rates and that was in a state court and I was
retained for a relatively minor amount of time to testify
regarding economic impact of the regulations on freight rates
and trucking rates and restrictions and so forth.
     Q    About when was that?
     A    Oh, this has got to be fifteen years ago.
     Q    All right.  So about '78?
     A    Something like that.
     Q    Okay.
     A    I remember the trucking firm or the moving 
company and they have since gone out of business.  I can't
recall. . .
     Q    Who were the parties?
     A    All I remember is the trucking company that I was
retained with.
     Q    And who was that?
     A    I don't remember the name of the firm, but the
individual was Wayne McKubbin.
     Q    And it was a private trucking company?
     A    Yes, here in Gainesville.
     Q    And they were sued by a competitor or they sued?
     A    They were being sued, I believe.
     Q    And the competitor was another trucking company?
     A    I believe.
                     Q    Any other retentions as a potential expert witness?
     A    Yeah, there was one with AmStar Sugar in New York,
sugar refiner.
     Q    And that was in?
     A    That was in a potential case that never went to
trial.
               All of these, except for the one on trucking and
the one in the Federal District Court in Virginia, never went
to trial.
     Q    Okay.
     A    The AmStar case involved, if I recall, a sugar
brokerage.
     Q    What court?  You said New York.
     A    I believe some New York court, but it never went to
trial and. . .
     Q    Who were the parties, besides AmStar Sugar
Refiners?
     A    It was another private firm, but I don't recall.
     Q    Was AmStar plaintiff or defendant?
     A    I don't recall, I really don't.
     Q    Do you remember whether they. . .
     A    I believe they were the defendant and the nature of
the case had to do with whether or not AmStar could drop a
general line broker and go ahead and develop their own
brokerage force, and it had to do with the brokerage ÄÄ the
brokering of sugar, if I recall, and my role on that was just
to look at sugar brokerage as it existed and look at
specialization in sugar brokerage versus companies' ability
to develop their own services by not retaining brokerages.
               I can't remember the legal issue that was involved.
     Q    So was your retention, your expertise in this case,
did it involve economic impact, per se, or more of an
economic feasibility?
     A    It wasn't economic feasibility, it was economic
impact, in terms of the economics of the firm, you might say. 
The economics to the firms that were involved, namely the
brokerage firms that were ÄÄ if you look at sugar brokerage
over history, from the time of the American Revolution to
today, you would find that sugar brokerage, as an industry,
was specialized sugar brokers and so forth, that industry has
waned and waned in terms of numbers and so on.  So some of
the last vestiges of some aspects of that specialized
business were concerned about their economic viability.
     Q    So this was microeconomics?
     A    It was firm economics.
     Q    Firm economics.
     A    Yes.  It affected the brokerage industry, but that
wasn't. . .
     Q    But that wasn't the nature of your potential
testimony.
                     A    No, I was just called on as somebody that had some
knowledge of sugar marketing and sugar brokerage.
     Q    Well, these may be faded memories for you, but
they're all interesting.
               Are there any other retentions, as a potential
expert witness, that you can recall?
     A    No.
     Q    The two cases that you indicated went to trial, the
Gainesville trucking case and the Immigration Reform Act
case, did you testify in both of those cases?
     A    Yes.
     Q    Okay.  Moving to this case, if we can.
               When were you retained as an expert in this case?
     A    I think it was sometime in late May or early June
of 1992.
     Q    And by whom were you retained?
     A    By the League, through Peeples, Earl & Blank.
     Q    Were there any other services that you were
retained to provide, besides potential expert testimony?

                         MR. BURGESS:  Object to the form.
                         MR. SAXE:  Grounds?
                         MR. BURGESS:  I don't think he said he was
          retained to provide potential expert testimony.

BY MR. SAXE:
     Q    Let me rephrase the question, Dr. Polopolus.
               Were you retained to provide potential expert
testimony?
     A     I think that was in the background, but I believe
the initial focus was to review the work of Hazen and Sawyer,
with the idea that there may or may not be litigation
involved.
     Q    Was the nature of your retention or employment
altered at some point between the initial retention and now
to include, more explicitly, providing potential expert
testimony?
     A    Well, I believe that it became clear in recent
months that my role might involve litigation.
     Q    All right.  So initially, it's your testimony, that
you were retained to review Hazen and Sawyer work.
               Can you elaborate on what you were asked to do in
connection with that review?
     A    Yeah.  My role was to work as part of a team with
Dr. James Richardson, in terms of evaluating the work of
Hazen and Sawyer, where they were the primary contractor to
the District to evaluate economic impact.
     Q    Were there any other individuals or entities that
you would be working with or have been working with?
     A    You know, at the time that I was contacted ÄÄ I was
contacted about this maybe in March or April of 1992, and
there was a period of time there where there was some
uncertainty as to my availability and so when all of that got
clarified and we discussed seriously my involvement, I had to
indicate to Mr. Burgess, whom I was directly in contact with
in these discussions, with Peeples, Earl & Blank, that in
view of my heavy teaching, research and other commitments at
the University of Florida, that I could ÄÄ if I were to
become involved that I would have to become involved under a
particular arrangement, in terms of services and support.
     Q    So the initial question, regarding your
availability, had to do with your other obligations as a
professor at the University of Florida.
     A    Right.  It basically ÄÄ what that meant, and what I
mean by that, is that I would not have the time to crunch a
lot of numbers and to conduct the laborious mathematical
calculations and computations, personally, that might be
involved.
     Q    Okay. 
     A    At this point I wasn't aware of any ÄÄ at this
early point I was not aware of other economists being
directly involved. I was viewing this in terms of what my
role would be as an economist assisting the evaluation of the
work of others.
     Q    Were you first asked to work on this controversy or
issue through IFAS?
     A    No, IFAS never asked me to work on this.
     Q    Did anyone else ask you, before you were contacted
by the League?
     A    Yeah, there was a communication that I received
from one of the sugar officials in ÄÄ about the time the RFP
was issued.
               I received a communication from Mr. Wedgworth,
saying:  Leo, why don't you consider applying for this
particular grant and conduct the analysis for the District?
               I did receive that communication.
               I received from him, not the District, but from Mr.
Wedgworth, a copy of the research proposal format.
     Q    Do you know Mr. Wedgworth from his dealings,
outside the context of this case?
     A    I had known him by reputation, I had interviewed
him in connection with a graduate student research, but I
didn't have any long established relationship with Mr.
Wedgworth.  I knew who he was.
     Q    You testified that he said:  Leo, why don't you
apply. . .
     A    Yes.  People have a hard time with Polopolus and
tend to shift quickly to Leo.
     Q    Okay.  Were you ever asked to work on this as an
IFAS project?
                     A    No.
     Q    You said there was an initial question regarding
your availability and then I believe you testified that it
was resolved.  You mentioned an arrangement regarding
services and support, but was there anything else that
happened that resolved the initial question about your
availability?
     A    Well, I don't know how important it is to get into
the details of that, but if you would like me to describe
what happened between my initial contact from Mr. Burgess and
the time I said I would be available to be considered as an
economist for the League, I would be happy to go through the
details, if you would like those details.
     Q    Well, about when did you agree?  Was that May '92?
     A    Yeah, it was late May, early June.  It was sometime
in late May or sometime in June, but I can't recall the
precise date.
     Q    Well, why don't you tell me what transpired between
when you were initially contacted by the League and when you
were retained?
     A    Well, I was initially contacted by Mr. Burgess and,
I believe, a representative of Peterson Consulting came to
Gainesville, pretty much like an interview, to see me, meet
me, talk to me, so forth, about my employment, and I
indicated to Mr. Burgess at the time that I might be
available, but I would have to get the approval of my
University of Florida, IFAS and the university, before I
would commit myself to this effort, and then I had a meeting
with my department chairman and discussed this and he said
that it didn't look very promising that IFAS would approve my
involvement, but he would discuss it, without filling out all
the formal paperwork, he would discuss it with my dean, and
he meant in particular the Dean for Extension, although I
don't carry an extension appointment, all consulting of this
nature has to be approved by the Dean for Extension, in
addition to the Vice President for IFAS.
               So I got another call from the department chairman: 
Leo, we're going to have to talk about this, and I have this
lengthy letter from the dean saying that for a variety of
reasons your request, as you're proposing it, would not be
approved.
               So I so indicated to Mr. Burgess, that it would not
be approved.
     Q    Was that in March of '92?
     A    That was probably in April of '92.
     Q    Okay.
     A    Then I began to think about that and I said:  Well,
wait a minute, what is the IFAS policy with respect to
outside employment?  And I started doing a lot of my own
research, collecting my own documents, trying to find what
separates an approval from a disapproval, and my own research
led me to the conclusion that IFAS did not have a coherent
policy.
               At that point I retained two local attorneys and I
said:  This is my problem and I'm doing this not for Leo
Polopolus but for other similarly situated.
               At that time I was very concerned that one of my
colleagues, Dr. Boggess, had similarly been told that he
could not consult.  
               So I said:  Well, I'm nearing retirement, I don't
have to worry about this employment situation, I'll take some
risks ÄÄ and I thought for the good of my colleagues.  
               So I retained two attorneys and I presented them
with all of the policies, all the documents and so on and so
forth.

                         MR. BURGESS:  Leo, I want to interject, for
          the record, that you have a privilege between what
          you say to attorneys and what they say to you, and
          you don't need to disclose either voluntarily or in
          response to questions any of those communications,
          if you don't desire to.
                         So you need to keep that in mind, vis-...-vis
          your discussions with attorneys.
                         DR. POLOPOLUS:  Thank you.
                                                         MR. SAXE:  I would also interject that you
          don't need to give me the substance of any
          communications with counsel, but unless counsel
          instructs you otherwise, I would expect you ÄÄ you
          can, to the extent that you remember it, and in
          response to my question, tell me about
          conversations that ÄÄ or communications that took
          place and identify the approximate dates and the
          nature of the conversation of the subject matter.
                         MR. BURGESS:  I disagree with Mr. Saxe.
                         I don't need to instruct him not to answer
          concerning matters of discussion between he and
          other counsel that he had employed.  I'm not his
          counsel for that purpose and I don't think I have
          the right to instruct him not to answer, but I'm
          just pointing out for his benefit that he has
          privilege bestowed on him, in the State of Florida,
          that he need not reveal the substance of
          communications between himself and counsel, should
          he decide that he does not want to do so.
                         MR. SAXE:  And how will I know when privilege
          is being invoked, counsel?
                         MR. BURGESS:  He can invoke that privilege on
          discussions he had between himself and counsel.
                         MR. SAXE:  Well, if you're instructing Dr.
          Polopolus that, rather than waiting for you to
          object on grounds of privilege, that he can tell me
          a conversation took place and this was the nature,
          but he's not going to tell me, on the grounds of
          privilege, is that your position?
                         MR. BURGESS:  With respect to matters that he
          had, he as a client had with his attorneys, in this
          particular subject matter, yes, I'm advising him
          that he has that privilege and he can make that
          determination.
                         MR. SAXE:  Are you referring. . .
                         MR. BURGESS:  You're blowing this out of
          proportion, Keith, it's a simple comment on my 
          part to him that he, as a client of an attorney, in
          this state, has a privilege not to reveal
          substantive communications between himself and the
          attorney.
                         MR. SAXE:  So your instructions are limited to
          the retention by Dr. Polopolus of the two local
          attorneys in any matters that were communicated
          between them?
                         MR. BURGESS:  Yes.
                         MR. SAXE:  Thank you.


BY MR. SAXE:
     Q    You can go ahead, Dr. Polopolus.
     A    Okay.  
     Q    You said you were nearing retirement and you had
decided. . .
     A    I had decided that I would consult these attorneys,
and meanwhile I wrote a letter to the President of the
University of Florida and in that letter I basically, again,
asked for the policy and asked for the equity at a time when
it appeared that professors in some colleges were being
encouraged to consult and other colleges they were given so
many days a week, and that kind of stuff, and at a time when
our former President was on the Board of ÄÄ you know, at the
time on boards of Johnson & Johnson, and at a time when the
Chairman of the Board of Regents, without even approval by
the Board of Regents, the Chancellor of the Board of Regents,
not the head, but the Chancellor, took on a directorship with
Florida Power, so on and so on, all of this stuff going on
and on.
               So I said:  Wait a minute, what's going on here?  
               So I wrote a letter to the President and so on and
so forth.
               Well, based on advice from my counsel on that
issue, I then decided that I would take certain risks,
employment risks, and say that I would be available.  
                                               Where it stands right now?  The University has
asked me to resubmit that application and I have so
resubmitted that application and it's in process.
               All I have asked the university to do is if they're
going to fire me over this particular issue that they give me
the opportunity to resign first.  That's all I've ever asked.
     Q    Okay.  I don't want you to give me any of the
details of your communications with your attorneys in this
matter, but could you tell me who the two attorneys are that
you referred to?
     A    Yes.
     Q    What are their names?
     A    Jonathan Wershow and Pamela Schneider. 
     Q    Are they here in Gainesville?
     A    Yes.
     Q    You testified that you're nearing retirement.  Can
you elaborate on that for me?
     A    Yes.  I'm fifty-nine and a half years old and I
have had thirty-three years of service and I intend to retire
from the University of Florida, but not to retire as a
professional consultant economist, when I become sixty-two
years of age.
     Q    So that would be three years from now?
     A    Two and a half.
     Q    Okay.  I want to go into a chronology of your work
in preparing for this case, but before we move off the topic
of your retention I have a couple of things I want to get
some elaboration from you on.
               When you said that you needed an arrangement or an
arrangement was necessary regarding your service and support,
because you didn't have time to crunch numbers or do
calculations, what did you mean?  Can you elaborate on that?
     A    Just that.  That in view of my responsibilities at
the University of Florida, and the various hats and roles
that I play, and the likelihood of a large amount of data
aggregations and data calculations and so forth, that I
would, if involved, I would prefer or request that I have
assistance or support in carrying out those calculations and
the preparations of tables and adding and subtracting and
dividing and so forth.
     Q    What assistance or support is being provided or
will be provided?

                         MR. BURGESS:  Object to the form.
                         MR. SAXE:  Compound?
                         MR. BURGESS:  Yes, and he testified with
          respect to what was provided.

BY MR. SAXE:
     Q    I'm sorry, Dr. Polopolus, you said you requested
assistance and support?
     A    Yes.
     Q    Did you get the response?
     A    Yes, I did.
     Q    What was the response?
     A    The response was that that support would be
provided.
     Q    And what support specifically was to be provided?
     A    That support was to be provided with the assistance
of Peterson Consulting.
     Q    Exclusive of what Peterson was going to do in
supporting you, what did you agree to do specifically?
     A    At what stage?
     Q    At that point in time when this initial request was
made.
     A    I agreed to evaluate the work of Hazen and Sawyer
and to become generally familiar with the issues that ÄÄ
economic issues that were extant at that time, talking about
mid-June 1992.
     Q    Did you prepare or was there prepared for you a
statement of work that described what you would do?
     A    There was a contract that I signed with Peeples,
Earl & Blank.
     Q    Did it contain a description of the tasks that you
would perform?
                     A    I don't recall the terminology of that contract,
but it provided a general outline.
     Q    Dr. Polopolus. . .

                         MR. SAXE:  Rick, do you know whether a copy of
          that contract has been. . .
                         MR. BURGESS:  It will be on our privileged
          list.
                         MR. SAXE:  Okay.
                         MR. BURGESS:  I think, except to the extent
          that if it does contain a scope of work, and I
          don't think it does, I think it's discoverable and
          I will provide it.
                         MR. SAXE:  Okay.

BY MR. SAXE:
     Q    In the next three months, excluding June of '92,
what was the division of labor between you and the Peterson
Consulting group and Dr. Richardson in any work that you did
analyzing Hazen and Sawyer's analysis?
     A    Well, in taking that time sequence from mid-June,
the very first thing that was happening was that Hazen and
Sawyer was beginning to issue reports of certain phases of
their work, sort of like preliminary papers on -- I think
they called them Task Force Reports, and my first involvement
was to review those reports and I recall -- I think my first
report was around June the 29th, 1992, where I reviewed Hazen
and Sawyer's Task Force Reports 1, 2, 3, not 4, but 5,
something like that, and then other task force numbers came
later on.  So from mid-June to mid-July most of my work was
general familiarization of the issues and the work of others
and including engineers and reports and economic reports, so
on and so forth.  But July 15 was a very significant date,
because that was the date that the preliminary report of
Hazen and Sawyer became publicly available.
     Q    Before the July 15 date, what did you or -- you
were just doing general reading and review of the task
reports that were issued by Hazen and Sawyer?
     A    Right.
     Q    How did you acquire those task reports?
     A    They were sent to me by Peeples, Earl & Blank, I
believe.
     Q    And you did not do any other work between June and
before July 15, besides reading those task reports?
     A    And commenting on them and -- I can't recall the
exact date. . .
               See, in the June period, June '92 period, I was not
aware of Dr. Richardson's involvement, but I was involved in
and part of the work was, if I recall, and I do recall, Hazen and
Sawyer's initial reports discussing the FLIPSIM









methodology as the best methodology and characterizing a
review of methodology, I think an original scope of work, and
so on and so forth, and I began to become more inquisitive as
to that methodology and began to review that methodology,
independent of any work of Dr. Richardson in this particular
application.
               At some point, and I discussed this with Mr.
Burgess:  Hey, there's an awful lot of number crunching that
was going to be involved here and it would be nice if we had
some analytical capability that goes beyond my resources and
my time ÄÄ and somewhere along this marriage came along and
somewhere in early July I began to ÄÄ I was advised that Mr.
Richardson was a part of the team and at that point, sometime
in early July, I began to work directly with Dr. Richardson,
agriculturist-economist at Texas A&M University, on
evaluating the economic impact issues.

          (Thereupon, a short recess was had; whereupon, the
          following proceedings were held:)

BY MR. SAXE:
     Q    Dr. Polopolus, before we get back to the chronology
that you were giving me, just a couple of other matters on
your retention as a potential expert witness in the case.
               You indicated that you had a contract sometime
around June of '92, when you were retained, and we don't know
whether there's a scope of work, but counsel will take a look
at it and see if there is.
               Has there been an evolution of your retention that
is formalized in contract amendments or revisions in a scope
of work or any other form?
     A    Not in terms of written documents, but there has
been an evolution in terms of communications from Mr.
Burgess, in terms of the nature of my work.
     Q    Could you describe that to me, please, with respect
to your work as a potential expert witness in the case?
     A    Well, I think early on it wasn't clear that I would
be involved as a potential witness.  I think in the early
phases, from June 22nd to maybe through August of '92, it was
more or less the concentration on evaluation of Hazen and
Sawyer's work, but in the fall of '92 it became more clear
that I may be involved in testifying in some litigation.
     Q    Okay.
     A    I can't recall the precise date, but. . .
     Q    Can you tell me more about how that expressed
itself?
     A    Yes, through telephone communications with counsel,
Mr. Burgess.
     Q    Thank you.
               One other question on your retention in the case.
         I hate to pry, but it's a matter appropriate for
discovery.
               Can you tell me about your financial arrangement
for your work on the case for the League?
     A    I think the contract, initial contract, established
the financial compensation that I would receive for the work
that I performed.
     Q    And what is that compensation?
     A    If I recall, it's slightly less than a hundred
dollars an hour.
     Q    That is for your work both testifying and other?
     A    There's no distinction, right.
     Q    Was there any quantification of how many hours of
work you would be providing on the case?
     A    I believe the original contract had a limit.
     Q    Do you recall. . .
     A    Upper limit.
     Q    Do you recall?
     A    I vaguely recall a number of twenty-five thousand
as an upper limit.
     Q    Has that been modified by any contract amendments
or otherwise?
     A    No.
     Q    Can you tell me how many hours of work you have
done thus far on the case?
                       A  The time and effort depends on the nature of Hazen
and Sawyer, so there was a lot of time and effort in July and
August and very little since then.  So the average amount ÄÄ
I don't know if you would average that and say:  Well, there
are periods of inactivity and periods of activity.  I would
say an approximate average would be about one day a week.
     Q    Okay.  Going back to your chronology of the work
that you have been doing.
               When you said you weren't aware initially of Dr.
Richardson's involvement in June and then sometime in early
July you became aware of his involvement.
               How did you become aware of Dr. Richardson's
involvement, can you elaborate on that?
     A    Well, again, through a telephone communication from
Mr. Burgess.
     Q    And what did you understand Dr. Richardson's role
was going to be?
     A    Well, at that time the relative responsibilities
became intimately clear and one doesn't need to be a rocket
scientist to figure out that Dr. Richardson, since Hazen and
Sawyer we assumed was using FLIPSIM and since Dr. Richardson
is the author and originator or FLIPSIM and I'm not, that Dr.
Richardson would have the responsibility of the FLIPSIM
analysis, which is the farm level, agricultural level
production analysis, and my responsibility would then be
concentrated in the aggregative impact analysis.
               So at that point it became a division of labor, a
division of responsibility between Dr. Richardson on one
hand, as a member of the team, and myself on the other as
dealing with the multiplier analysis and the aggregative
economic impact analysis.
     Q    Can you define or explain aggregative impact
analysis for me, what you mean by that?
     A    Well, taking the results of FLIPSIM, which were
cast in terms of representative model farms, casting that
impact in terms of the EAA as a region, and any related
impact to the broader geographic region around the EAA and
any broader impact around the state of Florida economy.
     Q    When you say FLIPSIM result impacts concerning
representative model farms, I'm not sure ÄÄ let me see if my
statement is fair or not and maybe we can get a clearer
understanding that way.
               Were the FLIPSIM results expected to be direct farm
level impacts and the aggregated impact analysis would be
secondary impacts, using those?
     A    No.
     Q    Okay.
     A    No, they would be both direct impacts.  We're still
talking about the primary industry, namely ÄÄ we're still
talking about, you know, the primary industry being
agriculture.  The question is whether you have it at the firm
level or the industry level of the geographic area levels.
               Dr. Richardson's analysis did not do the
aggregation for the industry of producers.
     Q    What does the FLIPSIM. . .
               When you say Dr. Richardson's analysis, that would
be the FLIPSIM analysis, or is there more to it than that?
     A    Yes.  The FLIPSIM analysis is a comprehensive tool
that's used to analyze economic impact and we can discuss
that and describe that, you know, to the extent that you care
to discuss that aspect of it.
               I had to have a very good understanding of what
that model was in order to better understand what we were
receiving from him, in order to do our aggregated analysis.
     Q    It may facilitate this testimony if we do it a
little bit later when we're referring to documents, but for
right now, in terms of the division of labor, I'm really
trying to just get a handle on the division of labor.
               So Dr. Richardson was going to use FLIPSIM to do
firm level impacts, you were doing the aggregation to the
industry, but still all direct impact.
     A    Yes, that's correct.
     Q    Okay.
     A    And then from that I was responsible for doing the
indirect.  So, in other words, the question is:  How many
acres in the aggregate would be lost to production as a
result of BMP, a tax assessment, the STAs, you know, what's
the aggregate acreage, aggregate this or that.
               We started with ÄÄ let's say the aggregate acreage,
what would be the impact of alternative policies?  FLIPSIM
would give, sort of at the firm level, and then my
responsibility was to aggregate that for the industry and
then given those aggregations apply the Leontief multiplier
analysis to determine the direct and indirect.
     Q    Is there any other input/output analysis
methodology besides the Leontief multiplier?
     A    Yeah, I mean, you can use the word input-output to
refer to efficiency ratios, you know, but in the context of
what we're doing. . .
     Q    Economic impact analysis.
     A    I'm not familiar with any technique that is used
for economic impact analysis as we're utilizing or conceiving
it.
     Q    Now, were you to do, at that point in time, before
the July 15th draft, Hazen and Sawyer draft, when you became
aware of Dr. Richardson's involvement and the division of
labor became clear, were you to do the number crunching and
calculations for the industry-wide aggregation and for the
secondary impact clarification from Dr. Richardson's analysis
or was somebody else to do that work?
                     A    I don't understand the question.
     Q    Let me streamline it a little bit.  
               You testified that you were going to do the
industry aggregation from Dr. Richardson's firm level results
and then provide the input-output analysis to check secondary
impacts.
               Were you going to do that all by yourself?
     A    No, as I said earlier, in any context I needed
assistance with the number crunching.
     Q    And that was the Peterson assistance?
     A    That's where the Peterson involvement came in to
assist me in carrying out those data manipulations and data
calculations.
     Q    Who is the Peterson team or group that would be
providing this?
     A    Peterson Consulting is a well-known internationally
recommended economic consulting firm that, to my
understanding, was retained by Peeples, Earl & Blank.
     Q    Do you understand that Peterson Consulting or any
employee of Peterson Consulting has been designated as a
potential expert witness in the case?
     A    I don't know anything as to whether they are or are
not.
     Q    Were there any particular individuals at the
Peterson Consulting firm that are part of the team assisting
you?
     A    There were a number of people.

                         MR. BURGESS:  Object to the form.

BY MR. SAXE:
     Q    Can you give me the names of the individuals
comprising the group at Peterson Consulting providing you
support or assistance?

                         MR. BURGESS:  Object to the form.
                         MR. SAXE:  Grounds?
                         MR. BURGESS:  He testified only that they
          provided assistance to him with what he did back in
          July and August, not that it's ongoing.
                         MR. SAXE:  Let me rephrase the question.

BY MR. SAXE:
     Q    Who were the people at Peterson Consulting who you
understood were going to be providing this assistance back in
June and July of '92?
     A    People at Peterson Consulting that I worked with,
who assisted me in the calculations, I believe beginning in
July, were a large number, but I believe it included Stan
Rolen, Andy Bernstein, and other members of their staff.
                     Q    Do you know who those members were?
     A    I did at the time, but I ÄÄ I believe there was a
Shelly, I can't remember the last names, Shelly Lofton, I
think, and a Hector somebody, and a Marsha somebody.  Excuse
me, but it's been since last July since I ÄÄ or August, maybe
early August, since I worked with some of them.
     Q    Did your contact with Peterson Consulting terminate
in July?
     A    Well, there hasn't been ÄÄ I wouldn't say
termination, but there wasn't very much activity at all after
mid-August.  In fact, I don't ÄÄ I don't know that I can say
no activity, but I don't know that ÄÄ there wasn't any
substantial amount of activity between me and Peterson until
the early December period when Dr. Richardson and I met with
the economists for the District and the economists for Hazen
and Sawyer in Hollywood, Florida, on December 16th, 1992.
     Q    So between August and December you had no. . .
     A    Basically. . .
     Q    . . .no interaction with Peterson Consulting?
     A    Right.
     Q    Did they continue to do work to support and assist
you during that period in your work as a potential expert
witness in this case?
     A    I wasn't doing very much in that period, so I don't
recall.
                     Q    Do I understand your testimony correctly that in
July you were assisted by Stan Rolen, Andy Bernstein and some
other people at Peterson Consulting, maybe a Shelly Lofton,
Hector somebody, somebody named Marsha?
     A    Yes.
     Q    And that that assistance and support continued
through August, but then there was nothing further until
December?
     A    That's my recollection.
     Q    Okay.  What assistance did Peterson Consulting
provide you in July?
     A    Okay.  Dr. Richardson and I worked out a basic plan
of research, in terms of evaluation of the Hazen and Sawyer
reports.  The division of labor was established, as I have
indicated.
               Then we bring it over to my area of work, then I
laid out the parameters of how we were going to analyze
economic impact and what multipliers were going to be used,
what definitions of impact we were going to include, that is,
what we were going to talk about, the baseline, and then once
we start with the baseline what we were going to talk about: 
Assessment rate at ten dollars an acre?  Assessment rate at
twenty-five dollars an acre?  Fifty dollars an acre?  A
hundred dollars an acre?  All these had a bearing on the
construction of our analysis.
                                               So given those decisions that Dr. Richardson and I
worked out, and then given the results of the firm level
analysis of FLIPSIM, then Peterson assisted in the ÄÄ what I
call the number crunching, assisted in giving the
coefficients for multipliers and giving the general data base
that is given in terms of the number of total acres, became
an important variable:  The total number of acres in sugar,
the total acres in sod, the total acres in vegetables, given
all that, then Peterson assisted in actually saying:  Well,
if we looked at this then what would be the jobs lost?  What
would be the acreage lost?  What would be the revenue lost? 
What would be the earnings lost?  As we had negative impact
from the policies ÄÄ alternative policies of the District.
     Q    Going back a little bit.  Before the July 15, 1992
Hazen and Sawyer draft came out, you indicated that you read
the task reports and commented.
               Did you prepare documents reflecting your comments
or were these notations that you made on the task reports
that you received, or both?
     A    If I recall, I prepared like a memorandum and I
believe I sent ÄÄ each of those memorandum were sent to Mr.
Burgess and I believe we provided copies of those, of my
comments of those early Task Force Reports, to you and
members of your counsel.
     Q    Were those the only written comments that you made
in your review of the task reports?
     A    Yes.
     Q    Before. . .
     A    That's correct.
     Q    Before the July 15th draft?
     A    Yes.
     Q    Now, the work that you described that was
contemplated in July, Dr. Richardson doing FLIPSIM farm level
analysis, you doing industry aggregation and Leontief
input/output analysis and Peterson assisting you in the
number crunching for those purposes, was that work that was
being done based on the early task reports that you had
reviewed and commented on?
     A    In part. 
     Q    What else did that work relate to?  Any other Hazen
and Sawyer work product?
     A    Well, their work product of their preliminary
report of July 15th and the interaction that I had with Dr.
Richardson regarding the critique that we made jointly of the
Hazen and Sawyer study when the draft report was available.
               So it was sort of a building process of involvement
and interaction on our part, which spread to the later public
statements that we made before the Funding Council on August
the 7th and attempted to make before the Governing Board on
August 13th.
                     Q    Between the July '92 memorandum on counsel
commenting on the early task reports and the August public
presentations, did you or anyone on behalf of the League
prepare additional reports or other documents that commented
on the Hazen and Sawyer analysis or expressed economic
impact?

                         MR. BURGESS:  Object to the form.
                         MR. SAXE:  Let me break it down.

BY MR. SAXE:
     Q    Take me through, chronologically.
               I've got the memorandum around July to counsel
concerning the early task report.  
               Now, as I understand your testimony, at this time
work was ongoing.
     A    Yes.
     Q    By you and Dr. Richardson and by Peterson
Consulting, and the Hazen and Sawyer draft came out on July
15th.
     A    Yes.
     Q    What was the next report or document prepared
either by you or by others on behalf of the League?
     A    I don't think there was a document, but I believe
that the report was issued at the time, and I don't think
that Dr. Richardson was in attendance, but I believe that I
made a press conference or had an initial reaction to the
report in West Palm Beach at the time of the report.
               In other words, we received the report, I read the
report, spent all night reviewing it and I think the next day
I presented an initial reaction to the report.
     Q    Okay.
     A    I can't recall the date, whether it was July 16th
or 17th, but it wasn't a written document, just an off-the-
cuff, you know:  This is my immediate reaction to the report.
     Q    And that was to the press?
     A    That was to the public and the press and I don't
remember all who was in attendance.
     Q    Where did that take place?
     A    That took place in West Palm Beach.
     Q    At the Water Management District?
     A    No.  It took place, I believe, in a meeting room of
a hotel, which I can't remember the name of.
     Q    And was that a press conference?
     A    It was more like a press conference.
     Q    You said it was to the public as well as to members
of the press.
     A    Yeah.
     Q    Do you recall who was there?
     A    I know there were members of industry there and
there were members of the press there.  I cannot recall who
else was there in attendance, to be honest.
     Q    Did you call the meeting or did you organize this
press conference?
     A    No, I think the League called the meeting.
     Q    And. . .
     A    And asked me to make the presentation at that
meeting.
               I think that was my first public statement with
regard to our ÄÄ Dr. Richardson's and our collective
evaluation of the preliminary report.
     Q    All right.  When were you asked to attend this
conference or meeting and make these statements?  Was it
after the Hazen and Sawyer report came out on July 15th?
     A    No, it was in anticipation that the report would be
out on the 15th, so maybe I got a call three days before, I
can't recall the exact date, but I received a call:  We're
going to have this report, it's going to be available, you've
read the Task Force Reports; the assumption was that the Task
Force Reports would be fairly consistent with the preliminary
draft report, which they turned out to be, and they would be
fairly consistent, but I don't have a text of that
presentation and I don't ÄÄ to be honest, someone said they
did a video of it, but I don't recall exactly the structure
of that presentation.
                     Q    Who might have done a video of it?
     A    I'm not sure.
     Q    Do you remember the person who said. . .
     A    I think there were TV people there, I don't know
whether the League had someone there to video it or not.  I
don't recall.  I know there were a lot of cameras going off
at the time.
     Q    It was a photo op?
     A    Something like that.
     Q    Do you know the purpose for the request of the
League for you to make these statements?
     A    It was to give an initial reaction to the report.
     Q    That's all that was expressed to you?
     A    Yeah.
     Q    Now, if more was expressed to you, but you feel
it's attorney/client communication. . .
     A    No.
     Q    You can tell me that, but. . .
     A    No, there was nothing like that.
     Q    Okay.  At the time of this press conference, had
you completed the analysis that you would subsequently
present to the Funding Council in August?
     A    No.
     Q    How far along was it?
     A    It was in a ÄÄ you know, this is always in a state
of flux and a state of change, you know, as new knowledge
becomes available.
               Some of the basic parameters were there.  Namely,
there was a ÄÄ the Hazen and Sawyer report estimated very
little job loss and that was of great concern to us, because
as we looked at it and looked at the assumptions that Hazen
and Sawyer used and the way we viewed those same assumptions,
we had a rather striking different interpretation at the time
about what that job loss would be and, if I recall, that was
one of the focus points of that press conference, is that the
District's report is saying:  Hey, there's no problem.  I
think the press was reporting, the Miami Herald and the Palm
Beach Post, and other media, that there's no problem, and I
think what we're saying is:  Hey, there may be a problem.  So
we highlighted the job loss differential.
     Q    To the best of your recollection, specifically what
was your statement at that conference?
     A    That some of it was that you have a report from
Hazen and Sawyer, which says minimal impact and our cursory
and preliminary analysis is saying that there can be a rather
large impact.
               Then the next two weeks we began to develop our
basis for arguing that we believed there was or could be a
large economic impact.
     Q    Did you quantify the possible increase in the
impacts over what Hazen and Sawyer had indicated during your
statement at the conference?
     A    I cannot recall the specific numbers, if any, that
were presented at that conference.
     Q    Actually I'm asking whether you recall that
specific numbers were presented, as opposed to quantitative
descriptions of the impacts as being much larger or other
relative kinds of descriptions.
               Were there any numbers presented?
     A    I really don't recall.
     Q    Okay.  And then you just indicated a few minutes
ago that in the next several weeks you then commenced to do
what?  To quantify the differences?
     A    Yes.
     Q    Okay.
     A    In the next several weeks we began to look at the
assumptions of Hazen and Sawyer, the methodology of Hazen and
Sawyer, recast some of those assumptions and re-estimate ÄÄ
assuming that Hazen and Sawyer had already utilized FLIPSIM
or some method like FLIPSIM, and starting with the basic same
parameters, in terms of total acreage and what the EAA
constituted and the acreages that were in cane, vegetables
and sod, and so on, but taking what we regarded were flawed
assumptions and then taking and utilizing the FLIPSIM
methodology in a refined state, then we came out with a
series of ÄÄ at that time ÄÄ numerical numbers and so forth,
and that constituted the August 7th report to the Funding
Council.
     Q    Okay.  At any time, up to that point, had Hazen and
Sawyer asked you, or any member of Hazen and Sawyer, Ms.
Johns or somebody else, for any assistance in their
undertaking?  Not just during the period of time of your
retention in this case, but goes back earlier than June '92.
     A    Oh, yeah, I had Chris Melene, staff member of Hazen
and Sawyer, in my office for several days and I gave him
filing cabinets of data from several reports.
               Now, I wasn't in as much contact with Dr. Johns 
as I was with one of her economists, but early on I believe
when ÄÄ I'm talking now about before I was involved in this
with Peeples, Earl & Blank and with the League, but whenever
Grace called or when Mr. Melene asked I provided them copies
of ÄÄ I think, in fact, I even loaned Mr. Melene my book on
sugar and he took it and read it and sent it back, and then
he needed other information and, you know, I said whatever I
have I would be happy to provide you out of my library on
sugar marketing, sugar economics, things of that nature.
               So I had a relationship with Mr. Melene in, you
know, I'm talking about March and I believe it was February,
March, before I ever even encountered Rick Burgess.
               But after I got involved and was retained by the
League I don't recall that I had requests from Hazen and
Sawyer for additional data or information to me personally.
     Q    Do you recall whether you were ever requested to
either review some of Hazen and Sawyer's work or to discuss
that work with Hazen and Sawyer that you declined to provide?
     A    I don't recall any requests, nor do I ÄÄ I don't
recall any requests.
     Q    So. . .
     A    So I had no opportunity to accept or decline.
     Q    Okay.  Up to the point in time where we're adding
your chronology now, which would be the end of July, had you
contacted or attempted to contact Hazen and Sawyer to discuss
their flawed results or their methodology or errors in
assumptions in the work they had done so far?

                         MR. BURGESS:  Object to the form.

BY MR. SAXE:
     Q    Okay.  Had you attempted to contact Hazen and
Sawyer to give any input on the model that they had done at
that point?
     A    I indirectly ÄÄ I provided comments on Task Force
Reports to Mr. Burgess and Peeples, Earl & Blank, the extent
to which that was then translated to Hazen and Sawyer I'm not
aware.
                     Q    Okay.  In the division of labor between you and the
Peterson Consulting group, you said that you laid out
parameters for the economic impact analysis and collected
multipliers to find relevant economic impacts, and they
assisted in number crunching.
     A    Yes.
     Q    Did they make any decisions concerning methodology?
     A    Not the basic methodology, no.
     Q    Did they make any decisions concerning the input
data to be used?

                         MR. BURGESS:  Objection, because I don't know
          what you're meaning by input data.

BY MR. SAXE:
     Q    Did they make any decisions about the numbers to
crunch, that is, Peterson?
     A    Not really, no.
     Q    So those decisions, was that part of your. . .
     A    And Dr. Richardson's, right.
     Q    So then would it be fair to say that they basically
carried out calculations at your directions and under your
guidance?
     A    That's it.
     Q    After the July conference or gathering, we'll call
it a press conference.
     A    Okay.
     Q    After the July press conference, what was the next
either written report that was produced on behalf of the
League concerning this work or oral presentation of analysis
for the League?
     A    The next major move or step was the August 7th
presentation by me to the Funding Council.
               I think it's fair to say, in this context, that
when Hazen and Sawyer presented their primary report they had
also established, to my recollection, a schedule of public
events, that they would take the result of their work and
make it publicly available to the Funding Council, to various
other groups at the District, and to the growers ÄÄ I'm not
exactly sure what their scheduling entailed, but they had an
organized program of making known to the public the results
of their work and in that context we felt it appropriate that
our side of that story be told, and so the first major
presentation to critique the Hazen and Sawyer analysis was a
presentation I made to the Funding Council in West Palm Beach
on August 7th, 1992.
     Q    Did you provide a written report or other written
document at that point?
     A    There was a written report, which was in the form
of an outline of the remarks.
                     Q    Okay.  Do you recall, generally speaking, what the
nature of the presentation was?
     A    Yes.
     Q    Can you describe it for me?
     A    Sure.
               It was a critique of the Hazen and Sawyer study on
economic impact and it began with an overview of the
structure of the agricultural economy of the EAA.  It
included estimates ÄÄ before we get to economic impact ÄÄ it
included our estimates, what we thought the employment base
was in agribusiness and in non-agribusiness.
     Q    What was the last one?
     A    In agribusiness as well as nonagribusiness.
     Q    Okay.
     A    And nonagricultural components of the EAA and it
included a discussion of the assumptions that we thought were
not dealt with adequately in Hazen and Sawyer and our
interpretation of what might be a better assumption, and it
included the quantitative estimate of job loss, acreage loss,
sales loss, under a variety of scenarios, and it compared ÄÄ
it summarized the Hazen and Sawyer result, and it compared
and contrasted our analysis of that, and there was a very
sharp contrast in the results.
     Q    What was the next either oral presentation or
written report that was produced, not necessarily presented?
                     A    The next one that was produced was the. . .
               You're talking about my presentation, not the
presentation of Dr. Richardson, but my presentation.
     Q    I'm actually talking about ÄÄ let me clarify it.
               Any that you're aware of on behalf of the League. 
Certainly any that you produced or presented or any that were
produced or presented by people you were working with or
people working for the League.
     A    The next focus point for me was August 13th, 1992.
     Q    And that was the. . .
     A    That was the presentation that I was to make to the
Governing Board of the District, and I need to give a little
background to what turned out to be some confusion about all
of this.
               August the 12th and August the 13th were two of the
days that the District set aside for discussion of the EAA
project.  August the 12th turned out to be a day when I was
making presentations in Baltimore, Maryland and I could not
be present.  I had a prior conflict of many months
longstanding and I so informed the District and I informed
counsel that I could not make a presentation on the 12th,
because I would be in Baltimore, Maryland, at the
Agricultural Economics Association meetings.  
               Okay.  I believe that on the 12th the report that I
had prepared was summarily presented by Stan Rolen of
Peterson Consulting, but I had not made a presentation and we
had requested that I be given the opportunity to make a
presentation on the 13th, before the District Board.
     Q    What did Stan Rolen present ÄÄ was this the written
outline of your earlier Funding Council presentation?
     A    I'm not exactly sure what he presented.  I'm sure
the testimony that he gave before the District Board would
reflect what he said.  I've never read a text of it and I'm
not sure what he presented, but I assume that what he
presented were the results of our report, the
Richardson/Polopolus report that we were to summarize on the
13th.  
               So on the 13th of August, 1992, Dr. Richardson and
I were prepared to appear before the Board and make our
summary presentation of our critique of Hazen and Sawyer's
analysis, but we were not permitted to make that
presentation.
               So the report was completed and I think the report
was offered, but the report itself was not presented.
     Q    When you say a report, do you mean a written
document?
     A    There was a written document.
     Q    Okay.
     A    Again, it was an outline form document that
presented our latest thinking about the Hazen and Sawyer
report and our latest thinking about what is the likely
economic impact of imposing the STAs on thirty-five thousand
acre reduction, of imposing BMPs and imposing alternative tax
assessments.
     Q    Did you say overheads?
     A    I think some of them were ÄÄ some of that report
was made into overheads.
     Q    Okay.
     A    So it was not a journal type paper, it was a 
paper that was prepared and intended to be presented in a
public. . .
     Q    Presentation materials.
     A    Right.
     Q    Documentary presentation materials.
     A    Yes.
     Q    Now, these had not been in existence a few days
earlier at the Funding Council presentation?
     A    Not that same form.  There were changes that were
made between the August 7th report and the August 13th
report.
     Q    Now, when you say the August 7th report, would that
be the written outline of remarks that you referred to
earlier?
     A    Yes.
     Q    Okay.  That was also a documentary presentation
material or packet?
     A    Yes.
     Q    And then there were changes made to it for the
August 13th presentation?
     A    Yes.
     Q    Do you recall what changes were made?
     A    No.  I really can't recall the changes that were
made specifically.  I would have to look at the two documents
and compare them.
     Q    Do you remember why the changes were made?
     A    I think it was more of presentation, not so much of
substance.
     Q    Had there been overheads also for the August 7th
Funding Council presentation?
     A    Yes.
     Q    But the overheads for the August 13th presentation
would be a little different?
     A    Some of them were different.
     Q    Some of them were different?
     A    Yes.
     Q    When you say that ÄÄ I'm paraphrasing the report ÄÄ
the report was offered, but wasn't accepted, I think that was
the gist of what you were saying.
     A    Offered but not presented.
     Q    What did you mean by that?
                     A    Well, it was a long day.  When, Grace Johns, with
Hazen and Sawyer, was permitted to present her report, we
thought that we would have the opportunity of following her
and presenting a rebuttal, but it turned out that several
dozens of people testified and made various comments, the day
kept wearing on and on and on, and at approximately six p.m.
that evening, when members of the Governing Board had planes
to catch and there was a question of quorum and people were
yawning and very tired, and then they called Dr. Polopolus
and Dr. Richardson to the podium to present their report, and
we began our report and then the Chair says:  Sorry, I don't
think we have a quorum, I don't think we have many people
that are going to stay and hear this, but I know the gist of
what you might be saying and I know that there's likely to be
a big difference between you and Hazen and Sawyer, can you ÄÄ
and there was sort of a stop in the proceedings ÄÄ and then
the Chair said:  Can you meet at some other time, can you ÄÄ
meaning Dr. Richardson and Dr. Polopolus ÄÄ meet with Hazen
and Sawyer, have a meeting of you two economists and discuss
your differences and then come back and give us a report?
               So that's how it ended.
     Q    Had Dr. Richardson made any presentation?
     A    I'm not sure whether he did or not up to that
point.  I don't know.
     Q    So you were standing at the podium when this took
place.
     A    Oh, on the 13th both of us were standing together,
we were both at the podium together, at six p.m. on the 13th.
     Q    And you were asked to submit something in writing?
     A    My recollection is that the District staff, and
with Hazen and Sawyer and with the League staff conferring at
that point, saying:  How are we going to handle this?  Well,
we obviously have a big difference of opinion about economic
impact but why not let the economists get together, meet and
discuss the methodologies, the procedures, so forth, and then
why don't we give the parties the opportunity to come back
after that meeting and report to us what happened.
     Q    Okay.  What happened next?
     A    Not much.
     Q    Let me ask a question before we leave this dark day
of August 13th.
               What did Hazen and Sawyer present at that Governing
Board meeting?
     A    My recollection is that Dr. Johns made a
presentation of her findings.
     Q    Did she present the July 15th draft reports?
     A    She presented her. . .
               I should have mentioned earlier that I believe on
July the 31st, Hazen and Sawyer issued their final report and
so now she's, on August 7th and August 13th, Dr. Johns would
be presenting the results, not of her preliminary report,
because she had made some changes, didn't change the final
conclusions, but obviously made some changes, and so the
August 7th and August 13th presentations were based on her
July 31, 1992 final report.
     Q    Had those changes between the July 15th draft and
the July 31 final report been considered by the people
working for the League and preparing the presentation that
was presented to the Funding Council on August 7th?
     A    Excuse me?
     Q    Okay.  Had the presentation that was made to the
Funding Council, on August 7th, included the changed material
on the July 31st Hazen and Sawyer final report?
     A    The presentation by whom?  By Hazen and Sawyer or
by us?
     Q    By the League.
     A    We certainly took into account the changes of Hazen
and Sawyer, between their preliminary report and their final
report.
     Q    So the presentation that was made on August the 7th
pertained to the final report as well?
     A    It pertained to the final report, yes.
     Q    And also that's true concerning the aborted
presentation on August 13th?
     A    That's correct.
                     Q    Okay.  What was the next thing that was done by you
or Peterson and/or Richardson in the case?
     A    Well, not much happened.
               The next stage was that we were trying to get a
meeting of economists that were the primary economists
involved, that is, the economists for Hazen and Sawyer and
the economists for the League, and up to that point we were
the only economists who were coming forward with a lot of
analyses and a lot of data and a lot of interpretations and
so on and so forth.  So we felt that we were the primary
group of economists involved and interested in demonstrating
that interest through public presentations and so on.
               So we were trying to get this meeting, this meeting
that we thought the Board had requested, and the next thing
we learned was that the District was calling a meeting of all
the economists, by all economists meaning the economists with
the Justice Department, economists at various universities,
economists with the Department of Agriculture, including, and
so on and so forth.
               So that's not what Dr. Richardson and I thought was
the meaning of the District Governing Board on August 13th. 
We just wanted to have a face-to-face opportunity to meet
with Chris Melene and Dr. Johns and discuss methodology as
economist-to-economist, you know:  Why do you do it this way? 
Could you have done it that way?  What was the basis for this
number?   What was the basis for that assumption?  So on and
so forth, you know, that type of thing.
               It took from August 13th to December 16th, 1992 to
actually realize this meeting.
               I did make a public presentation to the Funding
Council on November 19th, at which time I again said it would
be nice if the District permitted a meeting between the Hazen
and Sawyer economists and the League economists to hatch out
our differences over methodology.  It would be nice.
               At that time we said it also would be nice if the
District would permit Hazen and Sawyer, if they were to do
another analysis, which we didn't know if they would or
wouldn't, if they were to do another analysis, if they would
extend the analysis to a twenty-year period.
               But we had the meeting on December 16th and it was
a good one and very productive one from both sides, I think.
     Q    All right.  Going back to the efforts to arrange a
meeting between you and somebody on behalf of the League, I
take it, and Hazen and Sawyer; is that correct?
     A    Yes.
     Q    Were you the person who was attempting to make
these arrangements?
     A    No.  Mr. Burgess was, on behalf of the League, and
on behalf of ÄÄ representing the economists for the League,
was seeking to resolve this problem.
                                          QSo when you say:  We just wanted to discuss
methodologies and so forth, you mean the economists for the
League or do you mean counsel and the economists for the
League?
     A    I think basically it was Dr. Richardson and I who
felt an obligation to follow up on the Governing Board's
recommendation that the economists get together and talk
about it, the primary economists.
     Q    Okay.  What was the ÄÄ I take it from your
testimony that there was ÄÄ that you objected or that the
League objected to having other economists present at that
meeting?
     A    Yeah, there was concern about that.
     Q    Okay.  Can you explain those concerns for me?
     A    Well, I can speak for myself, you know, I can't
speak for the League on this point or anybody else's.  But
what we didn't want to happen is we didn't want to have and
characterize a meeting that had political overtones to it,
that had an adversarial overtone to it.  We wanted it to be a
colleagial meeting of the economists, where we sat next to
each other without any representatives of industry, without
any representatives of the District or without any pressures,
political and otherwise, we just wanted a meeting of the
primary economists.       
               We were characterized in the media as battling over
and having great differences and so forth, and we wanted to
say:  Okay, let's get into a closed room, without people with
vested interests, and just talk about economics and talk
about methodology.
               So that's why we didn't want ÄÄ we didn't want a
large number of people and then take a vote:  Well, was this
methodology good?  Nine in favor of two against ÄÄ something
like that.  We didn't want that kind of an atmosphere to
pervade the discussion.
     Q    All right.  You indicated, as a preface to your
comment, that you were only going to speak for yourself and
then you said "we".  
               Can you. . .
     A    Well, I think Dr. Richardson and I felt similarly
about this.
     Q    What did you understand the League's objection was
to the presence of other economists at this meeting?
     A    I really don't know.  Mr. Burgess could answer
that.
     Q    Did you have any understanding of the League's
objections?
     A    I believe they were concerned, as we were, about
making a kangaroo court out of this issue.
     Q    You described your rationale in terms of your
wanting to have a colleagial meeting, not an adversarial
meeting, without industry representatives present.
     A    Yes.
     Q    Did you not consider yourself to be an industry
representative?
     A    In that context I considered myself an economist.
     Q    Did you consider the economists that had been
retained by other parties in the case, to be representatives
of the parties as opposed to economists?
     A    I didn't think about it that way.
     Q    Well, what was your thinking about the presence of
economists, that had been retained by other parties would
make the meeting adversarial in a way that your presence, as
an economist retained by a party in the case, would not?
     A    It's a good question, but I think I expressed my
feeling about that.
     Q    And that is that you hadn't really thought about
it?
     A    Not in that context, and I should state very
clearly that I am not opposed, and I believe it's a very good
idea, for economists of all persuasions and of all stripes
and from all interest groups, be given the opportunity to
discuss methodology, but we were talking about a very
constrained issue that resulted from a specific event that
took place on August the 13th, and I'm talking about that. 
I'm not talking about meetings of economists in general, I'm
talking about responding to the Governing Board's concern
that the two economists get together and resolve and discuss
and so forth.
     Q    You were aware, I'm sure, at that time that the
League who had retained you also sued the Water Management
District over the SWIM Plan; is that correct?
     A    I became aware of that, yes.
     Q    Were you aware of that at the time that you were
attempting to arrange the meeting with Hazen and Sawyer?
     A    No.
     Q    At that time you were not aware of that?
     A    No.
     Q    Were you aware that ÄÄ did you have any
understanding about a challenge to the SWIM Plan by the
League?

                         MR. BURGESS:  Object to the form.

BY MR. SAXE:
     Q    Do you know when the League filed a petition
challenging the SWIM Plan?
     A    No, I don't know the date.  To be honest, I don't
remember the date.
     Q    Moving on to a parallel track, between the August
13th Governing Board presentation and the November 19th
Funding Council presentation.
     A    Yes.
     Q    What work was being done by you and Dr. Richardson
and Peterson Consulting, if any, on analyzing the Hazen and
Sawyer impact analysis or economic impacts on the SWIM Plan,
generally?
     A    Very little.  I wasn't in contact with Peterson
Consulting at that point.  In fact, the overheads that I
presented on November 19th to the Funding Council were not
prepared ÄÄ Peterson Consulting was not involved, I wasn't in
contact with them.
               I was in some general telephone conversations with
Dr. Richardson, but we had not conducted any new analysis of
the Hazen and Sawyer work for the presentation to the Funding
Council on November the 19th.
               It was a pretty much updated summary of our prior
presentations of August 7th and August 13th.
     Q    So there was another presentation document that was
presented on November 19th?
     A    A presentation document, outline format.
     Q    And what was done to update it from the materials
that had been presented or available for presentation on
August 13th?
     A    Well, some of it was a change in emphasis.  For
example, that particular presentation looked at price
assumptions and questioned the methodology of Hazen and
Sawyer over the price level, over the inflation of the price,
so on and so forth.  It was sort of like:  This is what we
believe to be one of the flawed assumptions of Hazen and
Sawyer, it could have been done like ÄÄ you know.  Like: 
What went wrong with Hazen and Sawyer?  And our character
says:  What would have been a better way to have dealt with
this?  And what we concluded or what we pleaded was that
Hazen and Sawyer would consider ÄÄ seriously consider if they
were to do another analysis that they give attention to what
we thought were flawed assumptions and that the District give
us an opportunity to meet with Hazen and Sawyer to talk about
them and that the analysis be extended to a twenty-year
period, and so forth.
     Q    But no new numbers.
     A    No new numbers, absolutely.
     Q    Not just by Peterson, but by. . .
     A    By anybody.
     Q    Had any adjustments been made in numbers?
     A    No new numbers, no, and that can be corroborated by
looking at the outline, the overheads that were presented,
the numbers were the same, you know.
     Q    Okay.  Moving then from the November 19th Funding
Council presentation, to the December 16th meeting.
     A    Yes.
                     Q    Take me from November 19th to December 16th, in
terms of the work that was being done, it any.
     A    Okay.  A lot of differences took place.  It was a
very significant ÄÄ there were significant changes in terms
of what Richardson and I began to do and did do in
preparation for the meeting of the economists.
     Q    Before we ÄÄ if you'll bear with me, I don't mean
to interrupt you, but just on a detail point while you're
there.
               Do you know when the meeting of economists was
agreed upon for December 16th?
     A    I can't recall that, but I imagine it was somewhere
in early December.  I cannot recall when that date was agreed
upon.
     Q    Was that the event that triggered these changes in
approach by you and Dr. Richardson?
     A    That was, in part.  There was also a Protective
Order that came to my attention about that time and our
realization, as we began to look at this issue of why is
there such a difference?  Why is it difficult to explain
these huge differences in impact?  Maybe it would be better
if we could place the battle on a plane where comparisons
would be more readily understood by the public and by others
who were trying to grapple with why are there these big
differences.
                                               So our decision making was to say we will adopt the
model framework of Hazen and Sawyer's analysis, even though
we think there may be some problems with it.  Let's adopt
that so that that doesn't become an issue.  Let's completely
go to public sources of data, as did Hazen and Sawyer, so
that we remove this kind of doubt that:  Oh, maybe the reason
why they have such big numbers is that the League economists
are using data from individual farms and Hazen and Sawyer
are using data from some other source and that's the reason
for not ÄÄ it's not because of this and that and that and
this.
               So we said:  Let's remove that doubt and let's
utilize the same data base, same data sources.  So let's use
the same model structure, let's utilize publicly available
data, and we thought we were all using FLIPSIM or something
like that, so we were all using the same methodology,
basically as a starter; so, therefore, the focus will be
placed on the assumptions and placed on what constitutes
total revenue and what constitutes cost, and where we think
the appropriate battleground should be on the assumptions.
               So in preparation for the December 16th meeting we
said:  Let's now take a new ÄÄ forget that earlier analysis,
let's take a new look at this thing and let's take a look at
how we would view Hazen and Sawyer's analysis within now a
new model framework, mainly the Hazen and Sawyer's model,
which average the different Belt Zones, 1, 2, 3, 4 and 5, and
the farm sizes that Hazen and Sawyer had, the large and small
size, average size, which are within each zone belt, and we
adopted all of that.  The yields that Hazen and Sawyer had
and so forth.  I'm not the expert on this firm analysis, Dr.
Richardson is, and so if you want to get into all the details
about what the specific yield was for each of the zone belts,
for the large farm, small farm, you would have to ask Dr.
Richardson.
               But we, as a general strategy, we said:  let's
adopt this framework and let's analyze the Hazen and Sawyer
report in that context.  And we did.
     Q    Were there any other aspects of the Hazen and
Sawyer's methodology, besides the yield belts, the different
size model farms and the yield numbers that you adopted?
     A    Would you repeat that?
     Q    Were there any other aspects of Hazen and Sawyer's
methodology that you adopted and changed from your previous
work, besides the yield belt, the different size model farms
and the yield values?
     A    Well, let me state that we attempted to validate
the Hazen and Sawyer study by taking all of the data that
Hazen and Sawyer had.  As a matter of fact, in our outline of
results of December the 16th, we took the Hazen and Sawyer
price, price trend and the costs, and we replicated Hazen and
Sawyer to the penny, and you would have to ask Dr. Richardson
about, you know, how we did that.
     Q    Okay.
     A    So we replicated it.
               So we believe that we know every element of the
Hazen and Sawyer analysis and we can reproduce it, not only
to then penny but over the ten-year planning horizon that she
studied.
               So we took he analysis and then said:  Let's now
look at some of the assumptions and. . .
               So, I don't know if I'm answering your question,
but one phase of this, you know, we adopted all of it, all of
Hazen and Sawyer, all of it.
     Q    What do you mean one phase of this we adopted. . .
     A    Well, one phase of it was, if you look at the table
that we presented at that meeting of economists, which we
also later presented to the members of the Governing Board,
we had three levels of analyses.  We had one ÄÄ we think
price is a critical component of all this debate ÄÄ one,
where we said we accept, for purposes of argument, we accept
Hazen and Sawyer's price level of thirty-five dollars and
ninety cents a ton, with a trend factor of increasing that
price one point seven percent per year over the planning
horizon to reflect the efficiencies of the mill.
               Given that assumption, we analyzed the impact in
that ÄÄ but then we changed other assumptions with attempt to
yield risk, so on and so forth.
               Then the second one was where we said:  Let's
assume that the price level of Hazen and Sawyer's thirty-five
dollars and ninety cents a ton, but we will not admit the
trend, because we found some statistical problems with Dr.
Johns' analysis of trend.
               Then we said:  Let's take a third price level where
we assume the average season price that growers, in fact,
receive and reported by the Florida Crop and Livestock
Reporting Service, over the last five-year period, let's take
that price, which is thirty dollars and some cents per ton,
and let's show the impact of that.
               So we did those three scenarios, utilizing FLIPSIM.
     Q    So there were two scenarios that were not pure
replications of Hazen and Sawyer and one that was?  I'm 
not. . .
     A    Well, it's confusing, because we, first of all, we
didn't report ÄÄ I should correct that ÄÄ we did not report
in that presentation our replication that replicates Hazen
and Sawyer to the penny, we did not report that in the table,
but we stand ready to produce that.  I'm sure Dr. Richardson
can produce that replication.
               What we did in our December 16th presentation was
show her price trend, her price level and trend, and show the
economic impact if we consider a different interpretation of
some of the assumptions, namely, for example, debt, so on and
so forth.
               At some point, if you want to get into the FLIPSIM
methodology, I'm not the expert on that, Dr. Richardson is,
but I would be more than willing to discuss what that means
and how similar our first stages of analysis were with Hazen
and Sawyer over the land use, which is apparently becoming an
issue as to whether or not we do land use and some people are
arguing that we only look at farm/firms and we don't look at
land use and so on and so forth.
     Q    All right.  
               I think later we'll get into some of those
questions during the course of the deposition.
               Now, being primarily interested in kind of trying
to establish what was done and when it was done, so that we
have a framework for questioning about these issues.
     A    Yes.
     Q    As I understand it, there was an analysis done that
replicated Hazen and Sawyer to the penny.
     A    Yes.
     Q    Then do I understand correctly that analyses were
rerun. . .
     A    Yes.
     Q    Varying certain assumptions.
                     A    Yes.
     Q    To produce the results that were summarized at the
December 16th meeting?
     A    Yes.
     Q    With Hazen and Sawyer?
     A    That's correct.
     Q    And those were three scenarios, so there were three
analyses, there was ÄÄ let me lay it out and you can tell me
where this goes wrong or where it needs to be added to.
     A    Okay.
     Q    There was a rerun, assuming Hazen and Sawyer's
price level and trend, but making certain corrections for
other assumptions.
     A    Yes.
     Q    Then there were two runs, assuming a lower price
level ÄÄ excuse me, the same price level but no trend.
     A    Yes.
     Q    And then one with a lower price level and no trend.
     A    Yes.
     Q    So there were basically three analyses.
     A    Yes.
     Q    Was there any other work that was done before the
December 16th meeting?
     A    No.
     Q    You produced certain printouts or documents as a
result of these analyses; is that correct?  
               Let's start working backwards.  
               The rerunning ÄÄ the three scenarios that were
done.
     A    Okay.
     Q    Did you or was there produced any documents that
reflected the results of that analysis?
     A    We did the summary presentation.
     Q    Okay.
     A    Again, this was all done in connection with
colleagial meeting with economists, where we were going to
talk about economics, talk about methodology, talk about
assumptions, and it was done in the context of reviewing, as
a reviewer ÄÄ we are the reviewer, this is where Hazen and
Sawyer did this, we're coming and saying:  Well, Dr. Johns,
why didn't you consider that?  So it was in that context we
presented that analysis.
     Q    So only a summary document was produced?
     A    Yes.
     Q    When I say produced, I mean created.
     A    Prepared, that's right.
     Q    All right.  You also referred to a, you know, a
replication of Hazen and Sawyer's results to the penny.
     A    Yes.
     Q    Was the document or documents prepared?
                     A    No, that's Dr. Richardson's characterization to me
about what he did.  You would have to ask him directly.  I
didn't see the document to verify that, only his word to me
that that is what he did.
     Q    Okay.  So do you know if there's a document 
that. . .
     A    I'm not aware of the document, whether it's on a
computer screen somewhere or what.
     Q    Okay.  Were any other documents created or
prepared, so far as you know, in conjunction with these
analyses?
     A    Well, there were two pages that were attached to
that legal size summary sheet of numbers and they were a
verbal summary of the assumptions.
     Q    Okay.  Then are we up to date for the December 16th
meeting with Grace Johns?
     A    Yeah, we're at the point where we thought that
Grace Johns' preliminary report of the twenty-year. . .
               By the way, we learned for the first time, on
December 16th, that two things happened:  One, that Dr. Johns
was given a contract to do a twenty-year analysis.  So to
redo or renovate or revise, whatever, the economic impact
study, which would then be due on March the 15th, 1993, and
that the District ÄÄ Dr. Woehlkhe, by the way, was in the
meeting with the economists ÄÄ that the District also was to
consider some economic analysis, if some alternative plans
were proposed, and so on and so forth, so that might be let
to another economist or group, but it was on December 16th
that we learned about, with definition from Dr. Woehlkhe,
that there will be ÄÄ and I cannot spell Woehlkhe, W-o-e-h-l-
k-h-e, or something like that.
     Q    Okay.
     A    That Dr. Woehlkhe had reported that, so we were
pleased to hear that that would be a twenty-year framework of
analysis.  
               So we expected the report to be available on March
the 15th, and I think that we have learned, through Mr.
Burgess, that the report was ÄÄ that an extension was made as
to the deadline on the report, that the report is now due
tomorrow, which is April the 15th, and with the preliminary
report due then, and then the final report due on April the
30th.
               So we're sitting on our hands and knees waiting for
this twenty-year report.

          (Thereupon, the luncheon recess was had; whereupon,
          the following proceedings were held:)

BY MR. SAXE:
     Q    Dr. Polopolus, just rolling back for a minute.
                                               Who was in attendance at the meeting on December
16th?
     A    December 16th there was Dr. Grace Johns, Chris
Melene, Dr. Carl Woehlkhe, Dr. James Richardson and myself.
     Q    Okay.  So representing the League was only yourself
and Dr. Richardson.
     A    Yes.
     Q    Did you present any documents to the District or to
Hazen and Sawyer at the meeting?
     A    Yes.
     Q    What were those?
     A    I think we referred to them earlier as a one-sheet
of analysis and two sheets of verbal comments about
assumptions and methodology.
     Q    On the analysis summary, the one hundred pages,
which I'll call the analysis summary, that contained
information concerning the recently rerun analysis with the
three scenarios that you produced after November 19th, 1992;
is that correct?
     A    That's correct.
     Q    And also did it refer to the analysis that had been
done and presented to the Governing Board or to the Funding
Council in August of '92?
     A    It had data that reflected ÄÄ there were three
blocks of data and I believe there was a block of data that
compared this new analysis with previous analyses.
     Q    And the previous analyses ÄÄ we'll get into the
documents in a short while ÄÄ but, to the best of your
recollection, that was analyses that had been done for the
August presentation?
     A    To the best of my recollection.
     Q    Okay.  What was the next step in the process for
you and the other members of the team working for the League?

                         MR. BURGESS:  Object to the form.
                         After when?

BY MR. SAXE:
     Q    After the December 16th meeting.
     A    Yes.
     Q    Dr. Johns and company.
     A    What was what?
     Q    The next step.  What did you do next and what did
Dr. Richardson and Peterson Consulting do, and any others who
were working on behalf of the League?
     A    Well, the next step was I felt some duty or
obligation to report back to the Governing Board of the
District and, whether rightly or wrongly, I chose to go to
the January Board meeting of the District to present the
results of the meeting that was finally held between Hazen
and Sawyer economists and the League economists.
     Q    That was the Governing Board?
     A    The Governing Board meeting on January 12th, 13th,
I can't recall the specific dates.
     Q    Between December 16th and that January Governing
Board meeting, did you do any additional work. . .
     A    No.
     Q    . . .for this case?
     A    I don't recall doing any additional work, other
than preparing sort of a summary of what I was going to say,
an outline to myself, and I don't know that it was written,
just sort of conceptually to prepare for presentation
generally.
     Q    Did Dr. Richardson do any further analyses during
this period between December 16th and the January meeting?
     A    I am not aware of any.
     Q    How about the Peterson Consulting group?
     A    I'm not aware of any.
     Q    What was the status of the analysis work, if any,
that was being done at this point?
     A    Well, I think we adopted a general plan that we
would, from December 16th, 1992, forward, we would adopt a
basic model structure of Hazen and Sawyer, we would adopt
completely the reliance on public available data, much of
which was in Hazen and Sawyer's report, and that we would
then await the completion of the twenty-year study to then do
an evaluation of that study, when that study became
available, which we thought was going to be March the 15th.
     Q    The decision that had been made earlier, after
November 19th, to change the approach that you were using to
adopt the Hazen and Sawyer modeling methodology and the
public sources of data, was that based strictly on the
concern about injecting additional issues or doubts, I think
is what you used, concerning the methodology and data?  Were
there any other reasons for that change of. . .
     A    Well, there was that and in relation to counsel
advising us about a protective order.
     Q    What was your understanding of the protective
order?
     A    I don't have a clear understanding, but my
understanding is that counsel advised us to carry out the
analysis with public supported data as we prepared -- if we
were to prepare for any litigation, any legal proceedings.
     Q    What took place at the January '93 Governing Board
meeting with respect to your presence?  Did you make any
presentation or what happened?
     A    I tried to. 
               My Greek blood got a little warm, because I went
there with the intention of making a five-minute presentation
on the results of the meeting between Hazen and Sawyer
economists and the League economists, and I filled out a card
and under the comment period, under the Everglades'
Restoration, I think Category 26, whatever it was, and I was
informed sometime during the middle of that day that I would
not be permitted to testify, make a public comment, and I
asked why and they said it's not ÄÄ you know:  We're not
going to do it.  Something to that effect.  
               Then I was told, at the lunch break, that they were
going to see if maybe I would be permitted to make a comment. 
Meanwhile the representatives of the District had made
comments about the meeting, that particular meeting of the
economists, which I didn't think fairly and fully represent
my understanding of what had happened at the meeting.  
               At any rate, I was later informed ÄÄ and the
communication was between me and a member of the Board
itself, and that Board member came back and said that I would
be permitted to make a brief presentation before the day was
over.  It was a relatively short meeting.
               So it came to about three o'clock and the last
people that were to be called and they called Mr. Polopolus
to make his statement and I go forward to make my statement
and I say ÄÄ I started with good morning, that was my opening
line, but by then it was good afternoon, and as I started to
make a comment the Chairman of the Board said:  Would you
send it to me in a memo?  You know, that was the end of my
presentation.
     Q    Which Governing Board member had indicated to you
earlier that you would have some short opportunity to make
comments?
     A    I believe -- I can't recall the names very
correctly, but I believe it was Mr. Nall.
     Q    The outline that you prepared, you don't remember
whether it was a written outline or just a mental outline of
your presentation?
     A    I believe the -- I had a mental outline and that
day I prepared hand scribbled notes.
               What I was permitted and the time that I was going
to be allotted kept getting shorter and shorter and then
finally I agreed, when I was permitted to make a
presentation, I basically agreed to two minutes.  So when I
was restricted to two minutes, as opposed to five minutes,
then I said:  Well, I'll make my comments without reference
to any data or numbers or anything like that.
     Q    Had you previously submitted correspondence or sent
correspondence to the District or to the Governing Board
concerning your meeting in December with Hazen and Sawyer?
     A    No.
     Q    You indicate that the District staff made some
comments on the December meeting.  Do you remember who




















     A    Mr. Pete Rhoads.
     Q    You felt that those comments were inaccurate?
     A    Biased, slanted.
     Q    What about them seemed biased or slanted to you?
     A    I'm trying to recall the specific issues that were
involved; but, if I recall, it turned out to be criticism of
the League economists, that the League economists did not do
A, B and C.  So the nature of the remarks were:  Well, the
economists got together and had a good meeting, but, you
know, the League economists, they didn't establish a
baseline, they didn't do this and that and the other.  There
were several points that Mr. Rhoads raised, and there didn't
seem to be a balanced presentation of what had happened.
     Q    At that point, from that point forward, after that
January '93 Governing Board meeting, I understand that the
status of the work being done was, as you indicated, that you
adopted a general plan to use Hazen and Sawyer's data and
methods and were waiting for the twenty-year analysis; is
that. . .
     A    Yes.
     Q    Would that be fair to say, that you were not doing
any analysis, further analysis?
     A    That's correct.
     Q    Is that also the case, as you understand it, of Dr.
Richardson?
                     A    I don't know.
     Q    Had you had any communication with him before that
period, in which he expressed plans, specifically after the
December 16th meeting, had he indicated that he was going to
be doing anything over the next month's time?
     A    I have had very little communication with Dr.
Richardson from December 16th to the present day.
     Q    How did you leave things with Dr. Richardson, in
terms of continued work on the analysis, since December 16th?
     A    My assumption was that when the March 16th
preliminary report would be available, then we would begin to
analyze and critique the Hazen and Sawyer report at that
point.
     Q    How about with respect to the work, if any, that
might be being done by Peterson Consulting?
     A    I'm not aware that they were doing any.
     Q    What was the next step after the January '92
Governing Board meeting, and by that I mean what was the next
task undertaken by any of the experts working for the League
on economic impacts?
     A    We did hold a meeting in preparation of what we
thought was a March 15th report, of representatives of
counsel and economists of various ÄÄ I think the economists
representing the Cooperative and counsel representing the
League, there was a meeting held sometime in ÄÄ I want to say
March, but I can't recall the exact ÄÄ there was a meeting
held in early March, like March 13th or something like that,
but it was scheduled to be in anticipation of the Hazen and
Sawyer report, at which time we discussed some ÄÄ we didn't
make any plans, but discussed some possible procedures and
general scheme of analysis and possible cooperation in the
event the report became available.
     Q    Tell me more about the meeting.
               Where was this meeting?
     A    It was in Tampa.
     Q    And you said before that you believe it was early
March?
     A    I believe early to mid-March.
     Q    Who was present at the meeting?
     A    It was several individuals present, several
individuals came late and I left early, so I'm not sure as to
the exact totality of the people who were present, but they
included Rick Burgess, with Peeples, Earl & Blank.  They
included, I believe, Bill Green, and I don't know the names
of all these people, but Ron Luke came about noon and we
crossed paths in that meeting of about ten minutes.  Ron
Luke, economist with the Cooperative.  
               Dr. Richardson was not at the meeting, he was
unable to attend the meeting.  Stan Rolen, with Peterson
Consulting, and I believe Andy Bernstein, with Peterson
Consulting.  There may have been one other member of counsel,
but I can't recall.
     Q    And what was the purpose of the meeting?  You
mentioned something about discussed proceeding further, once
the twenty-year analysis came out.
     A    The question was where do we go from here?  What
are the resources that are available?  And limited resources? 
How do we approach this and do we need to take this whole
panorama of issues?  Do we need to utilize FLIPSIM?  If we
utilize FLIPSIM, how would we utilize it?  Will we use it
stochastically or not stochastically?  If we didn't use
FLIPSIM, what would we do and how would we do it?  What are
the major issues that we think are the ÄÄ the critical
issues?  
               I think the sense, as I understood the sense of the
meeting, the sense of the meeting was that we were trying to
get to a point where the differences between Hazen and Sawyer
and the League economists could be more illuminated in terms
of what are the primary issues that separate the results,
given that the results were previously very dramatically
different.
               So at that point we started to discuss:  Hey, what
are the more critical issues and what are some new issues, as
we looked at the twenty-year horizon, that needed to be taken
into account, such as not only trade issues, like NAFTA and
GATT, and soil subsidence and technology, you know, not that
we answered any of this, it was just a brainstorming session.
     Q    Okay.  Were there any discussions about what data
would be used in any analysis that might be undertaken?
     A    Yes.  The conclusion, and based on ÄÄ and from a
variety of reasons that we have discussed earlier, was to use
publicly available data.  It's perfectly satisfactory to use
the methodological framework of model farms as presented by
Hazen and Sawyer.
     Q    When you say the conclusion was to use public
available data, whose. . .
     A    Well, that's my conclusion, my understanding.  I
shouldn't say conclusion.  It's my understanding of the
consensus.
     Q    When you say use the Hazen and Sawyer methodology
with model farms, what do you mean by that?
     A    That is the Zone Belts 1, 2, 3, 4 and 5.  The large
and small farms within each of those.  The average yields
that are representative by those zone belts and so forth.
     Q    Was there any discussion about the suitability of
those methodological aspects?
     A    I don't recall any discussions about suitability. 
     Q    Did anyone else express a view about the use of
public available data?
     A    Expressed a view either favorably or negatively?
                     Q    Any view.
     A    Again, I can't recall any specific discussions on
it, but my interpretation was that public available data is
adequate to do the analysis.
     Q    The discussion about FLIPSIM, whether to use it
stochastically or not, can you elaborate?
     A    Well, I think the question is how sophisticated
does one want to do the analysis and how many resources are
needed to do the analysis.
               No conclusions were made, these were just
discussed.
     Q    What were the views that were presented?
     A    I don't recall the different views, except they
were just saying sort of these are options that we should
look at.  Nobody said ÄÄ you know, nobody made the decision
and said:  Well, we should do this or that or the other.
               I can tell you my personal feeling about it, but I
can't speak for the group.
     Q    Okay.  What was your personal view?
     A    My personal view is that FLIPSIM is still the best
model to use for this type of analysis.
     Q    Stochastically or not?
     A    Stochastically.
     Q    What is the difference or what is the relationship
between the mode in which FLIPSIM is used and the resource
intensivity of using it?
     A    Part of that relates to if you link up with other
individuals and other groups.
               For example, if the League were to work
cooperatively with one Ron Luke and the Co-op, for example,
where one scenario would be where the League economists do
these pieces of the analysis and then Dr. Luke were to
conduct a community impact analysis.  It may be for that
community impact analysis that, from Dr. Luke's perspective,
it would be easier for him to work with a simpler model, so
on and so forth.
               So it has to do with the simplicity of the results
and the voluminous nature of the results that you get
stochastically versus fewer results, and it becomes a data
management problem.
     Q    Did Dr. Luke express a preference along those
lines?
     A    I don't recall, to be honest, because I only had
ten minutes of time with him.  He may have at this meeting,
but others attending the meeting did not characterize his
attitude on that.
     Q    As you understand it, what are the differences in
results between using FLIPSIM and a stochastic and non-
stochastic mode?
     A    It depends on the stochastic nature of the
biological events and the distribution, the probability
distribution associated with that.
     Q    When you say biological events, in the context 
of. . .
     A    In the context of vegetable yields, in the context
of sugar cane yields, in the context of vegetable prices and
possibly in the context of sugar cane prices and sugar prices
under certain policy environments.
     Q    What are the differences in model output between
FLIPSIM and stochastic and FLIPSIM and non-stochastic modes?
     A    There's a difference in output.
     Q    What is the difference?
     A    Well, the difference in output is if you use
stochastic methods and, here again, Dr. Richardson is the
expert, he developed the technique, he's a colleague working
with me on this and he's the one that one would defer to, you
know, the technical questions on it, but from my
understanding, when you put it in a stochastic mode you're
trying to bring risk and uncertainty, which is present in
agriculture, you're trying to model reality and put it within
the conceptual and analytical framework that you're doing. 
So you're trying to get closer to reality, by incorporating
risks, because it's hard to argue that there's no risk or
uncertainty with respect to yield, there is no risk or
uncertainty with respect to say vegetable prices.
                     Q    All right.  Getting back to my question then, how
would that express itself in terms of difference between the
outputs of. . .
     A    Well, in order to get the ÄÄ when you do
stochastics, as I understand the method that is used, it
requires like an experiment, it requires many iterations of
an event and permits you to develop standard deviations and
it permits you to do distribution, probability distributions.
               Now, if you're just doing the mean, you don't have
any of that.  You don't have standard errors, you don't have
standard deviations or probability distribution.
               What is the probability distribution that the yield
of sugar cane will be X or Y next year or two years from now? 
So on and so forth.
               So adds a great deal to the volume, the volume of
analysis, but the volume of analysis permits you to do things
scientifically that you could not do with no uncertainty, no
risk framework.
     Q    What are those things that would permit you to do
that, that you couldn't otherwise do?
     A    It permits you to ÄÄ here again I would defer to
Dr. Richardson, who is the author of this and has developed
the technique ÄÄ but it permits you to, for example, if you
knew that the distribution of yield, the probability of
distribution of yield is skewed, that is, not a normal
distribution of yield, if you have the mean yield, but if it
does not conform to a bell-shaped curve, where the mean of X
is in the middle of that distribution and you have a skewed
distribution, it has a lot to do with whether it's skewed to
the right, meaning higher average yield, or skewed to the
left, so on.
               So one needs to observe nature and let nature ÄÄ an
observation of nature to tell you where those distributions
are.  The same is true with prices.
               It all deals with the fact that the biological and
economic worlds are replete with uncertainty and risk.
     Q    Well. . .
     A    It doesn't necessarily. . .
               Go ahead.
     Q    Will Dr. Richardson be responsible for making a
recommendation to the League about whether to use FLIPSIM in
a stochastic or deterministic model?
     A    He's qualified to do so.
     Q    Well, will that be his role, as you understand it?

                         MR. BURGESS:  Object to the form.

BY MR. SAXE:
     Q    Who will be. . .
     A    I'm not the person that is going to be responsible
for it, you know, making that evaluation or determination, or
whether ultimately we should use stochastic or not.  Dr.
Richardson, on our team, is the most qualified to do that.
     Q    Can you do a yield distribution without farm level
data?
     A    Certainly.
     Q    How?
     A    Well, you can have a distribution of yields that
comes from the Crop and Livestock Reporting Service, and if
you know the pattern of history of yields, and if they give
you a monthly pattern of yields or a time series of yields,
or you can develop a probability distribution of yields
without farm level data.
     Q    Are probability distributions the result of a
FLIPSIM stochastic run?
     A    I defer to Dr. Richardson on that, but my
understanding would be that I can develop or he can develop
probability distributions before the run and incorporate
those distributions into the FLIPSIM analysis.
     Q    On a page of output, what numbers are shown from a
FLIPSIM stochastic run?

                         MR. BURGESS:  Object to the form.


BY MR. SAXE:
     Q    As distinguished from the numbers or the type of
numbers that would be shown on the run of FLIPSIM and a
deterministic mode.
     A    Again, I would defer to Dr. Richardson, the author
of FLIPSIM, to give a definitive answer to that, but my
understanding is that there would be a difference in the
output.
               The output differs primarily in this significant
way.  When you do the FLIPSIM, as we applied it in this
particular case, and I will be happy to explain how we
applied it in this case.  One of the key measures that comes
out of that is the probability that the model farm will
survive.  What is the probability of survival?  You can't get
that by using the deterministic ÄÄ you cannot get the
probability by using a deterministic mode.
     Q    Is it correct to say that FLIPSIM is a farm/firm
survival model, rather than an economic impact model?
     A    No.

                         MR. BURGESS:  Object to the form.
                         MR. SAXE:  Grounds?
                         MR. BURGESS:  Lack of definition.
                         MR. SAXE:  Dr. Polopolus answered the
          question, I assume he understood it.
BY MR. SAXE:
     Q    Why is FLIPSIM in the stochastic mode not a
farm/firm survival model?
     A    It's shorter than a farm/firm survival model, as we
applied in this case.
     Q    How did you apply it in this case?
     A    Okay.  We applied it ÄÄ FLIPSIM, as applied in this
case, and I have never had a prior experience with working
with Dr. Richardson, but there are three stages of the
analysis that we conducted using FLIPSIM.
               The first stage was synonymous with the methodology
used by Hazen and Sawyer, that is, in the first stage we did
a determination of quasi-rents.  What that is, is total
revenue minus total operating costs and determining the
return to the fixed factor land.  
               Now, the criterion for survival in land use, in the
Hazen and Sawyer model, was that if total operating costs
exceeded total revenue, land exited.  That was the criteria
of land use, used by Hazen and Sawyer.  That's our
understanding of it.  
               Okay?
     Q    Okay.  
     A    Now, in our application we did the same set of
calculations.  We didn't use debt, long-term debt in the
calculations.  We did not use income tax in the calculation. 
We did not use the family farm expense in the calculation. 
These were not used in that calculation.
               Now, where Hazen and Sawyer exited land, when that
became negative, our methodology continued that land in
production, in many cases with negative quasi-rents.  That's
why in some of our material, relative to this issue, we have
stated that our criteria for land use is more conservative,
that is, we want to keep land in longer than the criterion
used by Hazen and Sawyer.
               Now, you may ask:  Why so?  Because we went from
the theory to the reality of farm behavior and that reality
is that many farmers or their bankers, or the combination of
the two, stay in production for another year or maybe another
year, thinking that weather might be better next year or
something might happen and prices might be better, or
something might happen to relieve this depressed economic
condition.  So we keep them in.
               Okay?
     Q    Okay.
     A    And so then we go to ÄÄ we use the quasi-rent to
determine land values, a very important step.
               All right.  In addition to that, we take the
results and do a cash flow analysis of what the farm unit has
to pay out and this is where the interest on intermediate and
long-term debt and income tax and family living expenses,
things of this nature, this is where they clue into the
equation to determine cash flow, so we can get to the third
stage of our analysis, which is the balance sheet, and the
balance sheet looks at the equity that remains after we have
done all these calculations, the equity to the model farm in
relation to the assets of that farm.  This equity or net
worth ration then becomes our criterion for land use and we
have a very stringent criterion for taking that land out of
use, based on this equity, to asset criteria.
     Q    Go on.

                         MR. BURGESS:  Wait a minute.  I object to the
          form.  I don't know what go on means.

BY MR. SAXE:
     Q    What is that very stringent criterion?
     A    The stringent criterion is bankruptcy where the
equity-to-asset ratio is point one five or where the equity-
to-asset ratio is in a trend, a declining trend ÄÄ excuse me,
a declining trend, and when it reaches point five and it
appears that that will continue to drop, we take the land out
of production.
     Q    And what is the basis for that criterion?
     A    The basis for that criterion is that land values
are falling like a rock, profit rates are falling like a
rock, bankers and others are saying:  Hey, what can we do? 
We have permitted some consolidation already of the small and
the medium, and so on, on farms, and we've permitted all that
consolidation and it doesn't appear that there's enough
resources available or enough interest to bail out the
sinking ship.
     Q    Is that based on any empirical basis or is that
based on. . .
     A    It's based on Dr. Richardson's and my long
experience as agricultural economists.
     Q    Did bankruptcy ever occur in your analysis while
quasi-rent was positive?
     A    I defer to Dr. Richardson on that, but I don't
think so.
     Q    Okay.
     A    I'm quite sure; but, you know, he saw all the
computer runs and all the details, I did not.
     Q    Did bankruptcy ever occur in your analysis when
returns to land were positive?
     A    I defer to Dr. Richardson, but I would highly doubt
it.
     Q    When you indicated earlier that Dr. Richardson
would be the person with the most expertise on the team to
make the determination about the most appropriate use of
FLIPSIM, do I understand correctly that Dr. Richardson would
be the one to determine whether or not the biological
processes that caused or can cause skewed probability
distributions do or don't obtain in the EAA?

                         MR. BURGESS:  Object to the form.

BY MR. SAXE:
     Q    Do you understand the question?
     A    Not very well.

                         MR. SAXE:  Would you read the last question,
          please?
          (Thereupon, last question so read by reporter.)

BY MR. SAXE:
     Q    You indicated earlier, as I understood your
testimony, that the biological processes in the EAA, with
respect to yields and other variables, may be of such a
nature that their behavior over time is not a normal
distribution, but rather a skewed distribution; is that
correct?
     A    We're not looking at the distribution over time,
we're looking at the distribution at a point in time to see
what is the probability that, for example, next year the
yields will be ten percent higher.  What's the probability it
will be twenty percent higher?  What is the probability it
will be ten percent lower?  What's the probability that it
will be twenty percent lower?  And so forth.
               So that's the probability that we are looking at,
not looking at the probability of distribution over time, but
looking at the probability of an event that would occur next
year, two years from now and so forth.
     Q    And is Dr. Richardson the person on the team who is
going to be responsible for assessing. . .

                         MR. BURGESS:  Wait, there's no question.

BY MR. SAXE:
     Q    . . .assessing the applicability of those events in
the EAA over time?
     A    It isn't a question of assessing ÄÄ it's a question
of observing the distribution and reporting it from weather
data or other source.
     Q    And who will be reviewing that data and making that
determination?
     A    Well, if it's ÄÄ Dr. Richardson.
     Q    Okay.  What items do the total operating costs
include in the three-stage FLIPSIM analysis?
     A    I defer to Dr. Richardson for detailed accounting
of that, because my role was not to estimate those and I only
took his output and then went from there.
     Q    Do you know whether it included capital
appreciation?
     A    I defer to Dr. Richardson on that.
     Q    We were talking about the March '93 meeting and you
mentioned that there was discussion about whether to use
FLIPSIM in the stochastic or deterministic accounting modes.
     A    Yes.
     Q    Are those terms interchangeable?
               Well, let me ask you this.
               What is the non-stochastic mode for running FLIPSIM
called?
     A    Deterministic.
     Q    Deterministic?
     A    Yes.
     Q    You also mentioned alternatives to FLIPSIM were
discussed.  Can you elaborate what were those alternatives?
     A    One alternative ÄÄ I think the only alternative 
was ÄÄ although there are many alternatives, I think at that
meeting the only alternative was a Lotus spreadsheet.
     Q    Okay.  You mentioned there were concerns about
limited resources.  What concerns were expressed?

                         MR. BURGESS:  Don't answer that.
                         I will instruct him not to answer.
                                                         MR. SAXE:  Grounds?
                         MR. BURGESS:  Attorney work product.

BY MR. SAXE:
     Q    Were there any concerns about limited resources
that were raised by others, other than attorneys, at the
meeting?
     A    No.
     Q    Okay.  Do you understand that the League has made
any decisions on the number of things that were discussed at
the March meeting?
     A    Pardon?
     Q    Do you understand whether the League has made any
decisions about the things that were discussed at the March
meeting?
     A    Not to my knowledge.
     Q    One of the questions that you testified was raised
was generally where to ÄÄ where do we go from here.
     A    Yes.
     Q    Would it be your testimony that the League made no
decision about where to go from here?

                         MR. BURGESS:  Object to the form,
          mischaracterizes his previous testimony.

BY MR. SAXE:
     Q    Correct my mischaracterization of your previous
testimony, if you will, Dr. Polopolus.  
               Was there discussion about where to go from there,
once the twenty-year analysis was released by Hazen and
Sawyer?
     A    I left at noon, you know, I don't know, there may
have been.
     Q    During your presence at the meeting, was there any
discussion about what further work would be undertaken or
might be undertaken?
     A    Not to my knowledge or not that involved me.
     Q    That might be undertaken by other parties present
at the meeting?

                         MR. BURGESS:  In addition to that which he has
          already testified to?
                         MR. SAXE:  He qualified his last answer by
          saying "not by me", and I'm asking whether there
          were any decisions made about what work other
          parties might undertake concerning the economic
          impact analysis after the March meeting.
                         ANSWER BY DR. POLOPOLUS:  I don't know of any. 
          I don't recall any.  I don't know.

BY MR. SAXE:
     Q    How were things left, as you understood the outcome
of the March meeting?
     A    I don't know.  I left that meeting, because I had
an ambassador and I had to leave early so I left about noon.
     Q    Have you had any discussions with anybody since the
March meeting about the March meeting?
     A    No.
     Q    What do you presently understand to be expected of
you once the twenty-year analysis is released?
     A    I expect to conduct the aggregation analysis and
economic impact analysis part of the review of the twenty-
year Hazen and Sawyer study.
     Q    But you don't know whether Dr. Richardson's part of
the farm/firm analysis will be done using FLIPSIM in the
stochastic or deterministic mode?
     A    No.
     Q    Is it possible that Dr. Richardson won't do any of
that work?

                         MR. BURGESS:  Object to the form.

BY MR. SAXE:
     Q    As you understand it.
     A    I really don't know.
                     Q    Was there a discussion about what the Cooperative
might do?
     A    The Cooperative, I think, has expertise in
community impact ÄÄ I mean, the economists for the
Cooperative, represented at that March meeting, have
expertise in community impact analyses.
     Q    Will you or anyone on behalf of the League be
undertaking community impact analyses?
     A    I don't know.  I don't intend to.  I haven't been
asked to.
     Q    As you understand the March meeting, were there any
decision criteria identified for determining how to make the
decision about how to proceed?
     A    No, not to my knowledge.
     Q    So would it be a fair characterization then of your
understanding of the March meeting that many things were
discussed concerning how the parties present at the meeting
might proceed once the twenty-year economic impact analysis
was issued by Hazen and Sawyer, but that there were neither
decisions made about how to proceed nor were there
indications of how decisions might be made about how to
proceed?

                         MR. BURGESS:  Object to the form.
                         MR. SAXE:  Grounds?
                                                         MR. BURGESS:  Mischaracterizes. . .
                         MR. SAXE:  I'm asking if that is a fair
          characterization, I'm not asking the witness. . .
                         MR. BURGESS:  I realize that, but the record
          speaks for itself.
                         MR. SAXE:  How can you object to
          mischaracterization of an understanding that he
          hasn't testified to?
                         MR. BURGESS:  I think the record is clear as
          to what he has testified to.

BY MR. SAXE:
     Q    Dr. Polopolus, did you understand my question? 
Would you like me to have the court reporter read it back?
     A    At this point I would like for her to read it back.

          (Thereupon, last question so read by reporter.)

                         MR. SAXE:  All right.  Let me restate the
          question.

BY MR. SAXE:
     Q    What kind of possible division of labor or
coordination between the League experts and the Co-op experts
was discussed at the March meeting?
                     A    I don't recall any specific discussion or any
division of labor.  I mean, the part of the meeting I
attended was sort of a brainstorming session:  What are the
main issues or what are the primary issues of the difference
between Hazen and Sawyer's likely analysis on March 15th and
how would you prioritize the big issues?  That was the ÄÄ it
was more of a brainstorming around those issues, rather than
who might do what.
     Q    Okay.  Do you understand that there was any
discussion at the meeting about an option for the League
expert to do direct, indirect and induced impact analyses and
for the Cooperative experts to do other secondary impact
analyses, based on that work?
     A    Again, I don't have a clear understanding of that,
because Dr. Luke and I only overlapped ten minutes in that
meeting, so I don't really know what was discussed after I
left.
     Q    Okay.  Thanks.
               That brings us through the March '93 meeting.  
               Had you been invited to an economists' meeting in
February, on the twenty-year plan?
     A    I did not know it was the twenty-year plan, when I
was invited to a meeting in February.
     Q    Can you tell me about that?  
               In your testimony we went from a situation at the
January '93 Governing Board meeting to the March '93 meeting
among the parties and if there were any other events in
between concerning the development of the analysis or the
planning of the work I'd like you to identify them for me.
     A    Are you asking about the February meeting or other
plans?
     Q    Any and all, including the February meeting.
     A    With regard to the February meeting, I would have
liked to have attended and I regret that I was not there, but
I believe that I ÄÄ I know I received communication from Dr.
Johns about it and I believe I called her or she called me
about it.
               My problem on that particular date is that it was a
prior commitment, I believe the date was February the 3rd,
and on that date I had previously committed several months in
advance to assist in the training of twelve Russians, who
were in the United States as guests of our State Department,
on marketing and management techniques.  So I was in Tampa,
Florida on that day and for several days surrounding around
February 3rd, in a training session, that the University of
Florida had with the Vice Mayor of Moscow and eleven other
representatives of management and marketing personnel from
Byelorussia and Russia.
               So I'm sorry.
     Q    Was there any other work undertaken between the
January '93 Governing Board meeting and the March meeting, by
any other people, economists working for the League?
     A    I can't speak for the other economists or the
League, but I was not engaged in an analysis.
     Q    Do you know whether Dr. Richardson was?
     A    I'm not aware.
     Q    Okay.  I think I may have asked you that before, I
apologize if I repeated the question.  
               Did you know that the February meeting of the
economists was postponed to the 10th so that you and Dr.
Richardson could attend?
     A    No.

                         MR. BURGESS:  I'm going to post-date an
          objection to the question, since it lacked
          predicate, since I know that was not the reason for
          the meeting being postponed.
                         Note my objection.

BY MR. SAXE:
     Q    After the March '93 meeting, what was the next
step, if any, that was undertaken by you or Dr. Richardson or
Peterson Consulting in this case?
     A    The next major event is underway.
     Q    Okay.
                     A    This deposition.
     Q    Other than the meeting in March, at which
representatives from the Cooperative were present, and there
may or may not have been some discussion of the respective
work of the parties in preparing expert testimony on economic
impact and economic issues, have you had any contact, during
the course of your role as a potential expert witness in this
case, with either Dr. Luke or Dr. Leistritz or any other
representatives of any other parties in this case:  economics
representatives?
     A    No, I never met Dr. Leistritz or talked to him, so
I don't know him.  I know him by reputation, but I haven't
talked to him on any subject on any matter.
               Dr. Luke, I only have spoken to him twice.  Once he
asked to speak to me at the November 19th meeting of the
Funding Council in Belle Glade, and then I saw him for ten
minutes in Tampa, Florida at the meeting in March of '93.
     Q    Do you know whether there have been meetings
between other members of the team, and by team I mean Dr.
Richardson and/or the Peterson Consulting personnel, with Dr.
Luke or Dr. Leistritz or. . .
     A    I am not aware of any such meetings.
     Q    Other than the communication from Mr. Wedgworth,
that occurred before March of '93, are there any other
communications that you're aware of between you and any other
League team members with any of the Cooperative economists?
     A    None to my knowledge.
     Q    Dr. Polopolus, in the League's expert witness
designation for you, the League indicates that:  
               "A substance of expected testimony" and it says: 
"Analysis of District's economic study.  District's study is
seriously flawed and understates the potential economic
impact of implementing the SWIM Plan."
               Did that represent your opinion at the time of the
expert witness designation, as far as you know?
     A    Yes.

                         MR. BURGESS:  Give him the date.  
                         I think it was October of '92.

BY MR. SAXE:
     Q    I don't have a date with me, so assume it was
October of '92.
     A    As of that date, yes.
     Q    Is it still your opinion?
     A    I don't know.  I await the report of Hazen and
Sawyer, based on the twenty-year analysis.
     Q    With respect to the ten-year study that came out in
July in draft and then in final form, and subsequently
released in a contract completion report, would that be an
accurate statement of your general opinion of that work. . .
     A    Yes.
     Q    . . .of the Hazen and Sawyer study?
     A    Yes.
     Q    Will you be testifying at trial to your opinions
about the District's economic impact studies, whether it's
the ten-year or the twenty-year?

                         MR. BURGESS:  I think my only preface, I
          guess, in the nature of an objection would be that
          Dr. Polopolus would only know what he's going to
          testify to at the time of trial, in response to
          what counsel has told him to prepare for trial, and
          he would be responding to questions from counsel at
          the trial and I think that I can represent on the
          record, as I have represented or it has been
          represented at the hearings in this matter, that
          assuming Hazen and Sawyer's twenty-year study is
          completed and assuming that it does what its
          author, Grace Johns, testified to, which will
          supersede the ten-year study, we would only be
          asking Dr. Polopolus to testify concerning the
          twenty-year study and we would not be asking him to
          review the ten-year study of Hazen and Sawyer.
                         MR. SAXE:  All right.
BY MR. SAXE:
     Q    Okay.  Let me take a different line on the
question.
               Based on your earlier testimony, you have been
designated by the League to give potential expert testimony
on the District's ongoing economic study and also on regional
and statewide economic impacts on the SWIM Plan, you
indicated that that was consistent with your understanding.
               Now, besides testimony you might give concerning
any economic ongoing or otherwise economic study that the
District is conducting, might you be presenting opinions on
the potential economic impacts of implementing the SWIM Plan
that are not based on a study that is being conducted by the
District through Hazen and Sawyer or otherwise?
     A    I don't know.  I don't know that I understand the
question.
     Q    Well, let me rephrase it.
     A    Okay.
     Q    Will you just be testifying with respect to defects
in the District's study or might you also be testifying with
respect to independent economic impact analyses performed by
the League or others?
     A    At this point my frame of reference is only as a
reviewer of the Hazen and Sawyer twenty-year study.
     Q    So would it be fair to say at this time that it's
not consistent with your understanding of the scope of your
potential expert testimony that you would give testimony
about independent economic impact analyses conducted by the
League or others?
     A    Not unless the District ÄÄ excuse me, unless the
Hazen and Sawyer study is not forthcoming.
     Q    Well. . .
     A    Or, let's take another scenario.
     Q    Okay.  
     A    If the Hazen and Sawyer study is produced, but
Hazen and Sawyer economists do not present the report at the
trial, then there may be a different ÄÄ I may be asked to do
something in a more positive mode, but my present
understanding is that my role is to react and respond and
critique and evaluate the twenty-year Hazen and Sawyer study.

          (Thereupon, a short recess was had; whereupon, the
          following proceedings were held:)

BY MR. SAXE:
     Q    Dr. Polopolus, I understand from your testimony
that there remains some uncertainty before the next step or
phase of the Hazen and Sawyer analysis is released.  There
remains some uncertainty about just exactly what the League's
experts are going to be doing to prepare for trial.
                                               With that understood, can you describe for me, as
best as possible, chronologically starting with the first
step, any additional work that you, Dr. Richardson or the
Peterson Consulting group may be doing before trial to
prepare for your expert testimony?
     A    Well, it assume and depends upon the existence of
the twenty-year study by Hazen and Sawyer.
               Given that, then my general understanding is that I
will be doing the type of analysis that I did earlier in
reviewing the Hazen and Sawyer work, namely the aggregation
of the FLIPSIM or whatever farm mode structure is employed
and the application of multipliers to estimate the economic
impact.
     Q    Breaking it down a little bit finer for me, what
would be the first step and who will do it?
               Now, I will repeat the question, but based on what
you just said, it suggested to me that the first step would
be work being done by Dr. Richardson to produce farm/firm
output that you would then be aggregating, and if that is
correct I would like for you to really start at the beginning
and take me through it, on the assumption that there is a
Hazen and Sawyer twenty-year analysis.
     A    Okay.  Assuming that there is a Hazen and Sawyer
twenty-year analysis, Dr. Richardson would conduct the micro
or farm level impact analysis and whatever analytical
technique that is chosen and then I will see that information
and apply the aggregation and the multiplier analysis to
that.
     Q    Before we get to the next step of your work.
               When you say whatever methodological tool is used,
you mean whether it's FLIPSIM or Lotus or whether it's
stochastic or deterministic.
     A    That's correct.
     Q    Okay.  What data do you understand that Dr.
Richardson will use when he does his micro-farm level impact
analysis?
     A    Publicly available data.
     Q    And specifically what categories of data will form
a part of that analysis, as you understand it?
     A    Costs and returns.
     Q    Is that correct, publicly available costs and
returns data; is that correct?
     A    Yes.
     Q    Is that going to be the same data that Hazen and
Sawyer used in the ten-year analysis?
     A    I really don't know.  It could be.
     Q    Okay.
     A    Obviously we have a ten-year extension, so we're
not where we were going to the year 2003, you know the
twenty-year analysis takes another ten years, to 2013,
whatever that year is.
     Q    Will it be the same cost and return data that Hazen
and Sawyer uses for the twenty-year analysis?
     A    Like categories of data, like would it be the same
type of cost data, or would the numbers be the same?
     Q    Both.  Start with types.
     A    The types would tend to be similar.
     Q    Okay.
     A    The numbers could be different.
     Q    Okay.  I think I'll need more specificity so I
understand what is potentially going to be done to be prepared.
     A    All right.
     Q    What types?
     A    The costs and returns.  We'll just take the easier
part of that equation.
     Q    All right.
     A    Would be total revenue or total receipts.
               Total revenue is quantity times price, unit price
times the quantity.
               So for each of the commodities that are relevant to
the EAA, then one would have to make an estimation of
quantity.
               In this case quantity that exits from the baseline,
due to the impact of the STAs, the BMPs, and so on, the
quantity reduction times the value of that quantity that is
lost.

                         MR. BURGESS:  For the record, when Dr.
          Polopolus talks in terms of STAs, he's not talking
          about the subject near and dear to Mr. Saxe's and
          my heart, he's talking about the S-T-As.

BY MR. SAXE:
     Q    When you say a quantity exiting, that would not be
a calculated or derived value, that is going to be an
inputted value?
     A    The quantity of ÄÄ are we back to. . .
     Q    Talking about Dr. Richardson.
     A    Excuse me, I stand corrected.
               We're back to the FLIPSIM part of this.
     Q    Right.
     A    And he'll have to do an estimation of what the
model farm output is and what the model farm price is, do
that calculation of total farm revenue.
     Q    Okay.
     A    And for that you would have to have an estimate of
quantity and for that you would have to have an estimate of
price.

                         MR. SAXE:  Would you read that answer, please?
                          (Thereupon, last answer so read by reporter.)

BY MR. SAXE:
     Q    What did you mean by the model farm output and
model farm price?
     A    Again, I defer to Dr. Richardson, who is the expert
on the modeling, where we have adopted the Hazen and Sawyer
model farms, but in Zone Belts 1 and 2, for example, where
there is a large farm in Zone Belts 1 and 2 and a small farm
in Zone Belts 1 and 2, these are characterized by an average
size in the Hazen and Sawyer, assuming that they continue
their twenty-year analysis, within that same model structure,
then we will model it similarly, and so then we're talking
about within each zone belt there is this model farm in the
Hazen and Sawyer, and we'll estimate the total revenue that
comes out of those model farms.
     Q    So that would be the net revenue, then, total
revenue?
     A    It would be the gross revenue.
     Q    Gross revenue?
     A    Yes.
     Q    And that would be a function of the quantity of
crop produced on that acreage under those yield assumptions
times the unit price?
     A    To get the total revenue for a particular time
period.
     Q    What unit price will be used for that calculation?
     A    That's a determination for Dr. Richardson to make.
     Q    How about the quantity, is that also a
determination for Dr. Richardson to make?
     A    That is correct.
     Q    Okay.  
     A    Based on yield and other factors.
     Q    And you would not be providing guidance with
respect to those assumptions or that input data?

                         MR. BURGESS:  Those two assumptions, price and
          quantity?
                         MR. SAXE:  Well, I didn't want to assume that
          they were going to be assumptions.

BY MR. SAXE:
     Q    So whatever they're going to be, that's not going
to be something regarding which you're going to have input
on?
     A    Not really, not a major input.
     Q    And. . .
     A    Probably review it.
     Q    And you don't know whether the price data and the
quantity data will be the same price data and quantity data
that Hazen and Sawyer use in the twenty-year analysis?
     A    It could be, I don't know, we haven't seen the
twenty-year analysis.
               Once we see that analysis then we may adopt it, we
may not.
     Q    If it's the same as the ten-year analysis, would
you adopt it or would Dr. Richardson adopt it, as you
understand?
     A    Well, we have some problems with the price.
     Q    What would those problems be with the price?
     A    Price level, price trend.
     Q    Okay.  By price level what do you mean?
     A    What does the model farm expect to receive per ton
of cane or per net ton of cane, per standard ton of cane, or
whatever definition of cane we're talking about, and we would
have to review the twenty-year analysis, but we may agree
with the new Hazen and Sawyer assumption with respect to
price.
     Q    I think it may be more constructive for us to defer
some of this discussion of your future work until we have had
an opportunity to discuss your specific criticism of the ten-
year analysis.  It might become clearer in the context of
that discussion where you might depart from Hazen and
Sawyer's methodology and assumptions and work that you might
be doing.
                                               So why don't you just frame it out for me more
generally, as you started to do?
               You indicated that Dr. Richardson would be doing
the micro-farm level impact analysis, using publicly
available cost and return data.
               Then the next step, as I understand it, was that
you would aggregate the micro-farm level impacts to an
industry-wide direct impact. . .
     A    Yes.
     Q    . . .value?
     A    Yes.
     Q    And then what?
     A    Apply the multiplier analysis to that.
     Q    And what multiplier analysis would that be?
     A    Determine the direct induced and indirect economic
impact in terms of employment, in terms of earnings and
sales.
     Q    Would you be using Leontief input/output for that
purpose?
     A    Yes, indeed.
     Q    Do you know what multipliers you might use or where
they're from?
               Let me restate that.
               Do you know whether you'll be using Rims
multipliers for that analysis?
                     A    Well, we'll evaluate the availability and quality
of multipliers and make a determination.
     Q    Would that be your primary recommendation?
     A    Yes, it will.
     Q    What are your criteria that you might be using in
making that evaluation?
     A    We will, first of all, we will not estimate
original multipliers.  We will use Rims or other multipliers
estimated by regional economists.

                         MR. SAXE:  Would you read that back for me?
          (Thereupon, last answer so read by reporter.)

BY MR. SAXE:
     Q    What are some candidates?
     A    Well, within our own University of Florida faculty
there would be the work of Dr. Mulkey and Clouser, for
example.
     Q    Any others that you're aware of right now?
     A    Well, for other sectors, like in vegetable sectors,
we have other economists that have applied multiplier
analysis and we'll look at maybe some of that work.
     Q    What other economists or who are these other
economists?
     A    Well, the work of Ann Moseley, for example.
                     Q    Are there any other candidates?
     A    I can't recall any at this point.
     Q    Okay.  Will you use the same three-stage approach
that was used in the ten-year analysis?  With respect to the
ten-year analysis?
     A    We will use. . .
     Q    The same three-stage approach that was used with
respect to the ten-year analysis?
     A    In the multiplier analysis?
     Q    No.  The farm analysis, as you discussed it
earlier.
     A    The FLIPSIM analysis?  
     Q    Beginning with the FLIPSIM analysis and moving
through stage two and stage ÄÄ yes, the three stages of
FLIPSIM used, that's correct.
     A    The two basic stages, one is the FLIPSIM analysis
and the other is the aggregated multiplier analysis.
               Within the FLIPSIM analysis, which I think I
earlier testified to, the three stages of the FLIPSIM
analysis.
               As I understand your question. . .
     Q    It doesn't apply.  
               If the question doesn't make sense to you.  That's
fine.  Let me withdraw it and I'll rephrase it.
               What I would like you to do is elaborate from the
step of moving on the farm level to the industry level
analysis.
               What comes out of the third stage of the FLIPSIM
analysis and comprises input to the aggregation process that
you will by undertaking, assuming there's a twenty-year
report?
     A    Assuming that the FLIPSIM is run in a stochastic
mode, what comes out is the probability of survival of the
model farms.  That's a key piece of information that I use to
determine the land that may exit.
     Q    And how do you use that probability of model farm
survival?
     A    We can take some hypothetical examples, if you
would like, and just talk about it.
     Q    Okay.  That sounds good.
     A    Okay.  Let's say, for example, in Zone Belts 1 and
2 that where you have the small farm, model farm, and Hazen
and Sawyer analysis, and the large and the small farm in that
analysis, in that zone belt, and from Hazen and Sawyer's
report they indicate that the number of acres that represents
the large farms in Zone Belt 1 is X thousand acres and the
number of acres representing the small farms in Zone Belt 1
and 2 is Y number of acres.
               Now, let's assume that after we run the analysis of
total revenue, you know, run the FLIPSIM analysis that ÄÄ you
know, once we run the FLIPSIM analysis we get the probability
of survival, I believe our intention is that when ÄÄ and I
believe this is characterized as the December 16th analysis
that we presented to Dr. Johns ÄÄ that if the small farm has
the probability of survival of fifty percent, that we would
take the fifty percent that exits the small farm and now
becomes the property of the large farm.  So the large farm
cannibalizes the small farm.
               So in that situation, if the probability of
survival of the large farm is a hundred percent, there's been
no land that exits.
               Okay?
     Q    Okay.
     A    Now, let's take another hypothetical.  Let's take a
hypothetical where the probability of survival of the small
farm is zero and the probability of survival of the large
farm is fifty percent.  There are standard operating
procedures that we are likely to use.  All the land that is
attributed in the Hazen and Sawyer report to the small farms
in Zone Belts 1 and 2 would be cannibalized into the large
one, they would acquire them, so all that land shifts over. 
So whatever those acres are, are now moved over to the large
farm and they become basically the large farms, but I said
with a fifty percent probability of survival of the large
farm in Zone Belt 1, we now have aggregated over the land
that was formerly the small farm and it has now become a part
of the large farm and the probability and key number I need
is:  Okay, given that now, fifty percent probability of
survival at the land that is represented by that fifty
percent of this aggregation small farm, tells me the land
that exits from use, farm use, given that, then I begin my
aggregation analysis.
     Q    So in that hypothetical you just described, fifty
percent of the land in Belt 1 would be production?

                         MR. BURGESS:  Object to the form.  
                         Given all the same assumptions that he had for
          his hypothetical?

BY MR. SAXE:
     Q    In that hypothetical you just described, that's my
question.
               Fifty percent of the land in Belt 1 would be
production.
     A    I believe Belts 1 and 2 are aggregated together, so
it's Belts 1 and 2.
     Q    Okay.
     A    And then we would assume that fifty percent of that
acreage in those two Zone Belts would exit.
     Q    So, again, in that hypothetical, large farms buy up
the small, then half of this new large structure goes out of
production?  Is that. . .
     A    That would be ÄÄ the numbers show that and the work
product revealed that, and I would accept that as, you know,
all the criteria for survivability and all the criteria for
quasi-rents and all the other things that we talked about
earlier, all those tests would have to be ÄÄ and then, yes,
that would be the result.
     Q    So then the output of the three-step FLIPSIM
analysis, assuming it's run in a stochastic mode, would be
acreage leaving production; is that correct?
     A    Excuse me, would you repeat the question?
     Q    Yes.  The output of the three-step FLIPSIM process,
assuming it's run in a stochastic mode, and the input for
your aggregation process, would be a number of acres leaving
production?
     A    No.  The probability that that acreage would leave
production.
               The FLIPSIM gives, in stochastic mode, gives the
probability, not the acreages.
     Q    So the first step in the aggregation process is to
convert those probabilities into a hard number of acres
leaving production?
     A    Yes.
     Q    Okay.  The output of the third stage of the FLIPSIM
use, step me back a little bit deeper into that I guess third
stage of the FLIPSIM use.
               How does it produce a probability of a certain
model farm's survival?  Where does it come up with the
acreage figure?
     A    Well, you'd have to ask Dr. Richardson for the
precise answer to that, but my understanding is that in the
probabilistics stochastic mode enough random configurations
are developed by the computer to permit probability
assessments.  There's a lot of computer. . .
     Q    Processes?
     A    . . .processes that are involved in that stochastic
part of it.
     Q    Okay.  Thank you for that answer.
               I think my question needs clarification.
               Basis for the acreage distribution in the model
farm, the association of numbers of acres with a particular
model farm, in a particular yield belt.
     A    Yes.
     Q    Is that going to be taken from the Hazen and Sawyer
analysis?
     A    That is our intention.
     Q    What is the next step in the aggregation process
that you would be undertaking?
     A    You mean after we had the probability. . .
                     Q    Converted probability into number of acres, right.
     A    Well, then that's where we made the determination
for each of the zone belts and all the commodities that are
involved:  sugar cane, vegetables, sod, rice, and so on and
so forth.  Then we make a determination of basically a
revenue or sales figure, an estimate of economic value
represented by that lost acreage, for each of the commodities
that are of interest in the EAA.
     Q    And will you do that by multiplying the yield per
acre, by the unit price for that commodity, for that crop in
that belt to get value?
     A    No.  We're beyond the per-acre business.  We're now
in aggregate acres and what becomes significant here is a
valuation, for purpose of Leontief analysis, what is the
value, the unit value of that unit of production lost.  So we
have to ascribe a price.
     Q    Okay.
     A    In the case of sugar cane it's the value of the raw
sugar plus the value of the molasses, represented by the
acres lost.
     Q    And the calculation for value, based on acreage,
what are the components of the calculation, the multipliers
and the. . .
     A    Well, we have the acreage, then we have our ÄÄ
correction, we have to have the yield.  Then we have to
produce ÄÄ we have to estimate a yield, and for the yield
estimation and for the price estimations we're using public
available data, USDA data and if Hazen and Sawyer's numbers
draw from that source it's most likely that we will use that
source, the five year average of yield, the average price of
raw sugar, and so forth.
     Q    Let me take a slice right here for a moment.
               When do you expect the League will make its
decision or determination about exactly how it's going to
proceed in doing further analyses to prepare for trial?

                         MR. BURGESS:  I object to the form, assumes a
          determination has not been made.  He's already
          testified that the way he's going to proceed is by
          reviewing that report.

BY MR. SAXE:
     Q    You testified, if I recall correctly, that you're
not sure whether FLIPSIM will be used in a stochastic mode at
all and, therefore, I assume that you're not sure that you'll
be doing that three-step use of FLIPSIM that you've just been
describing; is that correct?

                         MR. BURGESS:  Because Dr. Richardson will be
          making that determination; that's what he
          testified.

BY MR. SAXE:
     Q    Do you understand that that decision has been made,
but you're. . .
     A    I'm not aware of any decisions being made.
     Q    Okay.
     A    I'm on ready to do my part of the analysis.  So
when it come to me I'll do that analysis, whether it's. . .
     Q    So then you won't be in a position to determine
precisely what work you will be doing or specifically what
sources of data you will be relying upon for your part of the
work, in preparation for trial, until Dr. Richardson has made
all his decisions and completed his work; is that true?

                         MR. BURGESS:  Object to the form, compound,
          and he's already talked about the fact that
          publicly available data is going to be used.

BY MR. SAXE:
     Q    Let me clarify.  Whether you will be using the same
publicly available data that Hazen and Sawyer used or other
publicly available data, that you're presently not in a
position to disclose, as you sit here testifying today.
     A    As I sit here today, I don't know if I'll use a
five-year average from USDA on the price of raw sugar, or a
ten-year average, or whether that five-year average, if it is
a five-year average, will be 1987 to 1991 or 1992 or whether
it will be some other time period.  It may be that the prices
that Hazen and Sawyer use in their revised report are
adequate.
     Q    When. . .
     A    So that's a determination that can readily be made,
but is not made.
     Q    When will you know those things?
     A    When I begin working on it.
     Q    When will that be?
     A    When we have the Hazen and Sawyer report.
     Q    The date the Hazen and Sawyer report is released,
that will be the date you will be able to specifically
address those things that you are presently not in a position
to address?

                         MR. BURGESS:  Object to the form.  That's when
          he will be able to start working on it.
                         MR. SAXE:  All right.

BY MR. SAXE:
     Q    Dr. Polopolus, my question is, when will you be in
a position to testify concerning the specific sources of data
and the specific methodologies, the specific assumptions that
you will be using or that will be used by other League
experts to prepare your trial testimony?
     A    There will be a time lag after the receipt of the
Hazen and Sawyer twenty-year study.
     Q    Can you give me some estimation of how much time lag?

                         MR. BURGESS:  What do you want to know,
          counsel?  What he will be able to do at that point
          in time after the report is issued?  That he's
          going to have his final opinions that he will
          testify to at the time of trial?
                         MR. SAXE:  No, that's not my question.

BY MR. SAXE:
     Q    My question is, when will you know, not bottom
line, not economic impact conclusions, but sources of data,
methodologies and assumptions that you will be using as you
perform the work to prepare for trial?
     A    My framework of analysis is relatively simple,
because what I'm dealing with is estimating the value of lost
acreage, so I'm going to be using publicly available data on
yields, publicly available data on prices and publicly
available multipliers and specifically what those numbers are
going to be I don't know at this point, but they will be in
the public domain and within a matter of weeks, possibly a
month after I initiate my effort I should be able to say: 
Well, it looks like we're going to use the five-year average
of raw sugar prices reported by USDA for the period. . ., and
we're going to use the molasses price of so many cents per
gallon from USDA, for the period. . . and, therefore, the
valuation that we place on the lost sugar cane acreage will
be in the neighborhood of this.
               But, again, I would have to await the FLIPSIM
results so I can do the calculation of how many acres are
lost.
     Q    That's helpful.
               So then it would be fair to say that it's likely
that within a month, at the outset, from the publication of
the Hazen and Sawyer twenty-year analysis that you would be
potentially ready to have another deposition at which you
would answer the questions of the specific sources of data
that you would be using, the assumptions and methodologies,
specifically with respect to sufficient details to enable
somebody else to reproduce the work that you were going to be
doing.

                         MR. BURGESS:  The only part of the question
          that I object to is, Dr. Polopolus, you don't need
          to assume for purposes of this question that you
          need to show up at an additional or subsequent
          deposition.
                         I will just state for the record that
          counsel's decision to go forward with this
          deposition, in the face of our Motion for
          Protective Order, and representations that were
          made at the time of hearing, regarding Dr.
          Polopolus' need to consult Hazen and Sawyer's
          twenty-year report, may well obviate counsel for
          the United States' entitlement to take any further
          deposition of this witness.
                         MR. SAXE:  Noted for the record.
                         Would you please reread my question.
          (Thereupon, last question so read by reporter.)
                         MR. BURGESS:  With my objection noted, you can
          answer.

BY MR. SAXE:
     Q    Let me rephrase it.
               In your estimation, would you be in a position to
describe specifically what sources of data you would be
using, what methodologies you would be using and what
assumptions you would be using in completing the work to
prepare for trial, no more than one month after the
publication date of the Hazen and Sawyer twenty-year
analysis?
     A    I would have difficulty saying no more than,
putting that restriction on it.  It could be more than one
month.
     Q    I'm looking for likelihoods.  I'm not asking for a
hundred percent certainty.  I'm trying to get first your
probabilistic estimation of the lead time or turnaround time
for your readiness to answer those questions, then we'll take
it from there.
     A    Because of the time lag that would require Dr.
Richardson to conduct his analysis, so really my framework of
reference is not the Hazen and Sawyer report, for my
analysis, but the FLIPSIM analysis.  Within that framework
then, yes, maybe within a month I could ÄÄ I would have all
the data and the assumptions and the time frames and the
sources of data known.  So that. . .
     Q    Let me get clarification, just to make sure that
you understood my question and that it's clear.  
               I'm not asking for an estimation of the date on
which you would be ready to give me your final results or to
give your final results in terms of the conclusions of your
work, I'm asking merely about the relative time or turnaround
time you would need in order to answer the questions about
what your specific sources of data would be, your assumptions
and methodologies.
                                               With that clarification, you may ÄÄ you may have
answered the question, but I just wanted to make sure you
understood that, that I wasn't asking for your final results,
but rather those specific nuts and bolts questions that would
enable somebody to reproduce the work that you were
attempting.
     A    A month is ÄÄ there is a reasonable probability
that I could have all that within one month.
     Q    One month of the Hazen and Sawyer report or
completion of Dr. Richardson's work?
     A    As you have phrased it, one month of the Hazen and
Sawyer report, I would have some indication of where I'm
going with the data and what data were used and so forth.  
     Q    Okay.
     A    Possible.  Some reasonable probability, but maybe I
should put a point five.
     Q    Point five?
               Okay.  Take me up to point nine, if you could, in
your best estimation.
     A    Then I would have to include Dr. Richardson's
analysis, because I will have some interplay with Dr.
Richardson in the conduct of that analysis with respect to
certain assumptions.
     Q    Could you quantify that for me, in ballpark. . .
     A    Well, for example, an issue that I feel I have some
expertise to offer has to do with sugar policy; price policy;
it has to do with international trade policy; it has to do
with, to some extent, with mill efficiency; with some extent
to technology, both production and milling level, these kind
of issues, which become an important part of the FLIPSIM or
the farm level analysis.
     Q    What I was hoping for was some approximate
quantification of the time, as opposed to the factors.
     A    Well, I'm trying to answer it with time, because
what I'm saying is my preoccupation initially won't be with
what data I'm going to use to do the multiplier analysis.  My
initial preoccupation will be to review the Hazen and Sawyer
report, with respect to the level of the price, the price
policy assumptions, how international trade issues are being
dealt with, how mill immigration with the grower is being
dealt with, how price enhancement, through mill efficiency,
is being dealt with, so on and so forth.
               So that will impinge upon my time and, therefore,
it will also reflect the attention that I may play or pay to
the sources of data for the prices and yields that are
necessary to estimate the value of production lost due to the
STAs, the BMPs and assessment.
     Q    Can Dr. Richardson do the FLIPSIM, assuming
stochastic FLIPSIM three-stage analysis, as you described,
can Dr. Richardson perform that analysis without that price
level and yield information that you're going to have to make
some initial determination about?
     A    He could.  I hope he consults with me on some of
the points.
     Q    Will his work be complete without that information?
     A    Well, he would have to have some price information. 
He would have to make some assumptions about price policy, so
on and so forth.
               Could he do it without consulting with me?  Yes.
     Q    Tell me, if you would, Dr. Polopolus, what is
likely to happen, rather than what is logically possible.
               Will you be making some initial determinations
about such matters as price levels and yields, in light of
national and international agricultural policies, treatises,
et cetera, and will that information ÄÄ if you would, just
answer that first question.

                         MR. BURGESS:  And in light of his review of
          the Hazen and Sawyer report?
                         MR. SAXE:  Correct.
                         MR. BURGESS:  Okay.

BY MR. SAXE:
     Q    Go ahead.
     A    Given the twenty-year Hazen and Sawyer report, I
will consult with Dr. Richardson regarding those aspects of
his analysis, for which I feel I have some expertise.
     Q    And within how much time?  A day, a week, two
weeks, a month?  For instance, would it be highly likely that
you would have completed that initial assessment and
consultation?
     A    It depends on the nature of the Hazen and Sawyer
report.
     Q    Okay.  Then if you would, give me a range, best
case and worst case, if you will, of highly likely completion
of the initial stage.
     A    If, for example, Dr. Johns uses price assumptions
that we view as realistic, uses assumptions with regard to
mill efficiency that we think are reasonable, makes a number
of assumptions that we think are reasonable, it's possible
that that time frame would be very short, could be a matter
of weeks.
     Q    So if I understand your testimony, I'm going to
characterize it and you tell me if it's unfair or inaccurate.
     A    Right.
     Q    If you're in substantial agreement with Hazen and
Sawyer's treatment of those elements, then it could take as
little as several weeks for you to make that initial
assessment; is that correct?
     A    That's correct.
                     Q    If you're in substantial disagreement with Hazen
and Sawyer on those elements, what is the likely time frame
for you to complete that initial review and assessment
preparatory to the actual FLIPSIM number crunching and the
additional work?
     A    With substantial disagreement obviously it would
take more time.
               Another factor would be the status, for example, in
the trade policy area, the status of GATT negotiations and
the likely impact of NAFTA on domestic sugar prices, for
example.
     Q    Assume for purpose of answering my question that
the League elected to ask you to proceed without waiting for
further developments on those issues, on the national and
international political front, assume that's not a factor,
how much time ÄÄ what is the likely multiplier factor, if you
will, on the about two-week time it would take you if you're
in substantial agreement, if there's substantial disagreement
with Hazen and Sawyer's report?

                         MR. BURGESS:  Do you understand the question?

BY MR. SAXE:
     Q    We're talking about, as I understand it, we're
talking about what I called before a preparatory review of
the Hazen and Sawyer work, to decide on the appropriate price
level, yield and other input values, if you will, for the
work that Dr. Richardson will initiate with the FLIPSIM.
     A    Correct.  Exactly.  It could be a matter of weeks.
     Q    I'm looking for a likely realistic figure, if you
will, not kind of a pie-in-the-sky optimistic figure.
     A    Right.
     Q    We've gotten one from your previous testimony of a
couple of weeks, if there's substantial agreement with the
Hazen and Sawyer treatment, and now I'm trying to get the
upward bounds, if there's substantial disagreement.
     A    Right.
     Q    So presumably it would be more than a couple of
weeks.
     A    More than a couple of weeks.
     Q    Would it be twice as much, three times as much? 
Something that you would be comfortable with, in terms of
reasonable conservative estimate of time.
     A    Economists always like more time and we like to
commit to ÄÄ the economic environment, to some form of
econometric or empirical analysis.  So given the time, one
would ÄÄ for example, the case of international trade policy,
given time, what I think would be an appropriate analysis
would be the estimation of price flexibilities and with
respect to increased imports, that could come about by way of
international trade agreements, whether they be GATT or
whether they be NAFTA.
               So the point I'm trying to make at this juncture is
that if the League feels this is a big issue, I would be
prepared to estimate those price flexibilities, conduct an
econometric analysis.  
               It may be that because of time and resources that
that's not in the cards and, therefore, we will make then
other estimates of these price flexibilities in some way or
another, but in some way or another we're going to try to
make an estimation of the likely impact of increased imports
of sugar, on the price of sugar.
     Q    As I indicated before, for the purpose of the two-
week estimate, you gave me, as a lower bounds, for readiness
to provide input to Dr. Richardson, I asked you to assume
that the League elected not to have you either ÄÄ well, I
said to wait for political developments, assume also now, for
purposes of my question, that they elect not to have you put
on the political path of this preparatory work, this
additional kind of international pricing analysis that you're
talking about.  
     A    Well, if we assume that we're not going to do that
type of analysis, then the additional time would be a matter
of a few months, but one could make a year's study of just
price flexibility of trade issues.  It could be the basis of
a year-long study.  So. . .
     Q    So say ÄÄ I'm going to recharacterize your
testimony and tell me if you're comfortable with it or how
you would like to correct it.
               If there's substantial disagreement between the
League and the Hazen and Sawyer work, with respect to price
leveling yield and treatment of those elements, in the
twenty-year analysis, it's likely to take several months
before you're in a position to provide the price level and
yield information that Dr. Richardson would use to do the
FLIPSIM micro-farm level impact analysis.
     A    It could.
     Q    Is that a likely conservative estimate, assuming a
substantial disagreement with the treatment by Hazen and
Sawyer?
     A    Several months.
     Q    Okay.  That's fine.

                         MR. SAXE:  Let me check and see if I have any
          other. . .

BY MR. SAXE:
     Q    Actually I do have a couple of questions on this
timing.
               It just occurred to me that we set out a time frame
for the feeding of certain input data to Dr. Richardson's
work.  
               Can you give me an estimate of how long it would
take, likely take, Dr. Richardson to complete enough of the
FLIPSIM three-stage analysis to provide you with the
probability of model farm survival that you would then need
to start your aggregation and, if I understand it correctly,
approach being in a position to answer the questions about
the sources of data that you would be using and the
methodologies.
               Would you like the question read back to you?
     A    Please.

          (Thereupon, last question so read by reporter.)

BY MR. SAXE:
     Q    Let me take it piece-by-piece, so I understand your
testimony.
               We started this particular topic with my question
about when you would be ready, high likelihood ready to
answer the questions about the specific sources of data you
would be using, the assumptions and methodology, and you
indicated that there were certain steps that would likely
have to take place, the first one of which was the completion
of a certain amount of work by Dr. Richardson on his FLIPSIM
three-stage analysis, as I understood it.
     A    Yes.
     Q    And then subsequently you testified that most
likely you would be making some preparatory determination,
based on the Hazen and Sawyer analysis, of appropriate price
levels and yields and perhaps other elements, before he would
initiate that FLIPSIM three-stage analysis; is that accurate?
     A    It's approximate.
     Q    Okay.  What I'm asking now, specifically, I've got
some time frames for those pieces and one piece I need
another time frame for is the turnaround time for Dr.
Richardson on his three-stage analysis, and the estimate. . .
     A    And the estimate is that one would have to ask Dr.
Richardson.
     Q    Do you have any approximate expectation?
     A    He's a wizard and he's very productive and hard-
working, but I couldn't characterize the time it would take
him to do this.
     Q    Fine.  Thanks.
               Getting back to the aggregation process.
               After you have converted probability to the number
of acres out and then determined the value lost from those
acres out, what would be the next step in the aggregation
that would be done?
     A    Well, the sales dollars are very critical to the
application of the multipliers and so the next stage would be
to make an estimation of the direct, indirect and induced
impact on sales, on employment and on earnings, which are job
earnings.
     Q    And would there be a further step in your
aggregation work after that?
     A    Yes.
     Q    And what would that be?
     A    We feel very strongly, because of the seasonal
nature of agriculture in the EAA and because the multipliers
that are used for employment assume full time equivalent
workers that a necessary conversion to the number of jobs,
the number of people in those jobs, needs to be estimated as
well.
               So we would intend to make that determination of
not only the FTE, which is lost, but the number of jobs,
seasonal and non-seasonal, direct and indirect, which are
lost.
     Q    Okay.  How do you propose to estimate the number of
jobs from the FTEs?
     A    Well, we will, and have in some of our earlier
work, have looked at the profile of employment in the EAA and
it gives us some basis for an understanding of how many
agricultural jobs and non-agricultural jobs are really there.
               We feel we have an understanding of publicly
available data, provided by the Florida Department of Labor,
that we have a reasonable handle on the number of seasonal
workers in vegetables and the number of seasonal workers in
sugar cane, the number of foreign H-2A workers in sugar, and
so on and so forth.
     Q    What is that?  I'm sorry, I didn't ÄÄ what is that
relationship?
     A    Well, that relationship, in our view, is that the
relationship in sugar is a smaller proportion of seasonality
than the relationship in vegetables and sod.  So we
distinguish vegetables and sugar, and by sugar I mean sugar
milling, sugar growing and sugar harvesting.
               So we have developed coefficients that we utilize
to adjust the FTE values to come to some estimate of the
number of jobs and in doing so we have tried to be very
conservative in the factors that we used to make those
determinations.
     Q    How have you developed those coefficients?
     A    Again, we have developed them by looking at the
seasonal and full-time employment in the sugar, vegetable and
sod industries and that's given us some understanding of the
total number of jobs that are there.
               So the factors that we use to then make that
estimation is based on that work.
     Q    What is the publicly available data for reports
that you used?
     A    Those are in the in-season, biweekly farm labor
reports available in Belle Glade and other offices of the
Department of Labor ÄÄ Florida Department of Labor.
     Q    Are the coefficients that you have developed
documented?
     A    Documented by whom?  
     Q    When I say you, I mean in the plural sense, you
and/or Dr. Richardson or Peterson Consulting group.
               Are those coefficients recorded on paper in your
possession or Dr. Richardson's possession or Peterson's?
     A    They're in my mind.
     Q    Are they documented?  I mean, do you have them on
paper or are they on paper?
     A    They can be determined from our worksheets for
estimating ÄÄ if we go back to December 16th, when we met
with Dr. Johns and the economists for the District, and we
provided Dr. Johns ÄÄ if I recall, specifically, Dr. Johns
asked me in that meeting of economists what factors we used
and I believe my notes of that meeting reflect the fact that
I indicated that, that coefficient for sugar and that
coefficient for vegetables.
     Q    So you orally provided those coefficients?
     A    I orally provided.
     Q    Do you know the coefficients now, as we. . .
                     A    Yes.
     Q    Okay.  Can you tell me what those coefficients are?
     A    In the case of sugar, based on our study of
employment profile in the sugar industry, in the EAA, our
determination was that one full-time equivalent is equivalent
in sugar one point three and in the non-sugar or the non-
agricultural component that there is seasonality in service
and trades and others and it would be ten percent.  
               So we adjusted the full-time equivalent figure that
came out of the multiplier analysis on a factor of one point
four.
               So if the multiplier analysis in jobs lost happened
to be ten thousand jobs lost full-time equivalents in sugar,
if that's the way that determination came, based on the
multiplier, which said that for the regional multiplier there
are twenty-seven point eight jobs lost for every one million
dollars in sales lost, we use the same multiplier that Hazen
and Sawyer used, the regional multiplier, if that's the case,
and you multiply the revenue lost and get the number of jobs
lost, and we multiply that times one point four.
     Q    All right.  So you will be applying this multiplier
to the. . .
     A    We only applied that adjustment to the employment
side of this thing.  We did not make any adjustment with
respect to the revenue of the sales multipliers, nor do we
make any ÄÄ we haven't made the adjustments to the job
earnings.  We have put our concentrated effort on jobs,
because I think that's an issue, that's an important factor.
     Q    Are the employment impact numbers, that you are
multiplying these coefficients by, broken down by sugar and
non-sugar?
     A    No, because what we are ÄÄ the multiplier has in it
the twenty-seven point eight jobs per million dollars of
sales.  In the multiplier, Leontief analysis includes both
the direct, the sugar workers, and the indirect, non-sugar
workers, because it shows the inter-industry effects of what
happens when you lose dollars in sales in sugar to employment
in the local economy, agricultural and non-agricultural.
     Q    So do you apply both the sugar and non-sugar
coefficient then to the FTE employee impact numbers?
     A    Excuse me.  We applied the one point four factor to
the estimate of the Leontief estimate of jobs lost.
     Q    So that. . .
     A    Which includes the sugar and non-sugar.
     Q    Okay.  So then what is the role of the sugar
coefficient of one point three?
     A    What we're saying there is that the seasonality
impact is in sugar and not in the non-farm sector.
               What we want to characterize is the seasonal nature
of employment in sugar, by giving it a higher weight of
seasonal employment, relative to the service and trade
sector.
     Q    And yet the sugar coefficient is lower than the
non-sugar. . .
     A    Well. . .
     Q    As I understand it, the non-sugar. . .
     A    There isn't a non-sugar. . .
               The multipliers don't have a sugar and non-sugar. 
     Q    The coefficients are what we're talking about.
     A    The multiplier for sugar sector. . .
     Q    Yes.
     A    . . .SIC code. . .
     Q    Yes.
     A    . . .that SIC code has a multiplier, an employment 
multiplier.
     Q    Okay.
     A    Now, that multiplier tells you the jobs lost in
sugar and everything else, because it gives you the direct
jobs and the indirect and induced jobs that are lost.
     Q    Okay.  So when you testified earlier about a sugar
coefficient and a non-sugar coefficient, I'm not sure I'm
understanding how those relate to this one number for the
Leontief input/output analysis of direct, plus indirect, plus
induced FTE impacts.
     A    We don't have three Leontief input/output
multipliers, if that's what you're. . .
     Q    No, that's not what I'm asking.
               What is the use of this sugar coefficient?  
               Does the sugar coefficient that you said earlier
was one point three people per FTE.
     A    Yes.
     Q    . . .does that have any role in converting from FTE
impacts from the loss of sugar sales to job loss, the loss of
sugar sales?
     A    It does if we add another one-tenth to reflect this
seasonal employment and non-.  We just use the one point
four.  That's the only number we use to adjust.
     Q    Okay.  Is this work reflected in the documents that
you have produced?
     A    It is reflected in the documents we produced,
provided in connection with the backup material to the
December 16th meeting we had with Hazen and Sawyer.
     Q    How about vegetables?
     A    Well, in vegetables you have a higher level of
seasonality.  So the adjustment factor is much larger, and in
vegetables we believe, based on the data and information from
the in-season farm labor reports and so forth, that the
appropriate adjustment factor is to double, not one point
four, but to double the employment that is created and
generated out of the Leontief multiplier.
                     Q    Does the half-time job have the same value to a
family as a full-time job, if the hourly wage rates are the
same?
     A    Would you repeat the question?
     Q    Yes.  
               Does a half-time job have the same value to a
family as a full-time job, if the hourly wage rates are the
same?
     A    Restate the question in another format.
     Q    Do you understand the question?
     A    No, I don't understand the question.
     Q    Perhaps we could skip this for now.
               Just for clarification, with respect to the
vegetables.  
               The calculations would be vegetable sales dollars
times the Rims employment multiplier, times the two point
zero coefficient, equals people?
     A    That's correct.

          (Thereupon, the deposition was adjourned for the
          evening.)


                   CONTINUED IN VOLUME II