ML20154B724

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Deposition of Wg Johnson.* Depositon Taken in New York,Ny Re Emergency Planning/Emergency Broadcast Sys Issue.Supporting Documentation Encl.Related Correspondence
ML20154B724
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 03/18/1988
From: Johnson W
LONG ISLAND LIGHTING CO.
To:
References
CON-#288-6238 OL-3, NUDOCS 8805170293
Download: ML20154B724 (65)
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{{#Wiki_filter:,c e s .Ja m mssgega ORGNXi 11MSCRLF1' OF PROCEEDIX ~ s ~ DCCTEKD n l CC UNITED STATES OF A!! ERICA O N -21987 r 5, Etin bEONcit NUCLEAR REGULATORY COMMISSION p sLcy-N ac IN 8 BEFORE THE Nk'irp# ATOMIC SAFETY AND LICENSING BOARD _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.x In the !!atter of: Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY (Emergency Planning) (Shoreham Nuclear Power (EBS Issue) Station, Unit 1)

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(~N, G DEPOSITION OF WILLI A!! G. JOHNSON New York, New York Friday, March 18, 1988 ACE-FEDERAL REPORTERS, INC. Stenotyp' hyrters 444 North Capitol Senyt m() Washington, D.C. 20001 (202) 347-3700 Nationwide Coverage 800-336-6646 pg5SBBE! 8"e8$eu

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l 1150 01 01 1 GW/gw 1 UNITED STATES OF At1 ERICA 2 NUCLEAR REGULATORY C0 tit!ISSION I 3 Before the Atomic Safety and Licensing Board 4 _______________________---------x 5 In the !!atter of ) Docket No. 50-322-OL-3 6 lot 1G ISLAND LIGHTING C0!!PANY ) (Emergency Planning) 7 (Shoreham tiuclear Power Station,) (EBS Issue) 8 Unit 1) ) 9

x 10 DEPOSITION OF WILLI A!! G.

JOHNSON ,m. 11 New York, New York \\m 12 Friday, !! arch 18, 1988 13 ; Deposition of WILLI A!! G. JOHNSON, called for 14 !i examination by agreement of counsel, at the Law Offices of ) 15 l Hunton & Willaims, 100 Park Avenue, at 10:00 a.m., before i 16 i Garrett J. Walsh, Jr., a Notary Public in and for the State 17 of Virginia at Large, when were present on behalf of the 18 respective parties: 19 20 ( i 21 i ,rh ( ) 22 1 l E ACE.FEnERat REPORTERS, INC. [ 20:w.rm smionmde cmeage sm 3 ma,

1150 01 02 2 b,/Gli/gw 1 K. DENNIS SISK, Esq., ilunton & Williams, 100 Park Avenue, 2 New York, Now York, and RITA SHEFFEY, Esq, Ilunton & 3 Williams, 707 E. !!ain Street, P. O. Box 1535, Richmond, 4 Virginia, 23212, on behalf of the Applicant, Long Island 5 Lighting Company. 6 tiICHAEL 11 ILLER, Esq., Kirkpatrick & Lockhart, South Lobby, 7 18 00 ti. Stroot, N. W., Washington, D. C., 20036-5891, on 8 behalf of the Intervoner, County of Suffolk. 9 10 11 12 13 14 15 16 17 l l 18 I t f 19 i 20 l 21 f 22 ACE FEoERat REPORTERS, INC. a

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3 O i G 1i C0NTENTS l 2! WITNESS EXAMINATION William G. Johnson 3 by Mr. Miller 4 4 5 EXHI B I TS 6 JOHNSON DEPOSITION NUMBER IDENTIFIED Exhibit 1 - Poll of 600 residents of Shoreham 9 7 EPZ 8 Exhibit 2 - Survey questions 17 9 10 13 O 12 13 14 15 l 16 17 l 18 19 l 20 21 i 22 O l ace I7EDl!RAl. REPORTERS, INC, [

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l 1150 01 04 4 r~s L_)GW/gw 1 PROCEEDINGS 2 Whereupon, 3 WILLIAtt G. JOHNSON, 4 was called as a witness, and having first boon duly sworn, 5 was oxamined and testified as follows: 6 DIRECT EXAMINATION 7 BY !!R. !! ILLER: 8 0 Good morning, !!r. Johnson. !!y name is Michael 9 Miller, and I am with the Law Firm of Kirkpatrick & 10 Lock ha rt. As I think you know, we represent Suffolk County 11 in the Shoreham Licensing Proceeding befor the Nuclear 12 Regulatory Commission, and I am here to ask you some 13 questions today regarding LILCO's proposal regarding its 14 cmergency broadcast system network, which I will refer to as 15 the EBS network. 16 I understand, tir. Johnson, that you will be a 17 witness for LILCO with respect to the EBS issues in this 18 procooding, is that correct? 1 19 A That is what I understand. 20 0 Can you tell me, !!r. Johnson, approximately when 21 you learned that you would testify for LILCO? () 22 A It was -- I was retained -- it was in l ACE FEDERAL REPORTERS, INC. ( 202 m rm NanonmJe Coseuge Mn3WW6

1150 01 05 5 )GW/gw 1 September, I believo. In September I was told that I might i 2 be asked to testify. 3 0 Can you toll me when you first learned that you 4 would, in fact, testify on LILCO's behalf? 5 A Last wook. 6 Q You woro informed by counsol for LILCO, is that 7 corroct? 8 A That is correct. 9 0 Can you toll me, fir. Johnson, your understanding 10 at the present timo as to what you will testify about? 11 A I believo I will be asked to testify about the U(~s 12 survey that my firm conducted for LILCo. 13 0 This in the telephone survey that was conducted 14 lato Septembor, early October? 15 A That is correct. t 16 O At this time, !!r. Johnson, do you believe you 17 will be testifying about any other aspects of LILCO's EBS 18 Network. I 19 l A Not that I am aware of. l 20 O Would it be fair to say, tir. Johnson, that a 21 summary of your testimony that will be presented can be () 22 found by reviewing the affidavit that you filed on LILCO's I ( ACE.FEDERAt. REPORTERS, INC. t .w.m.no s.- m n m, c m u m sa, muu

1150 01 06 6 )GW/gw 1 behalf last Fall with respect to summary disposition motion 2 in this case? 3 !!R. SISK: I will object to that question as 4 calling for speculation insofar as the testimony has yet to 5 he filed. i 6 The witness can answer it based on his present 7 understanding. 8 THE WITt1ESS: I don't know. 9 BY !!R. 11 ILLER: (Continuing) l 10 0 Aro you telling me, !!r. Johnson, at this timo you 11 do not know what your testimony will bo? i 12 A I do not know how my -- I am not a lawyer, and I 13 don't know how my testimony, the form of my testimony might 14 differ from the affidavit that I signed. 15 0 !-tr. Johnson, although the form may diffor, at 16 this timo do you believe that you will substantively be 4 17 testifying about any matters not set forth in the affidavit 18 that was attached to LILCO's motion for summary disposition? i J 19 A Could you repeat that, please. I am sorry. 20 0 From a substantive standpoint, do you believe the i I j 21 matters you will be addressing in your testimony are already () 22 set forth in the affidavit that was filed on LILCO's i l \\ i ACE-FEDERAL REPORTERS, INC. L 202-34h 3?t:0 NarbriwiJe cose r,ge Kux3346,46

1150 01 07 7 (3 t_/GW/gw 1 behalf with respect to its motion for summary disposition 2 last Fall? 3 A As I understand your question, yes. 4 0 Have you met the other witnessos that will 5 testify for LILCO'on this issue? h 6 A I don't know who the other witnessos are. 7 0 Have you mot a Mr. Ralph Dippell? 8 A I don't believo so. 9 0 Do you know who Mr. Ralph Dippell is? 10 A No, I do not. 11 0 Do you know Doug Crocker? 12 A I don't believo so. 13 0 Is it fair to say, Mr. Johnson, at this timo you 14 have not drafted any of the testimony that will be filed on 15 LILCO's behalf? i' 16 j HR. SISKt I object to that as privilogod 17 information relating to matters protected by attorney-work 18 product privilogo. 19 MR. MILLER: Whether he has begun to draft his 20 testimony is privilogod? l 21 MR. SISKt I believe that is correct, Mike. I l ( 22 will allow him to answer the question without further 1 ACE-FEDERAL REroarERS, INC. ww.rw swonme co, case wmm

t 1150 01 08 8 GW/gw 't waiver of.the privilege. 2 THE WITNESS: I have not written any testimony at 3 this time, any additional teratimony at this time. 4 BY MR. MILLER: (Continuing) 5 Q Mr. Johnson, is it f air to say that. you have not 6 testified with respect to any emergency preparedness or 7 emergency planning. issues since December of 1983, when you 8 testified on LILCO's behalf on, I believe, role conflict and 9 shadow phenomenon issues? 10 MR. SISK: Is that question, Mike, confined to 11 this particular proceeding? 12 MR. MILLER: No. I would like to know if 13 Mr. Johnson has testified anywhere with respect to emergency 14 preparedness or emergency planning for a radiological 4 15 emergency? 16 THE WITNESS: I have not. 17 BY MR. MILLER: (Continuing) 18 0 Was the first time you had so testified December l \\ l 19 1983, when you testified on LILCO's behalf on role conflict 20 and shadow phonomenon issues? t 21 A In terms of -- I had submitted written testimony () 22 prior to that particular hearing, but that hearing was the f ACE-FEDERAL REPORTERS. INC. j mmmm soonwe cmune simmu

i l i i 1150 01 09-9 n (_)CW/gw I first timo I had so testified. 2 0 So, it is the'first and only timo? 3 A I believe there were soveral hearings, but they 4 were the only timos, that la correct? 5 O Soveral hearings, all with respect to the 6 Shoreham plant? 7 A That is correct. 8 0 Could you summarize for me, Mr. Johnson, the 9 conclusions that you believe can be drawn from the tolophono 10 survey that was conducted by your company last September and 11 Octobor of 19877 12 A I don't have the results of the survey in front 13 of me. If you have a copy, I could -- 14 flR. !!I LLER: I do have a copy. Let's mark this 15 as Johnson Exhibit 1. 16 (Poll of 600 residents of Shoreham EPZ is 17 marked Johnson Deposition Exhibit 18 Number 1, for identification.) 19 (Witness perusos document.) i i 20 BY t1R. tiILLER: (Continuing) l 21 0 Now, Mr. Johnson, I will represent this is a copy () 22 of Attachment 7 to LILCO's motion for summary disposition ACE FEDERAL REPORTERS, INC.

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1150 01 10 10 p/GW/gw 4 L_ 1 that was filed last November 6th. It, I believo, is a i 2 report, cursory report, of the results of the survey that 3 was performed by your company, is that correct? 4 A It appears to be so, yes. 5 0 Now, can you tell me or summarizo for me the j c o n c /. r, o n t 11 6 concalsions that you believo can be drawn from this survey?M/ 7 A I think if I can just quote from my highlights, 8 98 percent of those that we interviewed stated they had at 9 least one radio in their home at the time that they were I i 10 interviewed. 11 There was a mean of 3.3 radios per household. 97 12 percent of all respondants, which means 99 percent of those 13 with radios, indicated they have at least one AM/FM or FM 14 only radio. 15 75 percent of those interviewed stated that they 16 have an AM/FM or FM only radio that can be operated by 17 battery. 92 percent of all households stated they have at 18 least one automobile equipped with an AM/FM or FM only l 19 radio, and 17 percent of those interviewed stated they are i 20 planning to buy an AM/FM or FM only radio within six months 21 from the time that the interviewing took place. () 22 0 Mr. Johnson, can you tell me why you asked the Act FEDERAL REPORTERS. INC. L

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Il l 1150 01 11 11 (3 Q GW/gw 1 question regarding the percentage of radios that could be 2 operated by battery? t 3 A When I was retained by Hunton & Williams, acting 4 I believe on behalf of LILCO, it was mentioned that one of 5 the things that LILCO wanted to find out was how many radios 6 could be operated by battery, and that was why I included 7 that question. 8 0 It has boon about six months, Mr. Johnson, since 9 your survey was performed. Have you dono anything to 10 determine whether the 17 percent of those interviewed that 11 were planning at that time to buy an AM/FM or FM only radio 12 have, in fact, dono so? 13 A No, I havo not. 14 O Mr. Johnson, first page of Johnson Exhibit 1, 15 under methodology, it states that the responses were key 16 punched and 100 percent verified. 17 Can you tell me what it means to say, "those responses were 100 percent verifiod?" 18 19 A It means that after they were key punched once 20 onto cards, another key punch operator in effect key punched 21 them again. It was done with a key punch machino, with e i i 32 verifying machine. ACE I'EDERAL REPORTERS, INC. [

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l1150 01'1'2 I 1 12 b_/ /gw-1 -Q A number of the questions asked in your survey, GW 2 Mr. Johnson, sought information.from the'respondants to the 3 best'of their ability based upon their memories. ~ 4 I,believe that is a fair statement. :Do you 5 ' agree? -6 A Based upon their perceived knowledge at the time, 7 yes. 8 O For example, when respondants were-asked to the 9 best of their ability how many AM or FM radios they owned, 10 you relied upon those persons memories as they were talking r~s 11 on the telephone with your people, is that correct? (_) 12 A Actually, they weren't asked the question in that 13 way. They were asked, if I might quote, "How many radios'do 14 you and your family have in your home, or don't you.have any 15 radios at the present time?" 16 O That is'one of a number of questions that were 17 asked? 18 A That is correct. 19 O And, for example, when -- well, the next question 20 from what you remember, how many of these radios are both AJ 21 and FM, I guess obviously you were asking people based upon I 22 their memory at the time of the interview or the survey, ACE FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 800-336-(M6

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what they could recall about the radios they owned? 2 A That is correct. 3 0 It is fair to say, Mr. Johnson, that the 4 verification process ' referred'to under the Methodolcgy 5 section of Exhibit'l has nothing to do with attempting to 6 verify the accuracy of the answers given to your company, is ~ 7 that correct? 8 A That is correct. 9 0 Can yor explain to me what it means to say that ecc-10 the margin of error's the 95 percent confidence leval for 2d)/ 11 the responses is about plus ot-minus two an6 one half 12 percent? 13 A Yes. The margin of error, or sampling error, in 14 this cass is plus or minus two and a half percent, meaning' 15 that if instea'd of interviewing a sample of the households 16 within the ten mile EPZ we had interviewed overy household t 17 with a telephone within the EPZ, 19 times out of 20, or 95 18 times out of 100, the answers we would have gotten from i 13 interviewing everybody would not have differed from the 20 answers we got by interviewing this particular sample by 21 more than plus or minus two and a half percent. ( 22 0 Mr. Johnson, Exhibit 1 does set forth the /\\CE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coserage 800 3364M6

=. ~..-- = T l11'50'01 14 14 . GW/gw-1 questions'that:were asked in the' survey. That is the second 2 page of the exhibit, is-that correct? 3 A Correct. 4 0 And then beginning on Page.3 to'the end of the S.

exhibit, I' gather these are the results from the various

-6 questions that were asked, is that correct? 7 A Yes. Actually, my pares aren't numbered, but the-8 third page are the results, yes. f t 9 0 And that is the page that has Table 1 up in the ~ 10 upper right hand cornsr? 11 A That is correct. 12 O Just let me ask you some questions about this 13 third page, Table 1, just so I can make sure I understand 14 what these results signify. 15 Obviously, you have a total of 600. .That is the 16 number of households that were surveyed, correct? 17 A That is correct. 18 0 Now, this first question, how many radios do you 19 and your family have in your home, or don't you have any r a 20 radios at the resent time, the results indicate that 13 21 households told you none? () 22 A That is correct. 1 /\\CE FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage fo n - 46 .--,__-,,,,,,,.,_-,.,,,n,, ,,,,-,,,,.,_,,n__._.,_,.,_,_n_,,

1150 01115 15 f'/GW/gw 'i (_ 1 0 An'd does that mean that is 2 percent of the 2 sample size? -3 A That is correct. 4 0 The numbers 11 and 12.and don't know, you.have 5 numbers and then underneath the numbers.the letter N.- Can 6 you tell me what that means? 7 A Actually, I believe that is an asterisk, and it 8 just means that the percentage was less than 1 percent. 9 0 okay. 'Now, on the next page, Mr. Johnson, the 10 same question is presented, but this gives you, I suppose, 11 some further data about the results of.that question, 12 correct? 13 A That is correct. 14 Q And you indicate, for example, in response n 15 thin first question about how many radios are owned, the 16 mean was 3.3 radios? 17 A That is correct. .i 18 0 Standard deviation, 2.04. Is that a percentage? i-19 A That 2.04 is a percentage yes, as I remember. 20 0 Can you explain to me what that means? l 21 A It means that 95 times -- I believe what it ) 22 means, and I haven't taken statistics in quite a few years, i-j ace. FEDERAL REPORTERS, INC. 202-347-37C0 Nationwide Cosetare 8(G 336-eM6 ...-.,_- - _...-._...,. -... _...~,......., _. _ _,...... _ -. _. _,....,,...._. -._, _...,-- _,

11'5'0 ' ~ 01 16 16 ',w)GW/gw 1 it means that 95 times out of 100, if we had asked everybody 2 that question -- I don't know what it means there. 3 0; The next column, I gather that is standard error?- 4 A I believe so, yes'. 5 0 Can you tell me what the number.083 means? 6 A Other than it b'eing a standard error' I cannot. 7-0 Could you explain to me what the term, "Standard-8 Error," means? 9 A I do not recall what it means. .10 Q Mr. Johnson, lets skip over to Table 3, which is s 11 the results of the question: "How many of these radios can be k((sY[d by battery?" Y 12 13 Again, you indicate that 600 is the total number 14 of households that were surveyed. Now, for None, I assume 15 this would indicate that 123 households said none could be 16 operated by battery, which is 21 percent? 17 A That is correct. 18 0 If you will go to Table 4, Mr. Johson, "How many 19 of these radios are just A!!?" is the question that was posed 20 to the respondants. 21 565 of the 600 persons surveyed respondeu None, f) 22 correct, which is 94 percent? f /\\CE FEDERAL REPORTERS, INC, 202 347-3700 Nationwide Coserage 800-3%6M6 . -... _ _ -. _ _. _. _.... _.. -... - _. - - _ _ _. ~. _, _. _ _

1150-01 17-17 7 _/GW/gw. 1 A Actually, we asked howlmany -- for people who L 2 said they had an AM/FM radio, we asked those people how many 3 can be operated by battery. That is Question 3. 4 We asked for people who said they had radios, we 5 first asked how many are AM/FM radios, and'if they.had said: ~ 6 "I have six radi , and they are all AM/FM," then they would 7 not have been asked that particular question. 8 MR. MILLER: Mr. Johnson, maybe this will help. 9 -Let's mark as Johnson Exhibit 2 what I understand to be a 10 copy of the survey questions that were used in your 11 Company's survey. 12 (Survey Questions is marked as Johnson 13 Deposition Exhibit Number 2, for 14 Identification.) 15 BY HR. MILLER: (Continuing) 16 0 Can you tell me, Mr. Johnson, is this, in fact, a 17 copy of the questions used by your company? 18_ A It appears to be, yes. 19 0 Can I fairly assume that the order of the 20 questions is as presented on Exhibit 27 21 A Yes. () 22 0 Mr. Johnson, the first question then was: "How ACE-FEDERAL REPORTERS, INC, 202-347 3?R) Nationwide Coserage Mr>3.16W46 1.

m 1150'02'01 18 , y)GW/gw-d._ 1 many radios are owned-by the family?" correct? 2 'A Actually, it was, "How many radios do you and 3 your family have in your home?", I guess. 4 O Okay. -Maybe-I shouldn't paraphrase. I was just -5 trying to do that. And then I assume the next question-6 'would be, "From what you remember, how many of-these radios 7 are both AM and FM?" 8 A That is correct. 9 0 And then the question was asked -- 10 'A That is if they indicated they did have radios-in 11 their home. (7)) - 12 0 Correct. And if they indicated they did not have 13 any radios, then you skipped down to Question 2 of Exhibit 14 2? 15 A That is correct. 16-0 And then after asking, "How many radios are both 17 AM and FM?", then the next question was, "How many of these 18' radios can be operated by battery? 19 A If they indicated they had an AM/FM radio, yes. resp a ~4e nz 20 0 If a resMndant indicated that he or she only had Jg'/ 21 an AM radio, was that question asked about the battery () 22 operation? ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Cmerage MO 336-6M6 .~..-, _.

1150 02 02 19 kjGW/gw 1 A Yes, it was. 2 0 So, under what circumstances then was the 3 question on battery operation not asked? Only if they 4 indicated they had no radio? 5 A That is correct. 6 O Mr. Johnson, further down in the questions, 7 beginning with Question 2, "Do you and your f amily own any 8 automobiles?", can you tell me the purpose for asking the 9 questions in your survey regarding automobiles, and radios 10 in automobiles? 11 A Once again, it was a question requested by the g-) ai 12 attorneys for LILCO. 13 0 Your survey results indicate that approximately 14 three percent of the households you surveyed do not have 15 access to an FM or an AM/FM radio, is that correct? 16 A Could I -- 17 0 Sure. It is not a memory test. 18 (Witness peruses document.) 19 0 (Continuing) I think the first page of Exhibit 1 1 20 may -- 21 A I don't know if it necessarily states that. It t,) 22 states that 97 percent have access to an A!!/FM radio in I ace FEDERAt. REPORTERS, INC. 202-347-3700 Nationwide Coserage 8N-336-%46 i

4 1150iO2 03-20- )GW/gw II their home. There are people who presumably have an AM/FM' 2 radio'in-their automobile. 3 0 That is where I'was going with'my question.- Did 4 your survey' attempt to correlate in any way those persons. 5 without AM/FM.or FM radios in their homes, and those persons ~ 6 without such radios in their automobiles?- 7 A No, it did not. 8 0 Is it possible,.Mr. Johnson that, therefore, .9 roughly 10 percent, or 11 percent, of the respondants to 10 .your survey ldo not have access to un AM/FM or.FM radio? 1 11 What Save done there, is I have taken-the 8 percent that 12 do not. ave such radio in their automobile, and the 3 13 percent that do not have such radios in their homes? 14 A Can you repeat that, please? 15 0 Is it fair to say that it is possible that l 16 approximately 11 percent of the population surveyed by your 17 Company do not have access to an AM/FM or FM radio in either 18 their homes or their cars? 19 A No, it is not. l 20 0 can you tell me why it is not fair to mako that l 21 statement? () 22 A Because 97 percent have at least an AM/FM or FM i l ACEJFEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coterage 8 % 3364446 .....,., -.. -..,, -..,,. - ~ - -,. -.. - - -, - - -. - - - -.. - - - -,

9 J L1150E02'04' 21 r . b)GW/gw 1 .only radio in their home. 2 0 okay. 3 A If we hypothesize,'we can hypothesize that 92 4 percent of 3 percent, or 2.7 percent quite possibly have an 5 A!!/Fli or Ffi only radio. in their car, so that conceivably 100 6 percent have an Ati/FM, or Pfl -- have access to an AM/FM.or Pfi 7 only radio either in their home or in their car. 8 0 Okay. So, I guess they answer is, though, that 9-based upon your survey we just~really can't tell that. - 10 There was no such correlation done? 11 A Up to this time there has not been, that, is 12 correct. 13 0 .Do you intend to pursue that in a further-survey? 14 A I have not-been asked to conduct another survey. 15 0 Based upon your survey, Mr. Johnson, can we draw 16 any conclusions about those persons that do not own sny 17 radios and those persons that do not own an automobile? 18 A Based on the analysis that has been done to date, 19 we cannot. 20 0 Are you suggesting, Mr. Johnson, that it would be 21 possible to somehow analyze in additional detail the results f 22 of your survey from last Fall to ascertain that matter? ACE FEDERAL REPORTERS, INC, j 202 347 3700 Nationwide Coserage 800 3E6646

4 w .1150 02 05 22' GW/gw 1 A It is possible, yes. 2 O How would that be done?.How could that be-done? 3 A If my~ client requested me to have it done, I 4 could. arrange to have it done. 5 0 Are you talking about then having to conduct.an 6 additional survey or could you take the results of last 7 -Fall's survey and ascertain that information? 8 A We could take the results from laat Fall's survey 9 and ascertain that information. 10 0 And how could that be done? 11 A If I was requested to do so by my client. . O. 12 O No. I am asking you how, in fact, one would go 13 about using the survey results that are presented in Exhibit 14 1, to ascertain information regarding ownership of 15 automobiles and ownership of radios?^ 16 A One could tabulate the results. One could run a 17 table of the results, filtering out those with automobiles 18 and those without automibiles, and those with radios, AM/FM 19 radios, and those without AM/FM radios. 20 0 I see. I gather from your response, 21 Mr. Johnson, that what I will characterize as the raw data, 1 () 22 the completed actual survey forms ars still in existence, I /\\CE. FEDERAL REPORTERS, INC. i 202 347 3700 Nationwide Coserage 800 336-(M6 '

1150 02 06 23 GW/gw ~1 and you would need to go back to those forms? 2 A No. This was all key punched, and it would' 3 . require calling. CRC Information Systems, and saying: PRun i 4 Question 1 on Question 2, run Question 2 on Question 1, 5 filtering out those -- filtering just those who do not have 6 an AM/FM or Fli only radio." 7-It would be a very simply procedure. 8 0 In fact, does the raw data or the completed 9 survey forms, do they, in fact, still oxist? 10 A Yes, they do. 11 0 Is there any way, Mr. Johnson, to take the O' ~i 12 existing survey results to determine the percentage of the 13 EPZ population that own only AM radios, or have no radios? 14 A Yes. I 15 0 Have you, in fact, done that? 16 A No, I have not. 17 0 Is it possible for you, looking at the results of 18 these surveys today, to give me an answer to that question? 19 My question would be: "Can-you tell me approximately the 20 percentage of the EPZ population, based upon your survey, 21 that would have either only AM radio or no radio?" 22 A Not looking at these results. It would ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coserage MO-336-6M6

1150 02 07 24 /"N IL_)GW/gw l 'obviously be three. percent or less. 2-0 Why'do you say it would obviously be.3 percent or 4 3 less, Mr. Johnson? 4 A As I understand your question,.your' question was 5 "How many of the respondants have'only-an.AM radio,oor have' 6' no. radio at all?", and 97 percent of the'respondants have at 7 least one AM/FM or FM only radio. 8 So, that by definition, 3 percent or less would 9 fall into that category that you are suggesting. 10 0 Although, of course, there is the margin of error 11 is going to oe out there of two and a half percent one way 12 or the other? 13 A Yes. I was referring to the survey results. 14 0 Mr. Johnson, in your survey did you attempt to 15 make any determinations or draw any conclusions regarding 16 persons who listened to AM versus FM, or FM versus AM? 17 In other words, issues as to what -- even if a 18 person has an AM/FM radio -- what that person tends to 19 listen to in terms of AM band or FM band? 20 A No, we did not. 21 0 Is there any way to take the existing survey () 22 results and make that sort of determination? ACE FEDERAL REPORTERS, INC. j 202-347 3700 Nationwide Coserage MG3364646 .. - -. -,. _. - - -.. ~.. _ -.

/ ~1150 02 08 25 /'S -(_jGW/gw 1 A No. 2 0 Is it fair to say that that sortlof determination 3-would, in fact, require an additional survey?. 4 A One way of doing it would be an additional-5 survey, that is correct. I 6 0 .How else could it be done? 7 A I don't know how minutely the radio rating. 8 services have their geographic areas on Long Island,'but it' 9 is possible + anArbitroha$ingservicecouldcomeup 10 with some numbers, but I am not aware of any. 11 0 I gather from your answer you are familiar with-12 Arbitron rating service? 13 A By name, yes. 14 0 Do you consider Arbitron reliable source.of 15 information regarding listenership? 16 A I am not qualified to answer that. 17 0 Mr. Johnson, were any surveys contemplated but 18 not commenced by your company? 19 A Are you referring to my relationship with Hunton 20 & Williams and LILCO in general? 21 0 No. I am talking about this proceeding. I am () 22 sure that over the years you have contemplated some surveys ACE FEDERAL REPORTERS,.'NC. 202 347 3700 Nationwide Coserage MO-336-(M6

J 1150 02 09 26- ., \\. -L jGW/gw- .1 that were not commenced. 2 A I am afraid to say.so, yes. But in the case of 3 this situation, this matter under discussion, I am not aware 4' of any surveys 'that were contemplated but were not 5 commenced. 6 Q Are you aware of any that were commenced but not 7 completed? 8 A No, I am not. F ~ 9 0 .Was any pretesting done before your survey was 10 conducted? 11 A No, it was not. .12 0 Was consideration given to conducting. pretesting 13. beforehand? 14 A No. 15 O Mr. Johnson, based upon your survey results, if I 16 were to ask you in your opinion the worst case in terms of 17 the percentage of population that would not have access to 18 AM/FM or FM radios, it would appear that'we would be 19 focusing upon persons while ther are in their cars, is that 20 correct? 21 A I am sorry. Could you repeat that question? 22 O If I were to ask you what would be the worst i ACE FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coserage KO-336-6/.46 l

y I150'02'10' 27 -G k /GW/gw I case in terms of the higher-number.of. persons that would not 2 have access to AM/Ft1 or FM radio, we would be focusing on 3 persons in their automobiles, is that correct?- 4 A If I am understanding your question correctly, 8 5 percent of the people in automobiles, according to our 6 survey, would not have access to an A!!/FM or FM only radio.- 7 0 Whereas only 3 percent if those persons were in 8 their homes? 9 A That is correct. Now, I am sorry, but I would 10 like to clarify my answer. '8 percent would not have access 11 to an Afi/FM'or_FM only radio that was equipped in the 12 -automobile. It is possible they would have access to a 13 portable AM/FM, or FM only radio that they had on them in 14 the car. 15 0 That they would carry with them in the 16 automobile? 17 A That is right. 18 O Mr. Johnson, in terms of trying to get some 19 numbers in my head, if we assume that the EPZ population is 20 approximately 160,000 persons, is it fair to say that 8 21 percent of the population as surveyed by your company would l: () 22 be roughly 8 percent of 160,000 persons? l l l /\\CE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coserage 800-336H46 ~. _ -....., _ - - - -. - ~ - _ _ -. . -, -.,., - >. ~. _ -. - -. -. -. _.. -, -., - -. -.. _ - _

1150 02 11 28 7!_jGW/gw 1 A No, it is not. 2 0 Is it impossible to reach any conclusions about 3 the numbers of persons that could be without AM/FM or FM 4 radios based upon your survey results? 5 A It is possible, yes. 6 Q How would you do that? 7 A We sampled households. We didn't sample 8 individuals. If you could tell me how many households -- if 9 one knew how many households there were in the SPZ, one 10 could make projections as to how many households for <~s 11 whatever one wanted to project. ..] 12 0 To reach any conclusion about the number of 13 persons without AM/FM or FM radios, would one have to 14 conduct another survey? 15 A No. 16 0 okay. Would one simply ascertain the data 17 reguarding number of households within the SPZ and then use 18 your percentages from your survey results to determine the 19 number of persons without radios? 20 A One could do that, yes. 21 0 Mr. Johnson, the survey you conducted was a n j () 22 random sampling survey, is that correct? I i ACE FEDERAL REPORTERS, INC. 202 347 37(O Nationwide Coserage Kn33fr646

li., i l'150LO2112 29 )W/gw 1 A It.was'a random' survey,;yes.- 2 0 A statistically valid random-sample was taken? i3 A That is-correct. L4 0 Is it fair-to'say the persons. surveyed were, .5-therefore, evenly distributed throughout the EPZ in terms of T 6 their residences? 7 A The persons surveyed were distributed across -the 8, EPZ in proportion to'the number of people living in the 9 various zones within the EPZ. 10. I believe there are 19 zones-within the EPZ, I 11 geographic zones. I .g$^ '\\ / 12 0 So, fir. Johnson, is it fair to say that'those '13 zones with a higher population, more inquiries were madeoto 14 the respondants in that zone than~to the less populated 15 zones? 16 A That is correct. That is what I was trying to 17 say. 18 0 It would be true that there were questions asked 19 of some persons, though, from each and every EPZ zone, is 20 that correct? f i 21 A Yes. Each EPZ zone that had households. I am j .() l 22 not aware of an EPZ zone without a household. ACE FEDERAL REPORTERS, INC, 202 347 3700 Nationwide Coserage NW646 L

u-4 h150f02'13 -30 fi.-$ L_/GW/gw 'l 0-Was any weighting done of the survey results? 2 A No weighting was done of' the survey results. J 0 Was. consideration 'given to weighting the-results? .4 'A No. .Never. ~5: 0-Were any persons outside the.EPZ surveyed? I 6 !! Ji To the best of my knowledge, no. It is always 7 theoretically possible in something like this that somebody 8 inadvertently dialed a wrong telephone number. 9 0 Was consideration given to' surveying' persons 10 outside the EPZ? 11 A No. (n)- 12 0 Did your survey attempt to compile any economic 13 data regarding the respondants? 4 14 A Mo, it did not. 15 0 Did you gather any sociological data regarding i 16 the respondants at all? 17 A No, we did not. 18 O Mr. Johnson, I gather from the results of the 19 survey, as I read them on Exhibit 1, it was not attempted to 20 determine whether all radios that were owned, whether AM or 21 FM, or AM/FM were in f act in working order, or could be () 22 heard well, or anything of that aature? It was simply a ace-FEDERAL REPORTERS, INC. 202 347 3XO Nationwide Coserage F00-336-(M6 3

1150 02 14 31 s t_.)GW/gw 1 question of how many radios do you own? 2 A That is correct. 3 0 Do you have any information regarding the numbers 4 of persons within the EPZ that have their radios hooked or 5 connected to the rooftop antenna? 6 A No, I do not. 7 0 Are you aware of iny information regarding the 8 typical orientation of antennas within the EPZ, or Long 9 Island? 10 A No, I am not. <w 11 0 Mr. Johnson, have you ever surveyed any other ( ), 12 population with respect to radio ownership, or the 13 listenership habits of the population? Radio listenership 14 habits? 15 A Yes. 16 0 Could you generally describe for me that survey, 17 or surveys? I don't really need the client name. 18 A I have done a considerable number of surveys for 19 various clients where we attempted to ascertain which radio i 20 stations, various sample type populations listen to, and 21 when they listen to these stations. l (s,) 22 0 These were surveys done for the radio stations? l i; ACE FEDERAL REPORTERS, INC. [ 02-347 3?m Nationwide cmerage 8m-336 6u6

.1150'02 15 32 GW/gw 1 A No. These were done for-spe'cific clients. 2 0 Clients that were'considering whether to 3 advertise with certain stations? 4 A That is correct. 5 0 can you draw any general conclusions regarding: 6 listenership habits with. respect to-AM versus FM of the 7 general population based:upon the surveys you have conducted ~ '8 in the past? 9 A There are none that come to mind right now. 10 0 Are you aware of any other information regarding 11 listenership habits of. general population with respect to AM . _O. 12 versus FM? 13 A No, I not. 14 0 Mr. Johnson, were any steps taken in your survey 15 to ensure that a household was not telephoned more than i; 16 once? 17 A Yes. 18 0 What were those steps? 19 A When the sample was developed, it was developed, 20 as I believe it is indicated here, on an every nth basis l 21 within the various geographic areas in the EP2. 1 () 22 As I recall, the listing was by household so l ACE-FEDERAL REPORTERS, INC. [ 202 347 3700 Nationwide Coserage 80M36-646

1150 02-16 33 (~ fy_)jGW/gw 1 that we would take the first household in a particular 2 geographic area, and then the ninch household,-and the 18th-3 household, and the 27th household, or whatever the' interval 4 was determined to be for each geographic area. 5 So, in that way it would have been very ~ 6 dif ficult for the same household to have been included twice 7 in the survey. 8 0 Mr. Johnson, at this time do you have any plans 9 to do any additional work with respect to these EBS issues 10 other than, of course, to prepare your testimony that will 11 be presented at trial? --bg 12 A At this time I do not. 13 0 If I were to request the completed survey forms, 14 Mr. Johnson, approximately how much paper are we talking 15 about? 16 A Approximately 600 sheets of paper this size. 17 0 600 sheets that would look like Exhibit 2, but 18 filled in? 19 A Yeah, and it would be blue instead of white i j. 20 colored. 21 0 Have you done any surveys that involved any of () 22 the stations within LILCO's present EBS network? t ace FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coserage M433MM6 (. ..-,.,,--,.n,-.,-.--,-,..-

.~ 4 1 1150 02 17- . 34 ,tQ D GW/gw 1 .A Yes. 2 0 Are you at this time aware of.the1 ten stations 3 that-are at issue in this proceeding?- 4 A No, I am not, but -- I am sorry, I said yes 5 because -- my answer stands, yes, I have. 6 0 Can you tell me what stations or stations you 7 have done work for? 8 A I have not done any work for specific stations. 9 0 Is this work again that you have done for 10 potential advertisers of the stations involved? 11 A That is correct. 12 0 And I gather, !!r. Johnson, based upon'this past l' 13 work you drew some conclusions about the percentage of the i 14 population that, in fact, listen to the stations? 3 15 A Yes. 16 0 Was the population at issue in the surveys any h 17 portion of the population around the Shoreham plant, the 18 EPZ? 19 l A Quite possibly. I 20 0 Can you tell me how many stations of the ten C 21 stations in LILCO's network you have done work that involved () 22 these issues of listenership of the public? t t /\\CE. FEDERAL REPORTERS, INC. l 20: 347-3No Nationwide Coserage MO 33MM6

1150 03 01 35 tJGW/gw 1 A I don't know the ten stations. I have conducted 2 several surveys in Suffolk County, and the surrounding area 3 _asking about radio listenership, and I would assume that the 4 ' stations that you refer to were stations that were mentioned 5 by respondants. 6 0 If I gave you the listing of the ten radio 7 stations, would you be able to tell me whether any, in fact, 8 have been involved in your past surveys? 9 A Not right now, no. 10 0 Do you know if WPLR, which is an Fil Station based r 11 in New Haven, Connecticut, is a station tnat you have done 12 any work for in the past, or whether it has been involved in 13 any surveys you have conducted in the past? 14 A As I said, I have not done any work for WPLR. In 15 regard to certain potential advertisers of radio stations in 16 Su f folk County, I have asked some questions and they might 17 have been included, or they might not have been included in I 18 l the responses. 19 Q So, I gather, Mr. Johnson, what you have done in 20 the past with respect to certain businesses within Suffolk 21 County, you have gone out and polled or surveyed the () 22 population about which radio stations they generally listen ACE FEDERAL REPORTERS, INC. 202 347 37m Nationwide Coserage MO-336H46

i ~ 1150 03 02 36 ~(~/GW/gw L_ 1 to so'that those businesses,'your clients, can make better 2. ' determinations about whether to advertise with certain t 3 stations? 4 'A In this case they weren't buainesses, but yes, 5 so my clients could make. determinations. 6 0 About whether to advertise or not? 7 A That is right. 8 0 How many surveys do you believe in the past you 9 have conducted that involved the stations that are at issue 10 in this proceeding? 11 A I don't know which stations are at issue, but .O 12 over the past few years I have conducted at least two 13 surveys of radio listening on Long. Island. 14 0 'Would those surveys, Mr. Johnson, provide any 15 insight into whether persons genera 11y' listened to AM versus 16 FM? 17 A I don't believe so. 18 0 Well, let me just present a hypothetical to you. 19 If the results of your survey showed that 43 percent of 20 those surveyed listened to various stations that are AM only 21 stations, wouldn't that give you some insight into the fact () 22 that that segment of the population listened to AM? l ACE. FEDERAL REPORTERS, INC. 'o2-347-3700 Nationwide coserase Mo-336-6N6 ._m.-__, .-.r-,.- .-..,__..m,- _, _ _ _...,. _, _, _ _.. - -.., _ _. _ _ -. ~,. _ _ _ -. _. - - -

1150-03 03-37 ( GW/gw 1 A If-the questions were asked in such a way to 2 ascertain that answer, yes. 3 }iy questions were not asked i'n.a fashion-that 4 wou!d ascertain that particular answer. 5 0 Are your' questions more in terms of: Do you i 6 listen to particular stations? ~ My quections are generally which stations do you 7-A 8-usually listen to for the news. Questions along that line. 9 Q How extensive is the data that has been compiled 10 with respect to these two surveys? How much paper are we 11 talking about? 'I 12 A Fifteen times 1,200 -- 18,000, and 12 times 1,000 13 - 12,000. 14 0 Too much paper. What about the results? Have 15 those results been compiled? I assume they have been. 16 A Yes, they have. 17 O And I am assuming that the results of the survey 18 group we are discussing would be relatively few number of 19 pages? 20 A Yes. P 21 Q And is it fair to say that the results from these () 22 surveys would generally tell you within Suffolk County i c /(CE. FEDERAL REPORTERS INC, [ 202 347 370) Nationwide ccnerase Mo33HM6 ,.._.--._.-_,,.,m,

1150 03 04 38 k,jGW/gw I which stations are listened to for the news, which stations 2 are listened to for sporting events, which stations are 3 listened to for music listening pleasure, et cetera? 4 A No. 5 0 Could you describe the results of the surveys, 6 and how those results would be presented? 7 A Well, first of all, the sample that we are 8 sampling in this case are registered voters who are not -- 9 residents are not necessarily registered voters. 10 So, I would not draw any conclusions about the 11 population at large in Suf folk County on the basis of these 73V 12 results. 13 0 Have you done any surveys in the past, 14 Mr. Johnson, that you believe could be used to draw 15 conclusions about the general population within Suffolk 16 County or the EPZ? 17 A Yes. 18 Q And those surveys involved in some way radio f stations on Long 19 Island? i 20, A tio. l 21 O Okay. With respect to surveys that you have ()' 22 conducted in the past that you believe could be used to l 1 ACE. FEDERAL REPORTERS, INC. [

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1150 03 05 39 L_jGW/gw 1 draw general conclusions about the general population within 2 the EPZ or Suf folk County, have any involved radio stations 3 or issues regarding listan?rship habits of the general 4 population? Listeners:<io nabits with respect to radio 5 stations? 6 A Not that I can recall. 7 0 So, the surveys. you have conducted in the past 8 have involved, I gather, political candidates and their 9 desire to ascertain where they should put their campaign 10 funds in terms of getting the message across to the public? g~s 11 A That is some of it. I also do work for the New b 12 York Powe r Au thority, and obviously they weren't concerned 13 about political candidates. 14 0 The survey for the New York Power Authority, did 15 that involve in any way the Shoreham plant. 16 A I have done a survey for the New York Power 17 Authority where Shoreham was mentioned. 18 0 Can you tell me the context in which Shoreham 19 was mentioned? 20 A This was part of a statewide survei that was 21 conducted for the power authority, I believe, in 1980 or ( )/ 22 '81. ace-FEDERAL REPORTERS, INC. L

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<y . g c.. L' A t .' o N1500306: '40 A . lsGW/gw 1 'O Did it involve in any way the radio stations in 2 or around the Shoreham. EPZ? 3 A I don't believe'it did. i 4 MR.. MILLER: I don t believe I-have any further-5 questions, Mr. Johnson.- I thank' you for your time. i: 6 THE WITNESS: Thank.you. 7 MR. SISK: Okay. Very well. 8 (Whereupon, the taking of the deposition i 9 concluded at 11:00 a.m., this same day.) 10 - - - - - ~ ~ ~ ~ e 11 WILLIAM G. JOHNSON O i ci & %

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1150 03 07 41 g L_/GW/gw 1 CERTIFICATE OF NOTARY PUBLIC t 2 I, Garrett J. Walsh, Jr., the officer before whom 3. the foregoing deposition was taken, do hereby certify that 4 the witness whose tstimony appears in the foregoing 5 deposition was duly sworn by me; that the testimony of said 6 witness was taken by me and thereafter reduced to 7 typewriting by me or under m' direction, that sa!d 8 deposition is a true record of the testimony given by the 9 witness; that I am neither counsel for, related to nor 10 employed by any of the parties to the,oion in which this 7-s 11 deposition was taken; and further, tha a not a relative Lb 12 or employee of any attorney or counsel employed by the 13 parties hereto, nor financially or otherwise interested in 14 the outcome of the action. 15 16 GARRETT J. WALSH, JR. I 17 Notary Public in and for the 18 Commonwealth of Virginia at La):g e 19 l tly Commission expires: January 9, 1989 20 2L ) t 22 ACE FEDERAL. REPORTERS, INC. l

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'o Attcchment 7 Raport on e Poll of 600 Resid9nts of tho Shortham EPZ pgj

DEPOSITK)N ^

[ EXHIBIT (v) Methodology M _ / A total of 600 randomly selected heads of households within, the 10 mile EPZ around Shoreham were interviewed by telephone between September 30, 1987 and October 4, 1987. The sample was selected on an every nth basis from lists of all residents with home telephone numbers living within the EPZ. Interviewing was conducted by' Mktg., Inc., a nationally recognized survey research interviewing firm with headquarters in East Islip, New York. Responses were key-punched, 100% verified, and tabulated by CRC Information Systems, Inc. of New York, New York. A copy of the computer tabulations is enclosed. i The margin of error (at the 95% confidence level) for the responses is about + 23%. fighlights 98% of those interviewed have at least one radio in their home at the present time. There is a mean of 3.30. radios per household. 97% of all respondents (99% of those with radios) have at least one AM/FM or FM only radio. 75% of those interviewed have an AM/FM or FM o,nly radio that can be operated by battery. 92% of all households have at least one automobile equipped with an AM/FM or FM only radio. /x k-) 17% of those interviewed are planning to buy an AM/FM or FM only radio within the next six months.

car 9AICH RESEARQl, IHC. EPZ RADIO STUDY TABLE TABLE TITLE FILTER: 1 0.1 IOU #1ANY RADIOS 00 YOU NO YOUR FAffILY HME IN YOUR ltEE. OR DON'T YOU ltWE ANY RADIOS AT TIE PRESENT TIfE7 2 4.1 FR0f1 LeMT YOU RDEFSER, 500 PMNY OF TIE 9E RADIOS ARE BOTH Aff 40 Fit? 3 4.150011ANY OF TIEE RADIOS CAN 8C OPERATED BY BATTERY 7 4 0.1500 FMMY OF TIESE RADIOS ARE JUST Aff? 5 0.1 MO IOU f1ANY OF 1rEBE CAN BE OPERATED BY BATTERY 7 4 4.1 MO SOU fMMY OF YOlR RADIOS ARE JJST Flf? 7 4.1 MO 90U PMMY OF 1)E9E CAN BE OPERATED BY 3ATTERY7 8 4.1 TOTAL IICIODEE F OLMIlc AN Frt RADIO 9 e.2 DO YOU #6 YOUR FATTILY OuH ANY AUT0f10BILEB7 10 9.2100 f1ANY OF TIEBE IWWE CAR RADIOS 7 11 4.2 IOU F1ANY OF T}ESE CAR RADIOS ARE BOTH Art Ale Flf? 12 4.2 NG HOU FMNY ARE JUST Flf? 13 0.3 00 YOU THIM YOU OR YDLR FAf1ILY UILL DE BUYDC EIT)ER AN Aft /FH OR AH Ft1 Olt Y RADIO DURDC TIE TEXT SIX 110NTHS OR S07 14 9.3 00 YOU THDOC YOU OR YOUR FAl1ILY UILL BE BUYING EITTER AN Art /Fil OR Mi Ft1 00 NOT HAVE NO Art /FT1 OR FFt-OlLY RADIO ONLY RM)IO DLRDC TIE TEXT SIX F10NTHS OR 807 l 1 0 0 9

,I-I C M AIGN RESEAROf, INC. EPZ RADID STtDY P TABLE 1 4.1 H3J FMNY RADIOS DO YGJ MO YOLR fat 1ILY I4WE IN Y0Lst 10rf, OR CON'T YOU HAVE ANY RADIOS AT TFE PRESENT TIRE 7 t-TOTAL o. TOTAL RESPODOD(TS k 600 ( l .0,E 13 2. l-1 I: 1 89 15. i: 2 I 135 23. 3 135 i 23. 4 94 16. I 5 58 l' 10. 36 6. 1: 7 is ti 3-I e p. s l': 1. o 2 l,i 10 11 l 2* g-11 1 f. 12 2 I DG(oT 100U + 1 D I F i F' g 9 O l

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1- . mane i Italle... ! work for the natioul survey research fitui' t Resear up. We're doing a eurvey of the different types of radt t people have in their homes and estemobiles. Are you the male / female.. head of your household? .(Ir YES) PA00EID WITN INTT.AVIEW (If N0) May I please speak to the sale or female head of your householdt 1. How many radios do you and y nr famil have any radios at the present time? y have la y'our homes or don't you (1 L1' (2) 2 (3) 3 (u) 4 (4) 8 (I) 8 (7) 7 (8) 8 (0) 9 (0) to 4 other (please specify) (X) DON'T 20W [.f) NOME'(8K2p 70 Q. 2) 5 Tron what you resember, how many of these radios are both AM and FM'? < (1) 1 (2) 2 (3) 3 (4) 4 (5) 8 (8) 8 [7] 7 (I)S-{B)'8,(0)10 4 Other (please specify) [X) DON'T 2 0W- ' (Y) WOIS '. . ? .% y, w. How many of these radios can be operated by be.tteeghi. (1) 1 (2) 2 (3) 3 [W) 4 (3) 5 (6) 8 (7) 7 (8).T*(Il.9" (0) to ...I t'i., t? 3 Other (please specify) (X) DON'T WCW (Y) scam

  • 3; 9

How many of these radios are just AM) -r [1) 1 (2) 2 (3) a (4) 4 (s) s (s) (7) 7 (s).s (s) 4 't03 1,0 7 10. Other ('please specify) - (X) DON'T DOW (Y) WONE 11 And how many of these can be operated by batteryt i (1) 1 (2) 2 (3) 3 (4) 4 (5) 5 (1) 8 (7) 7 (0) 8 (9) 3 (0) 10 12 Other (please specify) (X) DON'T 2 0W (Y) NONI il And how many of your radios are just THf (1) 1 (2) 2 (8) 3 (t) 4 (8) 5 (8) t (?) 7 (I) 8 (0) 9 [0] 10 iti Other (please*specify) _ (X) DON'T D OW (Y) NONE 15 i l t 2. Do you and your family own any automobiles 1 (1) YE8 (2) NC (8 KIP to Q. 2) 16 (It YES) Mow many of these have car radios? l (1) 1 (2) 2 (3) 3 th) 4 O nza (please specify) 17 t l (4) DON'T DOW (7) NONE (8 KIP TO Q. a) How many of these car radios are both AM and IHf (1) 1 (2) 2 (3) 3 , [4] 4 OTX1R (please specify) il I l (C) DON'T KNOW [7] NONE t ~ And how many are just AMP (1) 1 (D 2 (3) 3 (4) 4 CTMIA (pLEASE Sp3 CITY). it (6) DON'T D OW (7) NOME 4,x-(:t eum 8 Just one more question...De you think you or your family. will be buying either an AM/TM radio or an FM only radio during the nort six sonths or so? i (1) YE8 (2) NO (1) DON'T 00W 20

  • h ThaAk you very much.,.have a real nico day /evaning.

i j Telephone Nwaber v..--8-..- i _ _.._. _ _ _}}

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