ML20206M815

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Affidavit of Ae Luloff.* Population Growth Rates in Seacoast Area Inaccurate.Resume Encl
ML20206M815
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 04/14/1987
From: Luloff A
HAMPTON, NH, NEW HAMPSHIRE, UNIV. OF, DURHAM, NH
To:
Shared Package
ML20206M356 List:
References
OL, NUDOCS 8704200201
Download: ML20206M815 (39)


Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY A'4D LICENSING BOARD

)

In the Matter of )

) DOCKET NOS. 5 0-4 43-OL PUBLIC SERVICE COMPANY of ) 50-444-OL NEW HAMPSHIRE, et -al. *

)

) OFF-SITE EMERGENCY PLANNING (Seabrook Station, ) PLANNING Units 1 and 2) )

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AFFIDAVIT F ALBERT E. LULOFF I, Albert E. Luloff, depose and say as follows:

1. I am Associate Professor of Rural Sociology, and

- Community Development Program Coordinator in the Department of -

Resource Economics and, Community Development at the University

- of New Hampshire. I have been employed at the University of New Hampshire since September, 1977, where my responsibilities are equally divided between teaching and research. My research component has emphasized'ihe study of the structure and. impact of population redistribution and migration on New Hampshire communities. As part of my research efforts, I have developed n and maintained one of the first, and largest, integrated data n

~o 88 banks on minor civil divisions in the state, which provides me So a base of knowledge from which to do much of my work on ou I have 88 community and population trends within New Hampshire.

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published extensively in the area of migration and its impacts, R5 and a statement of my professional background and mas qualifications is attached hereto and marked "A."

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2. I have thoroughly examined Volume 6 of the New ,

Hampshire Radiological Emergency Response Plan, focussing my examination on the population figures it contains and the methodology used to obtain those figures, and am able to state, based on my expertise, ongoing research, and specific knowledge of the seventeen New Hampshire communities'in the Seabrook EP2, that very little or no confidence should be placed on the accuracy of many of those figures, especially those which (1) are based on projections of the population growth rates of

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towns in the EP2, (2) pertain to the size of the special needs and other transit dependent population groups, and (3) pertain to the size of the peak transient population. -

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3. Population Growth in EP2

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g';y~ Applicants contend that an adequate treatment of

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growth in the seacoast area is accomplished in the KLD Report,

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~~ which'makes'use of 'mean annual growth rates over 4 years, for the New Hampshire towns.* (Lieberman, TOH III) In fact, such treatment may be biased. in.ethat lt-ignores the vital and- -

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dynamic changes that have occurred in southeastern New -

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, Hampshire, in general, and the seacoast in particular since the-l mid-1960's. Rockingham County, which is the home of the seventeen New Hampshire communities in the EP2, has experienced l

l a greater than national and regional rate of growth since the decade of the 1950's. For the period 1950-1980, it averaged a l decennial rate of growth of 39.3% compared to the national average of 14.44 and regional average of 9.9% for the same time period. Further, for the most recent decade -(1970-1980),

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Rockingham County alone accounted for more than 10%.of the total New England population growth (51,400 of 501,000).

Lieberman's (TOH III) claim that a 4-year period is used to generate the annual growth rates is in error since the

' compounded annual rates were calculated using state data for

, the years 1980 and 1985* (Lieberman, SAPL 34), which, in fact, represents a 6-year time frame. Further, no justification is given for the use of the 1980 and 1985 dates in the first place, especially since other data for a longer time series is readily available.

For projecting small area populations, the general rule,is to make use of as,much continuous information as available, unless a disjoint series presents itself, that is, unless a structural shift in population growth occurs.

Thus, regardless of whether the 1780 to 1985 series used by Lieberman is 4 years or 6 years in duration, the selection of the most recent time span for generating average annual rates of growth results in a set of conservative predictions of population since it ignores the long term'and' uninterrupted dynamic of growth experienced by the seacoast area communities. Indeed, for eleven of the seventeen communties, the use of the 1980-1985 time frame produces the lowest average annual rate of growth and, therefore, the most conservative l

estimate of population size for these communities. For similar reasons, it is not clear why Lieberman would use 1984 office of State Planning estimates of population as the base from which to apply the 'most recent annual growth rate for each town" 1

(Lieberman, SAPL 34) in order to project 1986 town populations. Since he was already in possession of 1985 data, and since 1984 is not a standard year, there appears to be no reason to use it as a baseline for projections. Such a procedure undermines the logic of creating a 1980-1985 average annual rate. And, that the final estimates were " confirmed by local sources" (Lieberman, SAPL 34).does not provide any measure of validity despite the claim for same found in Applicants Motion for Summary Disposition on SAPL 34. Validity is based on an assessment of the degree to which a data item measures what it,is designated to measure. The use of figures, drawn in large part from the local town offices and from a model developed by the Office of State Planning of New Hampshire (which in itself is based, in part, on a disaggregation of state and county growth models to the minor civil division level) does not provide an independent measure of validity. Essentially, such an assessment is contaminated by the presence of an identity relationship, that is, - -

confirmation is sought for numbers drawn in part from the suppliers of those numbers.

Similarly, the complaint of the Applicants that there is 'no current regulatory requirement to project into the future when formulating ETE" (Lieberman, TOH 111) neither vitiates nor addresses the contention of SAPL 31, item 3, which raises the need for data on resident and employee growth over the expected forty-year life span of the plant. The use of KLD's average annual rate (based on 1980-1985 data) would i

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result in an aggregate population of roughly 95,000 in 1990:

103,000 in 1995; and,112,000 in 2000.

A more realistic, and less conservative (but still not liberal),model one which uses a fifteen-year time series, 1970-1985, to create the average annual rate of growth would result in estimates of 97 000 in ,

1990,107,000 in 1995, and 121,000 in 2000. ,

The early  ;

differences in these models, though quite small, become much larger as one moves further from the point of projection , and, in all cases, small differences can have major , imp acts on

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several of the seventeen seacoast communities since these communities vary widely in population size, ranging in 1985 -

from a low of 651 to a high of 26,675.

Thus, marginal increments in average annual rates of growth cangecause lar numericai increases in population in several of the -

communities.

By fixing on o'nly the last six years of the time series acquence, as in the work of Lieberman, the average annual rate tends to decrease. Since steady growth has occurred over the long term, more net additions of individ uals to achieve a constant rate of growth is needed whe n using a shorter time frame, because the larger the initial populati on base, the more difficult it is to maintain high average annual rates of growth.

Moreover, the Applicants' claim that the Intervenors (SAPL 31) statement *(t)he area along the coast... 'can be "

expected to have grown at a rate faster than the country (sic) --

s, wide average' ...

provides no basis of fact other than the '

intervenor's expectation" is in error since it disputes'

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experiential evidence. Further, there is ancilliary evidence to support the SAPL 31 claim. For example, regardless of intra-county growth differentials, many of these seventeen towns continue to experience rapid growth, far exceeding

. national, regional, and state averages. ,Indeed, several national planning organizations have targeted this area as one which will continue to experience growth, largely as a result of its valued residential ambience, proximity to large metropolitan centers, and good highway access (especially Routes 95 and 495). Similarly, data on both traffic counts and housing patterns support the Intervenors' contention (SAPL 31). <

According to published New Hampshire Department of ,

Transportation (NEDOT) information, traffic counts at five sites'in the area (Routes 1, 1A, 501, 95 Toll Plaza, and 95 State border-Mass and NH) have increased by more than 36%

i between 1980 and 1986. For example, counts at the 95 toll booths reveal an increase of 65% in average daily traffic (from 26,100 in 1980 to 43,300 in 1986); an 18% increase on lA in Seabrook (from 8,500 in 1980 to 10,000 in 1986); a 424 increase on Route 1 in North Hampton (from 11,400 in 1980 to 16,300 in 1986); and a 49% increase on 101 in Stratham (from 13,000 in 1980 to 19,300 in 1986). Thus, on both the major interstate and state highways and on what is essentially a commercial and shopping route, traffic patterns have grown significantly since-

. 1980. Such data, in part, reflects the continued increases in population of seacoast area communities.

Housing patterns in the seacoast area during the same time period also reflect continued growth. .Between 1970 and 1985, the total number of housing units in the seventeen communities increased from 22,300 to 35,000, an increase of more than 50%. This growth can be decomposed into increases in single family, multi-family, and mobile home units. Single family units increased from 14,600 to 23,500, multi-family units from 6,600 to 9,900, and mobile homes from 1,000 to 2,700. This increase was not limited to just the early part of the 1970-1985 period. Indeed, between 1980 and 1985, over 1,000 multi-f amily units, 500 mobile home units, and 2,200 single family units were added to the housing stock of this

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region. Further, between 1980 and 1987, ~more than 900 new condominium units have been-sold in the Seacoast area. -

According to figures compiled by the State of New Hampshire, over 19,000 building permits were issued in 1985 statewide, an

.. , , s increase of over 11,000 permits from 1983. Many of these

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permits were issued for construction in the seacoast area, which remains a popular residential choice for immigrants to New Hampshire. Thus, the Applicants' contention that the Intervenors' statement is not based on factual or empirical evidence is incorrect (Lieberman, SAPL 34) .

Further, a report by the Energy Management Department of Public Service Company of New Hampshire (May, 1986) states that

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" signs of weakening with regard to New Hampshire's above r

l average performance are nowhere in sight." According to the report, this performance, which the Energy Management

Department labels "nothing'short of robust,' points to several factors which have fueled New Hampshire's economy, and the report begins this list of factors with popu'lation growth. It also mentions the state's low unemployment rates and personal income growth as key contributors to the state's booming I economy. It is important to note that Rockingham County, which contains the seventeen New* Hampshire communities in the 10-mile EPZ, has greatly profited from this robust economy. Numerous firms have relocated, expanded, or developed in this region, and the area continues to enjoy extremely low unemployment rates. PSNH itself suggests that the state will experience a population growth rate "twice the rate of the region (New

, England) and nation in the next twenty years.' Since the rational annual average rate of growth is about 14, then the -

state should enjoy about a 24 annual average rate, according to PSNE. The state increase represents an aggregate movement of all ten counties; however, two counties, Rockingham and Hillsborough, acccunted for almost 60% of the state's total population growth between 1970 and 1980, and Rockingham County alone accounted for 37% of the state's growth. Thus, it is clear that Rockingham County's growth rate will far exceed New Hampshire's average annual rate of 2% and is in part a major driving force of that average. What is further clear is that many of the seacoast communities will be playing important roles in driving the county average. Thus, Lieberman's use of 1980 to 1985 average annual rates are conservative in that no fewer than 12 of the 17 communities experienced a growth rate

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of less than 2% per year, with 5 experiencing rates less than i 1% per year. It would appear that if it is reasonable for PSNH I to use forecasts based on a 24 per year population growth rate to forecast energy demand, then it cannot be unreasonable to i

use the same 24 per year population growth rate to forecast resident population.in the seacoast area. While the differences between Lieberman's estimates and a " flat" 24 rate, or a modified average annual rate based on the 1970-1985 time series, will be small in the short time horizon (10-15 years),

these small differences become quite large, all other things being equal,.as you near the end of the 40-year expect'd e life -

span of the Plant. Thus, KLD's repeated statement in Volume 6 of the HERERP and in their responses to several of the Intervenors' contentions that their model for computing ETE's relies on a liberal interpretation is not correct with respect to their work on resident population growth.

Similarly, Lieberman in his response to Town of Hampton III discusees the approach he used in projecting employment figures to 1986.

While he is correct in his limited discuss'on i

of the difficulties associated with projecting employment figures, his modelling approach again differs from that adopted by the Energy Management Department of PSNH in its forecast of energy demand. In the report by the latter group, nonagricultural employment in the state is forecasted to average about 2.2% between 1985 and 1995 and 1.8 % between 1995 and 2005. This is a state average; once again, Rockingham County has enjoyed a better than state average rate of

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employment growth. For the years 1980 and 1985 (based on second quarter data for each year), Rockingham County had 3,689 and 5,241 units or industries, and 55,223 and 74,700 employees, respectively, and thus experienced about a 64 average annual rate of growth for industries and a 5.14 average annual rate of growth for employees. Lieberman's claim that he used 'the mean i

annual growth rate over 4 years, for the New Hampshire towns" i

is in error, since his rates were based on the 1980-1985 experience and, in any case, do not reflect the same level of optimism found in the Electric Load Forecast Model of PSNH or s in the employmen,t and industry figures developed by the N'4w Hampshire Department of Employment Security.

Finally, additional information on the relatively rapid ,

growth of the communities 'in the seacoast area is found in the changing patterns of land use in Rockingham County. Between 1974 and 1982, the dates of the most recent U.S. Department of Agriculture' aerial photographs of the state which have been i

digitized and entered into a geographic information system,

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l significant land use shifts occurred. The amount of land ~

classified as developed experienced an average annual rate of increase of 6.884, with most of this land coming from idle land (land recently cut from forest or land formerly in agriculture but left fallow so that the natural process of reforestation occurs), forest land, and agricultural land. The rates of change to developed land varied across the county as well as among communities in the EPZ. In 1974, almost 21% of Rockingham County was developed; by 1982 nearly 364 was

developed. Among the seventeen EPZ communities the comparable figures were 294 developed in 1974 and 47% developed in 1982.

Thus, the seacoast region was slightly more developed in 1974 and significantly more developed by 1982 than the county as a whole. Indeed, seven communities in the EPZ were more than 50%

developed in 1982, with Rye at 59%, Hampton at 60%, and ,

Portsmouth at a 74% developed rate (i.e., developed land at a percentage of total town land area)'.~ These rates further underscore the continued growth of the communities in the EPZ.

4. Special Needs and Other Transit Dependent Population It is the contention of the Intervenors (TOH IV) that NHRERP Rev. 2 calculates the special needs population of the Town of Hampton based upon a suspect annual survey. According ,

to Applicants' Motion for Summary Disposition of TOH IV, the asserted base of concern over the annual needs survey is disproved. The claim for disproval is based on the Affidavit of Richard Strome (TOH IV) where it is state that "an additional 50% of individual bus capacity (except school

requirement) has been arranged in order to provide for the effective evacuation." This response, however, begs the concerns of TOH IV as found in Section C (labelled special needs population). The contention of TOH IV is that the annual survey conducted by the State of New Hampshire for the Town of Hampton resulted in only a 24 response rate. No explanation of the survey results or of why a 50% multiplier was used, or of what the final total number of special needs people was is offered in the responses of Strome or the Applicants. Whether
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or not enough emergency equipment is available to meet the needs of the special needs population is simply not accessible from the responses generated by the Applicants.

Sir.11arly, KLD bases its trip generation information on a survey of adult heads of households conducted by First .

Market Research of Boston (Lieberman, SAPL 31). The Intervenors (SAPL 31) question the survey results on the basis of potential bias. The question is not answered in Lieberman's response. Rather, he argues that the " sample of 1,300 responses is extremely robust.* Statistically, robustness refers to a test's sensitivity to distortions, and is -

particularly difficult to evaluate whenever there are several distortions, or unmet assumptions, that apply simultaneously.

Thus, Lieberman's claim o'f robustness must be supported with -

i data which can argue convincingly that no serious distortions.

exist. Such data are not presented. Instead, Lieberman's claim appears to rest on the size of the sample, not its adequacy. Methodologically, one cannot use' size of sample to validate robustness since the number of people interviewed has little to do with the quality of the interviews or the representativeness of the resultant sample. The survey used to generate the information was clearly biased in that no apparent efforts at call back were made -- either the head of the household responded or the number was apparently scratched from l the list and replaced with one with the last digit of the phone l number increased by one unit. Such procedures are not common l

in phone survey methodology, primarily because of the great 12- )

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potential for response bias to be generated. Normally, multiple efforts (at least three) at staggered times (for example, weekend day, weekend evening, weekday evening) are used. Further, no effort was made to identify whether or not the surveyed sample reflected any of the contextual parameters of the population living in the seacoast. Thus, the results of the survey are questionable, and whether or not the actions of those employed in the EPZ are accurately represented by the survey remains unclear. The position in SAPL 31 (Item 6) remains unaddressed by Liebe*rman (in his Affidavit on SAPL 31).

Similarly, in SAPL 31 a question is raised on the number of people requiring transit assistance as estimated by KLD. Lieberman,.in response, does not address th,e question of validity of estimated numbers, as posed in SAPL 31, but rather refers to his argument on validity in response to Item 6 (the First Market Research Survey). The two estimates are drawn from and speak to two different segments of the EPZ population. The First Market Research Survey is seriously flawed, and the NHCDA survey, which Lieberman also uses to compare the results of the KLD effort, suffered from extremely low response rates (in Hampton only 24 responded). Thus, on

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almost any basis, there is little independent support for the numbers generated by KLD, including the fact that the RAC rebutted KLD's numbers with national car ownership statistics.

It is curious and patently inconsistent that KLD would rebut RAC on the grounds that only " site-specific data are relevant,"

especially, since KLD uses a study in New York State to support n

the trip generation data. Furthermore, that the number of people in the EP2 having no vehicles available and, therefore, requiring assistance is adequately addressed tur arbitrarily doubling the KLD count from 2,240 to 4,495 remains unsupported despite the claims of Lieberman, Strome, and the Applicants.

I I Strome's response to SAPL 18, it is argued that the correct number of busea.needed to transport all transit dependent segments of each community is available. He specifically states (Lieberman, SAPL 18) " current counts of school populations and other special facility populations, and the most recent results of the special needs survey, have increased the maximum number required to 515. This current number of maximum bus requirements does not impact on the 4 auf'ficiency of resources." Because the evidence to support -

Strome's response is not readily accesaible and the survey is suspect, I am currently engaged in research which will provide me with a much more reliable basis that that used by KLD for estimating the size of the special needs and transit dependent Population within the EPZ. Early indications are that the size of these groups could be twice as large as that found by NHCDA i in its survey.

Moreover, much KLD's basis for estimating need is l

drawn from data first developed by M. Kaltman which was l

published in February, 1981. Serious oversights are present in the Kaltman report with respect to the various special facility populations; including schools, health support, and child care facilities. With respect to educatonal facilities,

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only 24 institutions were identified by Kaltman in 1980-81. A major contribution to the undercount present in the 1980 Kaltman report is the absence of sites in Brentwood, New Castle, Newfields, and Portsmouth. Our research in 1987 has identified 39 institutions (public and private) with a total of ,

12,077 students. In 1980, the Kaltman report listed 12-day care f acilities with 577 total children. However, according to our research, there are at least 80 licensed day care f acilities in 1987, not including church schools (such as Hampton Christian School, which has a church preschool day care with approximately 45 preschoolers and 15 day care) which accounted for 1,828 total children. Thus, merely accepting the ,

findings of the Kaltman report underestimates the number of facilities (day care plus educational buildings) by a minimum ,

of 83 units and more than 3,000 students. Despite the fac,t that student enrollments in public schools have tended to decline in some communities in the region, there are many more facilities which were apparently overlooked by Kaltman in the initial _ report, and simply not counted by Lieberman in his use some five years later of the same report in calculating special needs population. Moreover, these numbers do not reflect those

day care facilities not licensed by the state in which five or i fewer children are cared for in a private home.

Similar problems with the Kaltman report exist in its i

enumeration of health care facilities in the seacoast region.

, Kaltman identified 6 total institutions in 1980 which accounted for 452 beds. In 1987, we have identified 24 total i  :

institutions with a total of 1,062 beds. It is notable that the Kaltman report did not include one of the region's largest health care f acilities, Portsmouth Hospital,(now Portsmouth Regional Hospital), and only included those facilities found in Hampton and Exeter. Furthermore, Strome's Affidavit in j

response to SAPL 31 states that (a)t least annually, the Director of NHCDA will direct that a plan review is performed to ensure that the plan reflects current emergency preparedness status .... Further, it is stated:

Annually the Director of NHCDA will certify, by letter to FEMA, complia'nce with the periodic requirements for the preceeding year.

I am informed that although they were asked during the discovery period, applicants presented no new information on the matter of special needs populations and, therefore, a question must be raised 'as to whether the duties of the NBCDA Director have been appropriately carried out. That the numbers first develope.d by Kaltman and pub,11shed in February og 1981 continue to provide the core information for identifying this population group, despite the fact that the Kaltman numbers are more than 6 years old, suggests that a major undercount of needed transportation resources has occurred. Such gaps in the extant data set also calls into question Item 7 of Strome's Affidavit in response to SAPL 18 wherein he states, "It is my opinion that the New Hampshire State and local RERP's identify and provide for the availability of transportation resources that simply exceed the capacity required for persons who may need transportation assistance at the time of an emergency,"

.(emphasis added).

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In addition, Lieberman's suggestion in his Affidavit 4

in response to SAPL 31 that the Intervenor's contention that there has been "significant growth" in seasonal accommodations in the EPz over the past 5 years is unsupported in any way is incorrect. Data exist which documents an increase of over 1,100 condominium units in the Town of Hampton alone between 1980 and 1985, and ancilliary data on traffic counts, aggregate and multi-family housing units, and new campground and hotel / motel bed and breakfast / inn units also supports the claim by the Intervenors of significant growth in the seacoast I region. Further, a report by'the New Hampshire Office of State Planning, Hampton Beach Chamber of Commerce, Arthur D. Littit, Inc., and Kimball Chase Company, published in 1984 and .

finalized in 1985 states that because of continued growth in l

! population and economic activity in the region, demand for - -

parking - the key to KLD's and Lieberman's estimation procedure i

for the peak population - will continue to grow at an estimated rate of one to three percent annually.

5. Transient Pooulation The KLD study attempts to estimate the size of the beach population in the EPZ by interpreting aerial photos of the beaches and their environs taken during periods of high use on summer weekends. The final estimate given is based on a I count of available parking places, multiplied by a factor j relating numbers of automobiles to numbers of occupants.

l Working together with William Befort, an aerial photo interpreter, I have confirmed that a great many photographs l ---___ _ . - . . - - _ _ - _ _ _ _ ~ _ _ _ _ - _ . , _ _ _ _ , _ _ _ _ _ - _ _ _ _ - _ _ - _ _

were used in the course of the KLD investigation: a total of about 11,000 color slides, of which all but 1,000 or so were tak'en in 1979. All were acquired using unspecialized 35mm camera systems with conventional non-photogrammetric lenses and conventional (non-aerial) flims, and were taken for the purposes of this inquiry. -

It is difficult at short notice to assess the value of this archive, especially in the absence of coverage maps showing the spatial layout of the photography. Certainly the number of photographs is adequately larger complete coverage of the strip of EPZ between Interstate Highway 95 and the ocean, atscaleslargeenoughtopermitcountingsuchcabsandparking l spaces as may be seen from the air, could be obtained with fewer photos. , ,

Non of the connecting links between the pictorial data and the reported numbers has been provided; in their absence, criticism must go partly by guesswork and any analysis is problematical. There must have been some sort of-r data-recording form on which counts of cars or parking spaces ,

in each photograph were compiled,. If these-records were -- -c available, individual-photo counts might be sampled for verification; as. it is, only the gross total for the entire area can be checked, which implies reinterpretation of the entire set.

Nor has sufficient background information been unearthed to permit even this laborious approach. As far as can be determined from preliminary examination of the

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Photographs, coverage of the beach and its environs is discontinuous despite the large number of exposures. This raises various questions. Was the intent to obtain complete coverege? If so, how were the gaps accounted for? If not, s then the study is a sampling study rather than a complete enumeration; yet no information about sampling design or ,

stratification accompaniep the photographs. Without such methodologica'l details, the aerial survey data belongs in the category of irreproducible results.

A disadvantage of .the 35mm slide format in aerial photo work is that it is too small to permit annotation at the original scale. This can raise serious difficulties in any b study involving counts. Wherever two photographs overlap in their coverage, as many.of these do, standard practice demands that the interpreter carefully draw a line of separation between the object to be counted on one photo and the objects to 6e counted on an over' lapping photo. This is easily done on large-format prints or on enlargements made from small negatives; on 35mm slides it is virtually impossible, and no

_ such lines appear on the KLD photography. Thus, it is -

difficult to guess how the interpreters avoided double-counting in cases of overlap, or how they knew where there were gaps in coverage. Were all interpretations transferred to a master map of the area? If so, it would be at least as valuable to have this map as to have the photographs. If not, then how was it possible to avoid duplications and omissions between photos?

Within. individual exposures, similar difficulties

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l arise. Without annotation on the images, an outside analyst can only guess at how the interpreters kept track of their counts of cars or parking spaces. Perhaps the slides were projected onto some erasable surface, and each item was marked off as it was counted? Or perhaps not: Absent a complete l recount, the photos themselves provide no evidence.

Aside from these factors,_which taken together make the photographic materials supplied nearly opaque to critical analysis, various other questions arise concerning the sufficiency of this photo data for this kind of ' inquiry. It should be obvious that many of the actual cars and parking spaces in any such area are sheltered and concealed from aerial observation. Can these be accounted for? If so, do they.

represent a d1fferent population, with perhaps g different occupants-per-car ratio, than the autos visible in the open?

Again, nine-tenths of the photography dates f rom 1979, since which time very substantial developments have taken place in coastal New Hampshire. Are the comparatively few later photographs sufficient to ensure that data derived from the earlier photos are not obsolete, and what tests have been performed to ascertain that this is so?

. William Befort and I are continuing our assessment of i

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' hhese aerial photos, and we hope to have further conclusions '

re'a.iy by the hearings this summer. Meanwhile, there is additional reason to suspect that KLD's estimates of peak transient and total populations in the EP2 are in error. For example, KLD relies on the Kaltman report for data on seasonal I

accommodations.

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The Kaltman report contains the only detailed list of seasonal accommodations, including peak occupancies of the area's camp grounds, hotels, motels, inns, and bed and breakfasts. Our ongoing verification of this data has revealed

. numerous omissions. For example, we have identified six additional campground sites which increase the maximum capacity a

for this segment of accommodations to more than 7,400 (an increase of over 2,000 from the Kaltman report). We have also identified 13 new hotels in the Hampton area, not counting f acilities under construction (such as the large Portsmouth i

Sheraton) and are in the process of tabulating total capacity .

i for these units. However, it is clear that the Kaltman report '

undercounted seasonal accommodations in the 1981 report, where approximately 3,.300 rooms in Hampton were identified. Not,

included in this study were the numerous cottages / bungalows located either in or abutting the Hampton Seasonal BusiNass Zone.This zone is betwee'n Ashworth Avenue and Ocean Boulevard and generally runs from A Street to the Seabrook Bridge, with -

the heaviest concentration of seasonal residences beginninO on G and H Streets and moving south towards Seabrook. In -

4 addition,severalstreets(suchasAtlantic,bosson,Epping, Dover, and Concord) which abut the state park and run from Ocean Boulevard towards the Beach contain numerous' seasonal residences. And, many streets running from Ashworth Avenue g towards the marsh, including but not limited to Dow, Fellows, I' Tuttle, Bragg, Keefe, Perkins, Johnson, Auburn, River, Haverhill, and Mooring, also contain many seasonal residences.

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e The failure to include these units might account for the wide discrepancy in the number of units / rooms identified in the Kaltman report for Hampton (approximately 3,300) and the estimate of 6,000 in 1987 from the Hampton Chamber of Commerce.

Further, no effort was made to identify or include known special events which would raise peak population estimates of the EPZ. Such events would include among others, Market Square Day, the Stratham Fair, and the Phillips Exeter Academy commencement exercises.

Applicants Motion for Summary disposition on TOH III and Lieberman's response to SAPL 31 both claim that several data collection methodologies were utilized in an effort to

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adequately account for both the permanent and transient -

populations of both Hampton ad n the EPZ.. These methodologies include the use of beac.h surveys, on-site parking surveys,

+@+

traffic counts, large-scale photos of the beach area (Hampton - ,

taken July 4, 1983), and multiple sets of extension aerial photographs taken of the regions. Whether the counts generated f rom the "large-scale photos" were accurate cannot be assessed

~

since they were not produced during discovery (apparently there are three of them, see page E-6, Volume 6,-NHRERP). Since a magnifying glass was used to help enumerate "... a total of a 1,160 persons ... on the beach and on t5e abutting sidewalk near the state facilities," opportunities for miscount of individuals clearly exist.

However, the true key to the estimates of KLD's transient population is based on their utilization of parking

spaces. ltt is argued in Volume 6 of the NHRERP (and in Lieberman's Affidavit on TOH III) that KLD " relied on empirical i observation of the number of vehicles which can physically be accommodated within the beach area." Since the counts alleged to be accurate by Lieberman, and supported by Strome and the Applicant, are the linchpins to the transient population-count, ,

this area is~one which neede a thorough examination.

~

I do not have the answers to the assessment of Lieberman's work at this point in my research, but by the hearings this summer, William Befort and I will be in a much better position to evaluate these critical numbers. Further, since the number of people per car, as est'blished a in the "36 surveys of vehicle .

occupancy," is a critical factor in Lieberman's response to TOR III's. contention that inaccurate accounting,has occurred, it is quit'e surprising that a survey of, vehicle occupancy did not occur on August 11, 1985 to coincide with the aerial mission flown on that date, a date KLD claims that the highest vehicle counts were made. In the absence of ground truth on the day of that mission, we can only hypothesize that the patterning established in the ground vehicle surveys of August 28, 1985, September 1, 1985, July 4, 1986, and July 5, 1986 are an accurate reflection of the peak day load of August 11, 1985.

Such treatment is highly questionable and not standard

. practice. Moreover, there were only four days of surveys with multiple timest it is an exaggeration .to speak of "36 surveys l of vehicle occupancy" when it is 36 different times on these four days that is being referred to. And, no explanation is

offered as to why the timing of counts on each of these days varies. Repeated surveys of an area at random times does'not establish a reliable estimate of vehicle occupancies.

There is additional information available which addresses increased summer transient traffic flow along'the ,

major seacoast arteries and which helps to support the TOH III_

and SAPL 31 and 34 contentions that increased population growth has occurred. For example, the average July-August 1986 daily traffic counts in Stratham on, Route 101 was 22,000 (304 greater than its average January-February daily count), on Route 51 in Exeter it was 18,500 (684 greater than January-February

.. ~

average), on Route 1 in North Hampton it was 17,500 (394 greater than January-February average), on Route 1A in Seabrook it was l'8,450 (213% greater than the January-February. average),

on Route 95 at the state border it was 83,000 (904 greater than

, sne aanuary-rooruary averages, ano at una we coAA cootns it was 62,250 (994 greater than the January-rebruary average). Thus, increased traffic continues to be documented in the mid-winter versus summer comparison.

i

~

l

,. 1.

Albert E. Luloff t

i

- 24-l l

--,_-___-.m._, -

...,_c,, .,,.-,___.____,,....r_-__..,_.m_..__._

April 14, 1987 STATE OF NEW HAMPSHIRE COUNTY OF M ss.

The above-subscribed Albert E. Luloff appeared before me and made oath that he has read the foregoing affidavit and that the statements set forth therein are true to the best of his

' knowledge. ,

Before me; h

\Notary Public y ~~.

My commission expires 10/23/90 f

1 J

l _ _ , , _ _ , _ . , _ _ _ _ _ __, _ _ _ _ _ _ _ , . _ _ _ _ _ _ _

JL' RESUE NAE: Albert Elliot Luloff HOE ADDRESS: 12 Tanglmood Drive Dover, NH 03820 PHONE: (603) 742-2822 0FFICE ADDRESS: 316 James Hall Department. of. Resource Economics and Community Development University 'of New Hampshire Durham, PN 03824 FHONE: (603) 862-1700 BIRTH: J une 22,19S0 MARRIED, three children ,

EDUCATION:

The Pennsylvania State University Maj or: Rural Sociology .

Minor: Theory: Rural-Urban Continuun Degree: Ph.D.

Date: November,1977 Thesis

Title:

Community Adoption of Flood Insurance: A Study of Structural and Interactional Influences North Carolina State University Maj or: Sociology Minor: English Degree: M. S.

Date: J une,1974 Thesis

Title:

Community Differentiation: A Study of North Carolina Conmunities Cornell University Maj or: Rural, Sociology Minor: Communication Arts i Degree: B. S.

Date: December,1971 l

Areas of Concentration:

t A. Community Theory and Development l B. Migration and Social Change C. Rural Sociology D. Methods and Statistics i

L

2 POSITIONS AND EXPERIEN :

Present Position - Associate Professor of Rural Sociology and Comunity Development (University of New Hampshire; 7/82 - ); Coordinator of Community Development '

Program (1979 - ).

Previous Position - Assistant Professor of Community Development (University of New Hamgshire; -7/77 - 6/82). --- -.

Teaching:

CD 507 - Introduction to Community and Community Development. This course stresses the principles and methods of comunity development with emphasis pl aced ,on theoretical orientations to the study of community.

CD 508 - Applied Community Development. This course provides the student with an opportunity to engage in cmmunity action episodes through " hands-on" experience (field placement). Cl ass discussions, -

assignments and readings are geared to the practice and utilization of community development theory and research.

CD 628 - Comunity, Conflict and Consensus. This course stresses the maj or theoretical' approaches to conflict ar,alysis. Through actual community case study research the students apply these theories in an effort to understand the critical social relationships which are part of planned or anticipated social changes in the comunity.

CD 705 - Planned Change in Nonmetropolitan Communities. This course focuses on the discussion and application of comunity development theory and principles as used in social science research. Emphasis .is given to empirical research studies of major rural development phenomena.

RECO 8,03 - Approach to Research. This course introduces graduate students'to the meaning of science and the application of logic in the Scientific Method. Emphasis is placed on the principles and techniques of scientific research, experimental design procedures, organization of investigative work, probl em analy se s, work pl ans, and scientific writing.

Research Activities:

NE-149 Levels of Mortality and F.;onomic/ Social Structure of Counties in the United States d

S-2 97 Community and Population Trends in New Hampshire

S-3 07 Land-Use and Demographic Change in New Hampshire

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3 NEC-24 Northeast Rural Sociological Committee; Secretary 1979-81; 1983-1984; Vice President 1984-1986 PlBLICATIONS:

Books and Monographs Published:

Rural Pooul ation Growth in New Enol and. University Park, PA: The Northeast Regional Center for Rural Development,1986. (with T. E. Steahr). .

The Directory of Rural Develooment Workers in the Northeast. Univer-sity Park, PA: The Northeast Regional Center for Rural Development, 1986.

The Structure and Imoact of Pooulation Redistribution in New EnglRDd.

University Park, PA: The Northeast Regional Center for Rural Devel opnent, 1985. (with T. E. Steahr).

Strateates for Estimatino the Ef fects of Rural Community Devel oament Pol icies and Procrams. Under contract to Iowa State University Press..

(with M. K. Miller and D. E. Voth).

l Chapters in Books and Proceedings:

l " Population Growth and Economic Development in New England." Pp. 71-78 in Jahr, J ohnson, and Wimberley (eds.) New Dimensions in Rural Pol iev : Building Uoon Our Heritage, 1986, U. S. Government Printing Office, Washington, DC; (with G. E. Frick).

"The Cultural Component of Rurality in the U.S. A. : Structural Stability Over Time." Pages 73-87 in R.C. Bealer, (editor), Ental Soci ol ogi sts at Work: A Fe st sch ri f t for M. E. John. 1985,. . _ _ _

Bellefonte, Pennsylvania: Grove Press; (with M. K. Miller).

" Interpreting the Turnaround for Policymakers." Pp.17-26 in Wolensky and Miller (eds.), Proceedings of the 4th Annual Conference on the Small City and Regional Cmmunity, 1981, Stevens Point, Wisconsin:

Univ er si ty of Wisconsin - Stevens Point Press; (w i th L. E. Swanson, J r. ) .

" Migration and Its Impacts on the Northeast." Pp. 123-140 in Hugh C. Davis (editor) The Proceedings of the Northeast Acricul tural Leadershio Assemb1v, 1979, Anherst, MA: Center for Envirorenental Policy Studies; (with T. E. Steahr).

Journal Articles:

"S oci al Conserv ati sm : Determinants and Structural Stability Over Time." J ournal of Rural Studies 2(Ntsnber 1): 9-18, 1986; (with M. K. Miller and L. J. Beaulieu).

4 "Reconceptualizing Age and Retirement Status: A Note." Soci ol ooi cal formi: 1E (August): 773-278,1985; (with L. E. Swanson, Jr., and R. H. Warl and).

"Nonmetropol itan Participation in Programs of the Great Society."

Social Sci ence nua rterl y 65 (December): 1092-1103, 1984; (with K. P. Wilkinson and M. J. Camasso).

" Local Voluntarian in New Hampshire: Who, Why, and at What Benefit."

J o urnal of the Cnem u n i ty Dev el o nment Society 15 (Nisnber 2):

17-3 0, 1984; (with W. H. Chittenden, E. Kriss, S. Weeks, and L. Brushett).

" Rural Industria11z ati on: A Logit Analysis." Rural Socioloov 49 (Spring): 67-88, 1984; (with W. H. Chittenden).

" Tenure and Satisf act' ion as Indicators of

Attachment:

A Note. "

J ournal of the North eastern Acri cul tural Economics Council 11 (Fall): 53-60,1982; (with L. E. Swanson, J r. , and R. H. Warland).

" Ant 1 urba ni sm and Norsnetropolitan Growth: A Re-eval uation." B.utal.

Socioloav 47 (Sisnmer): 220-223,1982; (with T. W.11vento).

'Who is Rural ? A Typological Approach to the Examination of Rurality."

Rural Socioloav 46 (Winter): 608-625,1981; (with M. K. Miller).

" Response Bias in Population Surveys: A Reply to Ryan and Lorenz."

J ournal of the rmmuni ty Devel onment Soci ety 12 (Fall): 20-23, 1981; (with P. H. Greenwood and T. W. llvento).

" Respondents, Nonrespondents, and Population Surveys." J ournal of the Comm uni ty Dev el onm ent S oci ety 12 (Fall): 1-11, 1981; (with T. W. 11 ve nto) .

" Migration and the Utility of the CWHS
A Comparative . Note." Review g.f_fublic Data Use 7 (December): 62-65, 1979.
" Factors Influencing Willingness to Move: An Examination of Nonmetro-
politan Residents." Rural Socioloov 44 (Winter)
719-735, 1979; (with L. E. Swanson, J r. and R. H. Warland).

" Inadvertent Social Theory: Aggregation and Its Effect on Community Research." J ournal of the Northeastern Acri cul tural Economics Council 8 (Spring): 44-47,1979; (with P. H. Greenwood).

'i 1 "Partici pation in the National Flood Insurance Program: A Study of Community Activeness." Rural Socioloov 44 (Spring): 137-152, 1979; (w i th K. P. W il ki nson) .

" Socioeconomic Impacts on Agricultural Land Use Changes in the North-ea st. " J ournal of the Northeastern Acricultural Economics Council 7 (Fall): 67-74,1978; (with D. E. Morris).

I 5

"Is Comnunity Alive and Well in the Inner-City? A Conment on Hunter's l Loss of Community." American Soci ol ooi cal Revier 42 (October): I 827-828,1977; (with K. P. Wilkinson).

"A Note on Population Size and Community Differentiation in Nometro-politan Communities." Sociol oov and Soci al Research 61 (July):

486-495,1977; (with C. S. Stokes).

" Historical Interpretations of Developments in American Sociological Theory: A Note." ' Indian J ournal of Social Research 14-(December): 194-209,1973; (with R. P. Mohan).

Agricultural Experiment Station Research:

" Land-Use Change: Rockingham County, New Hampshire 1953-1982." New Hampshire Agricultural Experiment Station, Research Report No.

112; 1986; (with W. A. Befort, M. Morrone).

" Land-Use Change: Strafford County, New Hampshire 1953-1982." New Hampshire Agricultural Experiment Station, Research Report No.

111; 1986; (with W. A. Befort, M. Morrone). -

" Population Growth and Change i n New Hampshire." New Hampshire Agricul tural Experiment Station, Research Report No.107, 1985; (with G. W. Howe and S. G. Hutchins).

"The Senior Population of New Hampshire." New Hampshire Agricultural Experiment Station, Research Report No. 104, 1984; (with E. F. Jansen, J r. , N. L. LeRay, and V. N. Pannel e).

" Town Goverment Volunteers: Their Characteristics, Motivation s, and Costs to the Community." New Hampshire Agricultural Experiment Statio n, Research Report No.101, 1984; (with W. H. Chittenden, E. Kriss, S. Weeks, L. Brushett).

"New Hampshire's Experience with the Current Use Program, 1974 to 198,0." New Hampshire Agricultural Experiment Station, Research Report No. 99, 1983; (with S. D. Smith, E. A. Fountain, P. H. Greenwood, and G. E. Frick).

"An Evaluation of Econanic Gains of Participants in the Hillsborough County's CETA Programs." New Hampshire Agricultural Experiment Station, Research Report No. 95,1983; (with P. H. Greenwood).

" Industry in New Hampshire: Changes in the Manuf acturing Sector, 1970-1978." New Hampshire Agricultural Experiment Station, Research Report No. 93,1982; (with W. H. Chittenden and J. P. Marcucci).

I 6

"A Methodological Appraisal of the Follow Up Instrument Used in Evalunting Hillsborough County's TA Programs." New Hampshire Agricultural Experiment Station, Bulletin No. 521, 1982; (with P. H. Greenwood).

"The Effectiveness of Wide Lath Spacing in Reducing the Handling of Short Lobsters in New Hampshire's Waters." New Hampshire Agricul-tural Experiment Stati on, Research Report No. 92, 1982; (with P. H. Greenwood, M. F. Grace, and the assistance of P. Tilton).

"New Hampshire's Changing Population." New Hampshire Agricultural Experiment Station, Research Report No. 87, 1980; (with T. W.11vento and G. D. Israel).

" Definitions of Comunity: An Illustration of Aggregation Bias." New  ;

Hampshire Agricultural Experiment Station, Bulletin No. 516, 1980; (with P. H. Greenwood),

t

" Migration and Its Impacts on the Northeast." New Hampshire Agricul-1 tural Experiment Station, Bulletin No. 511,1979; (with

T. E. Steahr). -

"New Hampshire's Popul ation: Trends and Characteristics." New Hampshire Agricultural Experiment Station, Research Report No. 73,

' 1978; (with K. T. Taylor).

"The Older Population of New Hampshire." New Hampshire Agricultural Experiment Station, Research Report No. 66,1978; (with N. L.

LeRay and J. G. Campbell).

Book Reviers, Nwsjournals, and Reports:

"New England Economic Development: A Pattern of Reindustrialization."

Ccumissioned paper for the New England Leadership Program, Inc.,

  • J anua ry, 1987.

"The Starr Case, Tenure, and RSS - A Perspective." The Rural Soci o-loaist 6 (January): 34-38, 1986.

l "Where the Surplus Milk is Being Produced." Hoard's Dai rvman 130 (September): 1023,1985; (with G. E. Frick).

" Rural Community Development: The Preliminary Program for the 1985 RSS Meeti ngs. " The Rural Sociol oai st 5 (May): 163-190, 1985.

" Update on the Program for the 1985 Annual Meeti ng. " The Rural i

Rociologist 5 (March): 125-126, 1985.

"On the 1985 RSS Meeting." The Rural Sociologist 5 (January): 52-53, 1985.

7 "On Teaching Fall '82." The Rural Sociologist 3 (July): Z18, 1983.

"The Rural Soci ol ogical Society: A Professional Cari cature. " Ib.e Rural Sociologist 3 (January): 23-27,1983; (with M. K. Miller).

" Book Review of Rural rmmuni ty Devel ooment: A Procram. Pol i ev , and Research Model . " Rural Socioloav 48 (Sunmer): 332-334, 1983.

" Book Review of New Directions in Urban-Rural Micration The Poou-lation Turnaround in Rural America." Rural Socioloav 47

~

(Sunmer): 405-408, 1982.

" Book Review of Community and S oci al Ch ance in Ameri ca. " Rural Sociolcov 46 (Spring): 157-159, 1981.

"Hillsborough County's CETA Programs: A Report Prepared for Southern ,

New Hampshire Services." Title IIB and D Follow-up Evaluation Proj ect; December,1980; (with P. H. Greenwood).

Invited Paper: "The Good Conmunity: A Rural Sociological Perspec-tive." Newsline 8 (July): 44-48, 1980. .

" Reply to comments on 'The Good Community: A Rural Sociological Perspective. '" New sl ine 8 (J uly): S3-56, 1980.

Invited Remarks: "A Comment on 'The Study of Small Towns in V i rgi ni a. '" Small Town 10 (January-February): 29-30, 1980.

" Book Review of Goal Settina for rmmuni ty Devel omente The Case of l Yuba Citv. Cal i f orni a. " Rural Socioloav 44 (Summer): 434-436, I

1979.

" Identifying the Locus for Action: What Local Residents Say." Small Igr.D 9 (December): 11-14, 1978.

" Book Rev iew of Soci ol ooi cal Theorve Its Develoments and Maior Pa ra di crn s. " Rural Sociol oov 43 (Fall): 528-529, 1978.

Citizens Concerns: "What Local Residents Say." Rural Devel oament Vol.1,1974; (with J. S. Theson, K. M. Martin and J. P. Madden).

Papers Presented:

l " Rural Land Use and Demographic Change in a Rapidly Urbanizing Environ-ment." Paper presented at the Sustaining Agriculture Near Cities Conference, November,1986; Boston, Massachusetts.

"Contenporary Issues in Northeastern Conmunities." Invited presenta-l tion at the George D. Aiken Lecture Series, University of Vermont, Septenber,1986; Burlington, Vermont.

t 1

8 "Envirorunental Variables in Models of Agriculture," (with M. Fischer).

Paper presented at the Annual Meetings of Rural Sociological Society, August,1986; Salt Lake City, Utah.

" Examination of the Relational Structure of Community Actions Using 0 -Analy si s," (with C. Kassab). Paper presented at the Ann ual Meetings of the Rural Sociol ogical Society. August, 1986; Salt Lake City, Utah.

"Maj or Issues Facing Rural Communities," - (with. L. - E. Swanson, J r. ) . .

Paper presented at the Annual Meetings of the Rural Sociological Society, August,1986; Salt Lake City, Utah.

" Identifying Canmunity Power Actors and Structures." Invited presenta-tion at RULE Leadership, Inc., Workshop #4, March, 1986; State College, Pennsivani.a.

Session Presider and Panelist, " Rural Community Studies," Presented at the annual meetings of the Rural Sociological Society, August, 1985; Blacksburg, Virginia.

"Agricul tur al Technol ogy : Concerns for the Future II." Seminar presented at the annual meetings of the Rural Sociol ogical Society, August,1985; Blacksburg, Virginia.

Session Organizer and Participant, " Population Redistribution and Migration in New England." Presented at the annual meetings of the Rural Sociological Society, August,1985; Blacksburg, Virgi nia.

"The Demographics of Northern New Engl and. " Invited presentation at Northern New England Rural Leadership Program, January, 1985; Bedford, New Hampshire.

"The Nature Region." Invited presentation at The New England Rural Leadership Program, December,1984; Fairlee, Vermont.

"A Common Language in Community Devel opment: Relating Theory to Practice - A Critique." Invited discussant conments for presen-tation at the annual meetings of the Community Development Society of hnerica, August,1984; Louisville, Kentucky.

"An Examination of the Rural-Urban Continuun A Factor Analysis of New Hampshire Municipalities," (with T. W.11vento). Paper presented at the annual meeti ngs of the Rural Sociological Society, August,1983; Lexington, Kentucky.

Rountable Organizer, "The Changing Role and Function of Community in Modern Society." Presented at the annual meetings of the Rural Sociological Society, August,1983; Lexington, Kentucky.

I 9

"The Cultural Camponent of Rurality: Prevalence, Deteminants, and Structural Stability Over a Decade of Change," (with M. K.

Mill er). Paper presented at the M. E. John Symposium, August, 1983; University Park, Pennsylvania.

"Vol untari an in New Hampshire: Who Volunteers and Why." Paper presented at the workshop of the New England Resource, Conser-vation, and Development Proj ect, September, 1982; Waterville Valley, New Hampshire.

Section Ch ai nn an, "Results of the RSS Membership Survey." Papers presented at the annual meetings of the Rural Sociological Society, September,1982; San Francisco, California.

1 Participant in NE-129 Panel " Improving the Distribution of Socio-economic Resources in Rural Areas: Case Studies (Monroe and Lyma n, N.H. )" Paper presented at the annual meetings of the Rural Sociological Society, September,1982; San Francisco, California.

4

" Rural Industrialization: A Model for Policymakers," (with W. H.

Chittenden) . ~ Paper presented at the annual meetings of the .

Rural Sociological Society, September, 1982; San Fran cisco, Cal ifornia.

"A Research Agenda .for Rural Community and Agriculture: Impl ications from the Turnaround," (with L. E. Swanson, J r.). Paper presented at the annual meetings of the Rural Sociological Society, August,1981; Guelph, Ontario, Canada.

" Community Activists-Apathists: A Brief Note," (with R. W. J. Smith and A. A. Taranto). Paper presented at the annual meetings of i

the Rural Sociological Soci ety, August, 1981; Guelph, Ontario, Canada, i

"A Critical Evaluation of: Beasley and Belyea, Rural-Urban Differences in Canmunity Structure; and Christenson and Taylor, Nomative and l

Situational Components of Satisf action with Common Public Services. " Discussant remarks for "Canmunity Studies Section," at the annual meetings of the Southern Sociological Society, April, 1981; Louisville, Kentucky.

E. Swanson,

" Interpreting the Turnaround for Policymakers," (with L.

J r. ) . Paper presented at the 4th Annual Conference on the Small City and Regional Community, March,1981; Stevens Point,

" Tenure and Satisf action as Indicators of

Attachment:

A Reassessnent,"

(with L. E. Swanson, J r., and Rex H. Warland). Paper presented at the annual meetings of the Rural Sociological Society, August, 1980; Ithaca, New York.

. _ - . ~ _ _ _ _ . __ __. _ . _ _ _ _ _- _ - _ _ _ _ _.._.-. _ _ _

10 i

" Ant 1 urbanism and Nonmetropolitan Growth: A Reevaluation," (with T. W.11vento). Paper presented at the annual meetings of the Rural Sociological Society, August,1980; Ithaca, New York.

'Who is Rural ? A Typological Approach to the Examination of Ruralism,"

(with M. K. Miller). Paper presented at the annual meetings of the Rural Sociological Society, August,1980; Ithaca, New York.

Discussant of section " Rural Development: Danestic Issues" at the annual meetings.of the Rural Sociological Society, August,1979; Burlington, Vennont.

Discussant of section " Agriculture in Rural Development" at the annual meetings of the Rural Sociological Society, August,1979; Burlington, Vennont.

"The Good Community and Moral Density: A Perspective." Paper pre-sented at the annual meetings of the Rural Sociological Society, August,1979; Burlington Vermont.

"Retirenent and Willingness to Move: A Note," (with L. E. Swanson,,

J r. , and R. H. Warl and). Paper presented at the annual meetins of the Northeast Agricultural Economics Council, June, 1979; Newark, Delaware.

" Migration and Its Impact on the Nonmetropolitan Northeast," (with T. E. Steahr),' Invited paper prepared for the Northeast Agricul-tural Leadership Assembly, March,1979; Cherry Hill, New Jersey.

" Migration to New Hampshire: Preliminary Findings." Paper prepared for New Hampshire Situation and Trends, Supplanent,1979; A Basis for Program Development, Cooperative Extension Service, University of New Hampshire.

Discussant of " Explanations of Social Indicator Differentials," Section

! 25, at the Rural Sociological Society, August,1978; San Francisco, California.

" Critical Information for Community Development Policy Formaul ation:

Absentee Ownership Considerations," (with B. E. Lindsay).

Paper presented at the annual meetings of the Community Develop-ment Society of America, August,1978; Blacksburg, Virginia.

" Economic Opportunities and the Willingness to Move: The Case of Nonmetropolita n Pe nn sylva ni an s," (with L. E. Swanson and R.

H. Warl and). Paper presented at the annual meetings of the Rural Sociological Society, August,1978; San Francisco, California.

" Socioeconomic Impacts on Agricultural Land Use Changes in the North-east," (with D. E. Morris). Paper presented at the annual meetings of the Northeast Agricultural Economics Council, June, 1978; Durham, New Hampshire.

=%.

11 "An Exploration of Social Structure of the Nonmetropolitan Community,"

(with K. S. Ham). Paper presented at the annual meetings of the American Sociological Association, September,1977; Chicago, Illinoi s.

" Community Structure and Interaction: A Synthesized Model of Flood Insurance Adopters." Paper presented at the annual meetings of the Rural Sociological Society, September,1977; Madison, Wisconsi n.

Section Chaiman, " Attitudes and Values in Small Communities," annual meetings of the Rural Sociological Society, September, 1977; Madison, Wisconsin.

Discussant of " Rural Values and Consensus," in section: " Rural ity :

Tetts of an Idea,",at the annual meetings of the Rural Socio-logical Society, August,1976; New York, New York.

" County as a Unit of Analysis: Pennsylvania the Case in Point," (with K. P. Wilkinson). Paper presented at the annual meetings of the Rural Sociological Society, August,1976; New York, New York.

"A Note on Population Size and Community Differentiation," (with C. S. Stokes). Presented at the annual meetings of the Rural Sociological Society, August,1975; San Francisco, California.

"Resuits of a ielephone Suryey of Citizen Responses Relatod to Rural Dev el opment, " Indi ana University of Pe nnsylvani a, Indiana, Pennsylvania, May,1975.

RESEAROi EXPERIENE sExtramural Funding:

A. E. Lul of f, M.K. Miller, Co-princi pal Investigators; " Industrial ization, Ambient Air Pollution, and Death from Respiratory Di seases in the Northeastern United States."

Amount: $10,000.00 Agency: Northeast Regional Center for Rural Development. Time Period: 7/1/86 - 6/3 0/87 L. A. Pl och, T.E. Steehr, Co-princi pal Investigators; "Persistencies and Changes in Socioeconomic Characteristics of Selected Northern New England Towns and Communities."

Amount: $12,993.00 Agency: Northeast Regional Center for Rural Development. Time Period: 7/1/ 86 - 6/3 0/87 A.E. Luloff, Principal Investigator; " Rural People and Places: A Symposium on Typologies."

Amount: $15,000.00 Agency : Northeast Regional Center for Rural Development. Time Period: 1/186 - 12/31/86

y 12.

A. E. Lul of f, T. E. Steah r, .

Co-princi pal Investigators; "The Structure and Impact of Population Redistribution in New England."

Amount $10,525.00 Agency : Northeast Regional Center for Rural i Development. Time Period: 6/1/85 - 4/1/ 86 l l

A.E. Luloff, T.E. Steahr, Co-princi pal Investi gators; "R ur al Pop ulation Growth in New England."

Amount: $8,016.00 Agency : Northeast Regional Center for Rual Development. Time Period: 9/1/85 - 5/31/86

~

P.H. Greenwood, A. E. Lul of f, Co-princi pal Investigators; " Title II Program Eval uation (CETA) Prdect."

Anount: $10,335.00 Agency: Hillsborough County, New Hampshire, Prime t Sponsor ( TA). Time Period: 6/15/79 - 3/25/80.

Additional Experience: ,

Director, " Levels of Mortality and Economic / Social Structure of Counties in the United States." Regional Research Prdect (NE-149) funded by the Agricul tural Experiment Station, Durham, New Hampshire, 10/1/83 -

i 9/30/88.

- Director, " Community and Population Trends in New Hampshire." State Station Prdect (S-297) funded by the Agricultural Experiment Station, Durham, New Hampshire, 10/1/84 - 4/30/88.

Co-Director, " Land Use and Demographic ChanDe in New Hampshire." State Station Prd ect (S-307) funded by the Agricultural Experiment Station, Durham, New Hampshire, 10/1/84 - 9/30/88.

Di rector, " Improving the Distribution of Soci-Economic Resources in Rural I

Area s. " Regional Research PrWect (NE-129) funded by the Agricultural j Experiment Station, Durham, New Hampshire, 10/1/79 - 9/30/83.

l Director, " Impact of In and Out Migration and Population Redistribution in the Northeast. " Regional Research Prd ect (NE-119) funded by the Agricultural Experiment Station, Durham, New Hampshire, 10/1/78 -

9/3 0/ 83 .

FROFESSIONAL ACTIVITIES AND HONORS Sigma Xi Alpha Kappa Delta Ho-Nun-De-Kah -- Cornell College of Agriculture and Life Sciences

, Scholastic Honorary l Member of the Anerican Scciological Association (1974 to 1982); the Southern Sociological Association (1977 to present); the Community Devel opment Soci ety of America (1978, 1980 to present); the Northeast Agricultural Econanics Council (1977 to present); the Rural Soci ol ogical Soci ety (1974 to present); the Population Association of America (1982 to present); the Southwestern Social Science Association (1982 to present).

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13 Service to Rural Sociological Society:

Membership Committee, 1979-80; Ch ai rman, 1981-82; Cochairperson Local Arrangements Committee, Ann ual Mee ti n g s, B u rl i ngto n, V e rmont, 1979; Member of R.S.S. Council (1981-82,1984-85);

Editorial Referee for Rural Socioloav (1977 to present); Associate Editor of Rural Sociol oav (1982-1985); Program Chat man,1985 Member of Community Development Society Journal and Editorial Com-mittee, 1983-1986; Ad Hoc Accreditation Committee, 1984-86; Research Committee,1984 to present Editorial Referee f or Review of Publ ic Da ta Use t Human Oroanizatient Comm uni ty Dev el onm e nt Soci ety t J ournal of the Northeastern Acricul tural Econanics Council.

Vice-President of Northeast Rural Sociological Canmittee (Farm Foundation),1975; Secretary of NEC-24 (Northeast Rural Socio-logical Comittee), 1979-81; 1984-1985; Vice-Chainnan 1985-present Secretary, NE-119 (Population Redistribution in the Northeast, Regional Research Group), 1979-81 Secretary, NE-149 (Levels of Mortality and Economic / Social Structure of Counties in the United States), 1986-88 V i si ti ng Facul ty, Department of Agricul tural Economics and Rural Sociology, The Pennsylvania State University, Sunmer,1981 Member of Computer Advisory Committee to Vice President for Academic Af f ai r s, U niversity of New Hampshire, 1979-1980; Member of Academic Affairs Committee, College of Life Science and Agricul-ture, University of New Hampshire (1979-81), Vice Chai nna n (1979-1980); Member of Community Development Resource Group (Cooperative Extension Service), University of New Hampshire,1980 to present; Member of the University of New Hampshire Advisory Comnittee to the University Press of New England,1980-present Member of Executive Committee, Institute of Natural and Envirorsnental Resources, University of New Hampshire (1978-1981); Member of Quantitative and Statistical Committee (1978 to 1981), Chairman l (1978-1980); Manber of Curricul um Committee, (1979-1981),

i Chai nnan, (1980-1981) i Community Development Program Coordi nator, Institute of Natural and Environmental Resources, Department of Resource Economics and Community Develop ent, University of New Hampshire,1979 to present Co-Advisor of the 1979 Ji Ocean Projects (TEW 697) Drew Memorial htard Winning Research Group "Th e Socioeconomic Response of Coastal Communities to the Fisheries Conservation and Management Act of 1976" Visiting Associate Professor of Rural Soci ol ogy, Northeast Regional l

Center for Rural Development, The Pennsylvania State University, l

J anuary,1986-December 1986 i

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14 REFERENCES Stan L. Albrecht, Dean, Family and Social Sciences, 990SWKT, Brigham Young University, Provo, Utah, 84602 Daryl J. Hobbs, Professor, University of Missouri, Department of Rural Sociology, 812 Clark Hall, Col mbia, MO, 65201 Michael K. Miller, $sociate Professor. of Community Health and Family Medicine, Center for Health Policy Research, Box J-177, J. Hillis Miller Health Center, University of Fl ori da, Gai nesville, FL 32610 Thomas E. Steahr, Professor, University of Connecticut, Department of Agricultural Econan,1cs and Rural Sociology, Storrs, CT 06268 Kenneth P. Wilkinson, Professor, The Pennsylvania State University, Department of Agricultural Econanics and Rural Soci ol ogy, 207 Weaver Building, University Park, PA 16802 9

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AFFIDAVIT NOW COMES Herbert Moyer, being duly sworn, deposes and states as follows:

1. My name is Herbert Moyer and I am a science teacher at the Winnacunnet High School in Hampton, New Hampshire.

2.

I make this affidavit in support of the Town of Hampton's Motion for Summary Disposition in the matter of Public Service Company of New Hampshire Seabrook Station, Units I and II, Docket Nos. 50-443-OL and 50-444-OL.

3. I personally drafted the language in the petition provided to teachers within the Emergency Planning Zone for Seabrook Station which provides: .

"We are the teachers who work at schools in communities within the We DO tenNOT mileaccept EPZ of Seabrook Station.

the conflicting duty which the emergency response (evacuation) plan assigns us.

We believe it is inappropriate to expect us to provide emergency support for our students during a nuclear accident which would simultaneously place our families in" danger."

4. I personally witnessed betwee'n 50 and 100 teachers sign this petition and their signatures appear as part of the signed petitions attached hereto and incorporated by reference herein.

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5. Of the several hundred teachers I have spoken to regarding the issues in the petition, I am personally aware ,

l of .2. teachers who indicated they would carry out their )

duties as assigned under the NHRERP.

Dated: 2.Y,/537 Herbert Mo er

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Personally appeared the above-named Herbert Moyer and .

swore to the truth of the foregoing statements based upon personal knowledge and belief.

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' JAt: T M. l.oTfm !!:t ey PutHe My c:mmis::ca Expir:s.;uly 7, tset k

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