UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

________________________________

NATURAL RESOURCES )

DEFENSE COUNCIL, et al. )

)

Plaintiffs, )

)

vs. ) Civil Action NO. 97-936(SS)

)

FEDERICO PENA, et al. )

)

Now comes William J. Weida, who deposes and says that:

I am an economist presently associated with The Colorado College, 14 E. Cache La Poudre, Colorado Springs, Colorado.

A true and accurate description of my professional qualifications, experience, and publications is attached to this AFFIDAVIT as Exhibit A;

At the request of plaintiff Natural Resources Defense Council, I have examined the claims made by defendant Department of Energy (DOE) and its contractor personnel at Argonne National Laboratory (ANL) concerning the regional economic impacts of the project known as the National Ignition Facility (NIF).

The documents that are the subject of this affidavit are a) the "Technical Documentation in Support of the Draft-Specific Analysis for construction and Operation of the National Ignition Facility, ANL/EAD/TM-63, Environmental Assessment Division, Argonne National Laboratory, United States Department of Energy, September, 1996, and b) " Impacts Assessment For The National Ignition Facility", Bay Area Economics/M. Cubed, December, 1996.

As a result of this review of DOE/ANL claims and my own investigation and calculation, I reach the following conclusions regarding the validity of the statements made by DOE in their response to this Civil Action:

a. Page 16, para. 31. DOE mentions, but does not respond to the issue of the size of the socioeconomic impact other than to cite DOE’s response to comments provided three years ago. My report demonstrates that the DOE response was inadequate and nothings in DOE’s response in this paragraph challenges that.

b. Page 17, para 32. DOE’s response simply misses the point. At issue here are regional economic impacts and regional economic analysis. For an EIS to be adequate, the socioeconomic impact of a proposed project on the region in which it is located must be addressed. A BEA region is established precisely because it represents a cohesive regional entity in which the effects of economic impacts may be calculated. To combine two or more of these regions, as is done in the ANL report, makes no more sense on a regional basis than discussing the impact of a national economic issue like Social Security by using a model that included the US, Canada, and Mexico. Thus, the use of more than one economic region is not "objective" as the DOE response claims, it is a subjective choice that goes beyond the intent and construction of the BEA models.

As opposed to the DOE comments, Metropolitan Statistical Areas (MSAs) were established specifically to account for the new regional economic effects that resulted when metropolitan growth transcended the boundaries of the counties in which metropolitan area was situated. If such relationships had also developed in the areas that ANL arbitrarily chose for their study areas, those relationships would have been noted by the BEA and similar areas would have been established. In this sense, ANL’s areas are not based on a "stricter economic definition" of the region but, rather, on an ad hoc selection of various regional entities.

c. Page 18, para. 33. DOE’s response appears to agree with the points in my paper. The regional area for LLNL is San Francisco, as my paper claims and as DOE recognizes in this paragraph, not an ad hoc area that stretches from near the Oregon border to north of Los Angeles.

d. Page 18, para. 34. Again, DOE misses the point. The reason for an EIS is to determine the impact of the proposed facility on the region, not to determine the impact of the region on the facility. By using percentage of workforce as the cutoff for considering areas of impact, the ANL did not account for sparsely settled regions where a small percentage of the workforce may account for a large amount of the employment in the region. This is the case in New Mexico where Sandia and Los Alamos employ workers from sparsely settled counties with large amounts of unemployment. A casual inspection of travel-to-work data from the 1990 census shows that while ANL’s regional designations make no sense for New Mexico, they conveniently do make the case for California where the factors of sparse population and extreme unemployment are missing.

e.Page 19, Para 36. The use of induced effects is neither clear-cut nor extensively accepted as this paragraph implies. They have been used on a number of public projects by organizations such as ANL, but those uses are usually contentious, just as this one is. In fact, even the Bay Area Economics/M. Cubed report states that "Argonne’s definition of direct and indirect effects is different than that used for other I/O models." ANL should have specifically stated which were induced effects and which were indirect employment effects rather than mixing the two, and DOE should know that this is the only way to accurately protray the data.

FURTHER AFFIANT SAITH NAUGHT.

I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief, and that this declaration was signed on the 15th day of June, 1977, in McCall, Idaho.

William J. Weida

Exhibit A

The Colorado College Colorado Springs, CO 80909

Colorado Springs, CO 80903 719-596-7492

719-389-6409

D.B.A., Econometrics and Operations Research, UNIVERSITY OF COLORADO, 1975

M.B.A., Management Theory, UNIVERSITY OF CALIFORNIA AT LOS ANGELES, 1966

B.S., Engineering, UNITED STATES AIR FORCE ACADEMY, COLORADO, 1965

Jan. 1997- Project Director, Global Resource Action Center For The Environment

Present and Professor, Dept. of Economics, The Colorado College, Colo. Springs, CO

May 1993- National Director, Community Education Campaign, Nuclear Site

Dec. 1996 Cleanup and Conversion, Economists Allied for Arms Reductions and

Professor, Dept. of Economics, The Colorado College, Colorado Springs, CO

June 1990- Professor and Chair, Department of Economics & Business,

June 1993 The Colorado College, Colorado Springs, CO

Aug. 1985- Professor and Co-Chair (1988-1990), Assoc. Prof. (1985-1988)

May 1990 Dept. of Economics & Business, The Colorado College, Colorado Springs, CO

Mar. 1982- Director (1984-1985) and Asst. (1982-1984) for Econ Policy and Analysis

July 1985 OASD/ISA, International Economic and Energy Affairs, Pentagon

Feb.-Sept. Economist, Blue Ribbon Commission on Security & Economic Assistance

U.S. AIR FORCE ACADEMY, COLORADO, Department of Economics

June 1981- Professor and Acting Head

June 1978- Associate Professor and Director of Instruction

June 1972- Doctoral Candidate, University of Colorado

Jan. 1975

Jan. 1970- Instructor, U.S. Air Force Academy Department of

June 1972 Economics

June 1965- Professional assignments as an officer and

Jan. 1971 pilot, U.S. Air Force.

Selected journal articles: "General Weapon Expenditure Forecasting with Risk as a Determinant of Development Time," The Journal of Technology Transfer, 1981, "Military Weapon Systems Expenditures and Risk: Theory and Evidence," International Journal of Social Economics, 1985 (with Dr. Frank L. Gertcher), "The Ethics and Economics of Foreign Sales of U.S.-Made Weapons," International Journal of Social Economics, London, 1986.

Books: Paying for Weapons: The Politics and Economics of Offsets and Countertrade, Frost and Sullivan, 1986; The Political Economy of National Defense, Westview Press, 1987 (with Dr. Frank L. Gertcher); Beyond Deterrence: The Political Economy of Nuclear Weapons, Westview Press, 1990 (with Dr. Frank L. Getcher); Substituting Employment From Environmental Cleanup Of Defense Facilities For Jobs Lost Through Disarmament, in Jurgen Brauer and Manas Chatterji, (ed.), Economic Issues of Disarmament, MacMillan Co., December, 1992; The Political Economy of Nuclear Weapons and Economic Development after the Cold War, in Akira Hattori, ed., Disarmament and Restructuring of the World Economy After The End Of The Cold War, Tokyo, Japan, May 20, 1994; Nuclear Weapons and Economic Development, in Chatterji, Fontanel and Hattori, eds., Arms Spending, Development and Security, Ashish Publishing House, New Delhi, India, May, 1996. Forthcoming: Regaining Security--A Guide to the Costs of Disposing of Plutonium and Highly Enriched Uranium, Asbury Press, London, 1997.