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Attorney Dill next introduced Ronald Cotterill, a Professor of <br />Agriculture Economics and the Director of the Food Marketing Policy <br />Center at the University of Connecticut, who gave the following <br />presentation. (Exhibit E) <br />AFFmAyrr OF PROFESSOR RONALD W. COTTERILL <br />STATE OF CONNECTICUT ) <br />COUNTY OF TOLLAND ) <br />RE: Appeal of Indian River County Planning and Zoning Commission Staff <br />determination that Supermarkets and Grocery Stores are synonymous and an <br />economic analysis of the Sea Mist Shoppes Proposal. <br />I, RONALD W. COTTERILI, being duly sworn, state: <br />1. That I am the Director of the Food Marketing Policy Center and a Professor of <br />Agricultural Economics at the University of Connecticut. I am the Executive <br />Director of an International Food Marketing Research consortium that includes <br />research economists from more than 22 universities in the U.S., Canada, the <br />U.S.D.A., the E.P.A., the F.D.A., and the General Accounting Office of the U.S. <br />Congress. I have written numerous books, journal articles, reports and papers on <br />the organization and performance of food industries. Food retailing is my special <br />area of expertise. Among other projects I have contracted with the Bureau of <br />Census to obtain special data to analyze supermarkets and grocery stores in all <br />standard metropolitan areas in the U.S.' My curriculum vita is attached to this <br />Affidavit as Exhibit "A". <br />2. The Moorings Concerned Residents has requested that I, a) explain exactly how <br />the Standard Industnal Classification (SIC) Code defines food stores including <br />grocery stores and supermarkets; b) define and determine whether supermarket <br />and grocery store are synonymous terms and c) determine whether, from an <br />economic perspective, the proposed Sea Mist Shoppes Development violates the <br />Indian River County Zoning Code. <br />3. The basis for my conclusions includes: my prior research and knowledge of the <br />food retailing industry, a set of documents (listed in Exhibit "B") furnished by <br />Moorings Concerned Residents and their retained legal counsel, Warren W. Dill, <br />trade and government publications, interviews with Bureau of Census staff, and <br />market area data for Vero Beach and Indian River County assembled under my <br />direction by Mr. Gene Winne and Mr. John W. Zilg of Moorings Concerned <br />Residents. <br />'Andrew W. Franklin and Ronald W. Cotterill, "An Analysis of Local Market Concentration <br />Levels and Trends in the U.S. Grocery Retailing Industry", Food Marketing Policy Center Research <br />Report No. 19, University of Connecticut, May 1993, 108 pages. <br />28 <br />July 12, 1994 <br />