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Correspondence
June 27, 1980

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Case Files, Chisom Hardbacks. Affidavit of Dr. Robert S. Miller (Redacted), 1988. b6322e05-c83e-ef11-8409-000d3a4eea03. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/c7726c91-63bf-40ae-9f74-70793c812d8d/affidavit-of-dr-robert-s-miller-redacted. Accessed April 06, 2025.
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IN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT RONALD CHISOM, et al., Plaintiffs-Appellants, V. BUDDY ROEMER, et al., Defendants-Appellees. AFFIDAVIT OF DR. ROBERT S. MILLER STATE OF LOUISIANA ) PARISH OF ORLEANS ) SS: Dr. ROBERT S. MILLER, being duly sworn, deposes and says: 1. I make this affidavit in opposition to Appellants motion for summary judgement. 2. I am currently President of Market Research and Issues Management, Inc., located in Baton Rouge, Louisiana. A copy of my resume' and relevant professional experience is attached to this affidavit as Appendix A. 3. I have extensive experience in the analysis of voter behavior with particular reference ta voter fall-off, turn-out participation, and voter demographics In Louisiana. Specifically, I have conducted statewide legislative district analyses for the Louisiana Association of Business and Industry, and have participated professionally in more than 70 elections in Louisiana. I have provided voter analysis, targeting, and opinion research for 11 judicial elections and have worked for Sylvia Cooks, a black candidate in the 18th Judicial District, in her most recent judicial election, and Fay Williams, a black candidate in the 8th Louisiana Congressional District. I have worked for eight black candidates in municipal and legislative offices. I have served on the staff of the Department of Experimental Statistics, Louisiana, State University, and I am the political polling and elections consultant to Channel 2, WBRZ television station in Baton Rouge, Louisiana. 4. I was retained by the Louisiana District Judges Association to assist in their analysis of reports prepared by the experts for the State of Louisiana and the plaintiffs in Clark v. Edwards. The State of Louisiana in this case has asked me to present my opinions with regard to those reports analyzing the presence of racial dilution in judicial elections conducted within Orleans Parish. 5. The fact that there is voter polarization does not mean that there is racial vote dilution. In the elections in the First Judicial District involving Lynch and Stewart, in the 19th Judicial District involving Pitcher, and in Orleans Parish involving Morial, Ortigue, and Magee, although there was polarized voting, the black candidate chosen by black voters was elected. While bivariate ecological regression is one method to establish polarization in voting, both sign-in and participation rates must be considered to establish racial vote dilution. 5.1 Sign-in data as available in Louisiana, is an indication that a voter has actually presented himself at a polling place on election day. In Louisiana, this information is recorded for each voter by the dates he has presented himself to vote, as well as his race, precinct where registered, party affiliation, and date of birth. By knowing the dates of the election, the type of office contested (executive, legislative, or judicial), as well as the race of the voter who signed-in, the best evidence is generated to determine voter participation patterns. 5.2 Participation is the choice of the voter to •cast a vote in one or more elections on a single ballot. On a multi-election ballot the number of voters casting ballots for each position to be chosen may vary. The variance in the actual number of black and white voters casting ballots in the same election forms the basis with sign-in data and bivariate regression to establish the presence of racial vote dilution. 6. Bivariate Ecological Regression as used by Engstrom is a procedure to estimate polarization in previous voter behavior. The best data to study specific voter behavior is exit interviews of voters as they leave the polling place. The next best procedure is to use sign-in data as the basis for analysis of voter behavior. A study or experiment should not be designed to suit any particular method. A researcher must be guided by theoretical, practical, and observational demands. Whatever data are generated, should be analyzed by the optimal method of analysis that the researcher can find. A method of analysis should never dictate the measurement, design, and collection of data; this applies to the use of the bivariate procedure by those wishing to document vote dilution. The availability of election day voter participation data by race, (sign-in data), indicates that the bivariate procedures used by Engstrom are not the optimal research procedures to analyze Louisiana elections. Sign-in data is available from State Registrar of Voters. The data used by Engstrom to analyze Orleans elections ignores sign-in data. Engstrom's analysis seeks to test covariational relationships. Typical propositions stating covariational relations are: "The higher the A, the higher the B"; "The higher the C, the lower the D"; and "The lower the E, the lower the F." The first proposition states a positive covariational relation, the second a negative covariational relation, and the third proposition, a reverse of the first, is also a positive relation. Propositions about covariational relations are concerned with co-occurrence of two or more activities. They provide no information about which activity is cause and which is effect. For example, the covariational proposition, "prestige varies directly with power", suggests that a person who has a lot of prestige, however defined, is likely to have a lot of power over others. The proposition does not tell us whether he gains prestige because he is powerful or becomes powerful as a result of his prestige. The problem is that Engstrom's methods are designed not to explain actual voter behavior. Rather, his methods are designed to reach a conclusion that if the results of elections are polarized, then racial vote dilution is to be implied. This methodology, which is based on but two factors (votes per candidate and the race of registered voters, not the race of those who actually voted), factors that are not the best available data, does not enable one to reach valid conclusions about vote dilution. It is my view that the dilution issue has not been proven by Engstrom's analysis. Specifically, Engstrom must show not only the extent to which the electoral preferences of the minority group members differ from those of the rest of the electorate; he must also show the extent to which the level of participation .in the electoral process is lower amongst minority group members than others, leading to minority voters having less opportunity than other members of the electorate (i.e. white voters) to elect candidates of their choice. Engstrom's analysis is based on estimates of behavior of potential voters, where potential voters represent the pool of registered voters in each precinct who may or may not vote in any election on election day. Under Engstrom's logic, potential voters could as easily be minority individuals of voting age, whether they are registered or not. Engstrom's estimates of both votes cast for the black or white candidate and "participation" rates are biased by imputing black voter efficacy. Engstrom assumes that 100$ of black voters desire to vote for every position on a ballot. This establishes the benchmark for black voter behavior at 100$ of registered voters. This is a key bias in one's analysis as both estimates of "participation" and voter percentages are based on a model of total voter participation. The preferred procedure is to measure actual participation and percentages based on the numbers of black and white voters signing in, computing the various roll-off and turn-out percentages, then comparing these percentages to the total voting population, or the potential voting population. 7. The dilution question in judicial elections can not be resolved if drop-off characteristics (whether voters had voted for one item on the ballot but had failed to vote for a judicial post lower down on the ballot) are not considered. Engstrom does not use drop-off data in his analysis. If a voter signs in on election day, he has an opportunity to vote. If the voter does not cast a ballot for a particular post, then that is the voter's choice; the voter still had an opportunity to vote. The results of roll-off can be dramatic. As Fay Williams' pollster during the congressional election, I recall that in the run-off election between her and Clyde Holloway, a white candidate, almost 6,000 fewer voters voted for the congressional position than voted on the same ballot for either U. S. Senate candidates John Breaux or Henson Moore in the Scotlandville area, a 90% black area of East Baton Rouge Parish. As Ms. Williams lost her election by fewer than 6,000 votes, had those voters cast a ballot, Ms. Williams might have won. 8. In Engstrom's double-regression procedure, non-participation rates are based on the pool of potential voters rather than actual voters. The result is that the potential exists to misinterpret voter preferences. For example, the results of the Sylvia Cooks election (an election in which I designed voter targeting objectives), show that when Ms. Cook ran a second time, she received fewer votes (both black and white) than during her first campaign. At the run-off following her second campaign, she received still fewer votes than during the primary. However, the percentages of those black's who did cast cast ballots for Ms. Cook were consistent. This shows that Engstrom's analysis is biased. If one looks at actual voter behavior, one cannot account for election results using Engstrom's procedure. 9. I have reviewed material by Dr. Ronald E. Weber concerning the Louisiana Secretary of State 1987 primary election. Dr. Weber used a precinct-based data base in doing his. statewide analysis. He performed regressions based on the total number of registered voters, not the actual votes cast. Dr. Weber analyzed each precinct in each judicial district and reported his results by judicial districts. I prepared the following figure as a graphic presentation by judicial district of the weighted regression analysis performed by Dr. Weber. As shown in the chart, there is no clear pattern among the estimated voter cast by black voters. From my expert review of Dr. Weber's report, I can conclude that there is no clear pattern among the estimated votes cast by black voters even using Dr. Engstrom's analysis methods. Sometimes the estimated black vote for all white candidates exceeds the estimated black vote for a candidate. Sometimes the estimated black vote for one or more specific white candidate exceeded the estimated black vote for both black candidates. At no time did the estimated black vote for one black candidate uniformly exceed the estimated black vote for any white candidate. I also participated in a district court primary election in the 19th judicial district between McDonald, Pierson, and Clark, a black candidate. In that election, Ms. Clark received substantially less than 50% of the black vote. The majority of black voters preferred Pierson, a white candidate. This shows the fallacy of the assumption that when given a choice, black voters always prefer a black candidate over a white candidate. Therefore, the use of only black/white election contests is flawed. 11. Given that Louisiana has had open primaries since 1976, at which the party affiliation is irrelevant for voting, that single shot voting is allowed; and that I am not aware of any impedimenta to voting sine 1976 in the First Supreme Court Judicial District, I believe that all judicial elections since 1976 should be included in any analysis seeking to to establish that minority voters can not elect candidates of their choice. The analysis prepared by Dr. Engstrom in my view is incorrectly limited to elections with black and white candidates. Dr. Weber examined 191 judicial district court elections (126 majority win, 34 plurality win, 31 run-off win). As shown by the following charts, which I prepared using Dr. Weber's data, it appears clear whether one looks at the results statewide by district, or statewide by year that black voters have elected candidates of their choice more often than not. Sworn to and Subscribed Before me this 541' d of Augu Act- 1-17,41310. Contested Majority win Elections for Louisiana District Judge Categorized by Preferences of Minority Black Voters by Year of Election (1976-1988) 70— so- T 50— A X 40- - 30- 20— . 10— o .5 of Elections Where Winner is Preferred by Minority Bloc X of Elections Where Winner is Not Preferred by Minority Bloc 2 3 4 6 7 8 9 10 11 DISTRICT 12 13 II 17 18 19 20 21 22 23 24 252827 282930 31 32 33 DISTRICT 34 35 35 37 38 39 40TOTAL Tab 1.2b 100 90 so E • 70 C • 60 T • 50 A 6 E 40 X 30 20 10 0 Contested Runoff Melons for Louisiana District Judge Categorized by Preferences of Minority ElWA( Voters by Year of Election (1970-1968) X of Elections Where Winner is Preferred by Minority Bloc X of Elections Where Winner is Not Preferred by Minority Bloc 1 2 3 4 5 6 7 8 9 10 11 DISTRICT 12 13 14 15 16 • 17 18 19 20 21 22 23 24 25 26 27 29 29 .30 31 32 33 34 DISTRICT 35 36 37 38 39 40TOTAL Tab lee 100T 90- 90— . P E iu— C 60— E T • 50— A 8 E • 30- - 20- 10 — o Contested Plurality win Elections for Louisiana District Judge Categorized by Preferences of Minority Black Voters by Year of Election (1976-1988) X of Elections Where Winner is Preferred by Minority Bloc X of Elections Where Winner is Not Preferred by Minority Bloc 2 3 4 5 6 7 8 9 10 11 12 13 DISTRICT 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 DISTRICT 34 35 36 37 39 39 40 TOTAL Table* 100— . 90— . 60-r 60- 40-r 20— . 10— . 0 Summary Of Judicial District By X Of Black Votes Weighted Regression Analyses - Secretary Of State Lombard. Rivers, and All Other White Candidates Lombard Rivers White Candidate Total ,IJ V A 2 3 4 5 6 7 8 9 10 11 12 13 14 JUDICIAL DISTRICT 19 20 21 22 23 24 25 26 • di 27 al 29 30 31 32 33 34 53 36 37 38 39 40 Or. Civil JUDICIAL DISTRICT abV Robert S. Miller (504) 344-6023 PROFESSIONAL PROFILE EDUCATION: Ph.D, Marketing, Louisiana State University, 1979 MS, Experimental Statistics, Louisiana State University, 1975 MSW, Social Welfare, Louisiana State University, 1972 BS, Psychology, Louisiana State University, 1970 WORK HISTORY: 1977 - 1988 President, Miller Associates, Inc., Market Research and Issues Management Consultants 1975 - 1977 Director (Part-time), Governor's Pardon Parole and Rehabilitation Commission, State of Louisiana 1975 - 1977 Vice President, International Systems Limited PRINCIPAL RESPONSIBILITIES AND CONSULTING ASSIGNMENTS: Governmental/Community Relations - Opinion research, public relations programming, legislative, and press relations, crisis management, issues forecasting services provided to the Louisiana Chemical Association, Louisiana Association of Business and Industry, Chemical Manufacturers Association, and 18 chemical manufacturers in ten states. Health Care - Regional and national health care studies for AMI, Health-America, National Medical Enterprises, and employer groups looking toward cost containment and service packaging. In addition, participated in 37 health related studies in 12 states regarding product line management, service offering, and pricing. Market Research Services - Includes economic impact, feasibility and attitudinal studies for a diverse group of clients. Included in this group are services for the financial industry, consumer product goods, and the media. Study's dealt with product adoption', consumer trade-offs, and distribution. A substantial amount of activities have been directed toward chemical product marketing. Political Polling - Participated in more than 100 elections, including substantial services for the Louisiana Association of Business and Industry. Currently completed surveys for current members of the Legislature, as well as services for a variety of print and broadcast enterprises in Louisiana. CIVIC AND PROFESSIONAL ACTIVITIES: A. Currently serving on: Board of Trustees, Louisiana Arts and Science Center Board of. Directors, Louisiana Jewish Federation Board of Directors, Greater Baton Rouge Chamber'. of Commerce Board of Directors, L/PAC (Louisiana State University System Political Action Committee) Board of Directors, LASPAC, AIPAC Founder, Champac Facility Political Training Institute - Greater Baton Rouge Chamber of Commerce B. Memberships include: The American Marketing Association The Market Research Association Opinion Research Association The American Association of Political Consultants National Network of State Polls C. Volunteer work for the following organizations: Baton Rouge Symphony Hospice Foundation Battered Childrens Foundation YMCA East Baton Rouge Parish School Board Capital Area United Way TAC/AAU Youth Track Episcopal High School Catholic High School Champac Greater Baton Rouge Chamber of Commerce Sewerage Planning Committee CORPORATE CLIENTS The following represents a partial listing of corporate clients segmented by industry: Medical Institutions American Medical Enterprises, Beverly Hills, California Ault Chiropractic Clinics, Baton Rouge, Louisiana General Health Systems, Baton Rouge, Louisiana Baton Rouge Chemical Dependency Unit, Baton Rouge, Louisiana Central Georgia Eye Care Center, Macon, Georgia Central Indiana Eye Institute, Kokimo, Indiana Cleveland Clinic, Cleveland, Ohio Drs. John Cooksey &.Priscilla Perry, Monroe, Louisiana East Jefferson General Hospital, Jefferson, Louisiana EmergiCenter, Pensacola/Fort Walton, Florida Eye Care and Surgery Center, Baton Rouge, Louisiana Eye, Ear, Nose and Throat Hospital, New Orleans, Louisiana F. Edward Hebert Hospital, New Orleans, Louisiana Forrest General Hospital Havins Eye Clinic, Las Vegas, Nevada HealthAmerica, Baton Rouge, Louisiana Humana Sunrise Hospital, Las Vegas, Nevada Jo Ellen Smith Medical Center, New Orleans, Louisiana Lane Memorial Hospital, Zachary, Louisiana Louisiana State Medical Society, New Orleans, Louisiana Louisiana Nursing Home Association, Baton Rouge, Louisiana Mary Bird Perkins Radiation Center, Baton Rouge, Louisiana Meadowcrest Hospital, New Orleans, Louisiana Medivac Mercy Hospital, New Orleans, Louisiana Northshore Medical, Slidell, Louisiana Ochsner Medical Center, New Orleans, Louisiana Ochsner Clinics, Baton Rouge and New Orleans, Louisiana 011ie Steele Burden Retirement Center, Baton Rouge, Louisiana Our Lady of the Lake Regional Medical Center, Baton Rouge, Louisiana Palms of Pasadena Hospital, St. Petersburg, Florida • ' • *:. • : S Singing River Hospital - Pascagoula, Mississippi Touro Infirmary, New Orleans, Louisiana Tulane University Hospital, New Orleans, Louisiana UCLA Medical Center, Los Angeles, California Woman's Hospital, Baton Rouge, Louisiana Financial Institutions Bank of New Roads, Louisiana Britton and Koontz- Bank, Natchez, Mississippi City National Bank of Baton Rouge First Allied Bank of Baton Rouge First Bank of St. Tammany, Louisiana First Financial of Ascension, Lutcher, Louisiana First National Bank of Commerce, New Orleans, Louisiana First National Bank of Denham Springs, Denham Springs, First National Bank of Jefferson, New Orleans, Louisiana First National Bank of Port Allen/St. Tammany, Port Allen First National Bank of Shreveport, Shreveport, Louisiana First Savings of Louisiana, LaPlace, Louisiana Guaranty Bank of Alexandria, Alexandria, Louisiana Guaranty Bank of Lafayette, Lafayette, Louisiana Guaranty Bank of Hammond, Hammond, Louisiana Jeff Davis Bank and Trust, Jennings, Louisiana Livingston Bank and Trust, Denham Springs, Louisiana Louisiana Bancshares, Incorporated, Baton Rouge, Louisiana Louisiana National Bank, Baton Rouge, Louisiana Merchants National Bank of Mobile, Alabama National Bank of Commerce, Jefferson, Louisiana NEAR Network - LINC Switch, Baton Rouge, Louisiana Ouachita National Bank, Monroe, Louisiana Patterson State Bank People's Bank and Trust of Iberia Parish, Louisiana Security Homestead, New Orleans, Louisiana Southern Savings, New Orleans, Louisiana Louisiana , Louisiana • 1'7. v.71,77i.. • ':11r.r:•:'#:.'.7.f.:7-.4t 7:r. s1.7 t • : • 4 • .7777,: 77— Political Research/Polling Richard Baker, Congressional Campaign • Larry Bankston, Baton Rouge Councilman & Senate Butch Baum, Governor Howard Beck, State Senate Campaign Pat Bergeron, School Board Leon Borne - House District 55 Senator Bill Bradley, New Jersey Environmental Issues Armand Brinkhaus - Senate District 24 Jim Brown, Governor James David Cain, Congressional campaign Leonard Charbert - Senate District 20 Sylvia Cooks, Judge - 15th Judicial District Archie Crosby - House District 18 Mike Cross, State Senator Tony D'Angelo, Mayor Joe Delpit, Representative Salvador Diesi - House District 40 Hunt Downer - House District 52 Jack Doland - Senate District 26 John Ensiminger - House District 14 Representative James Florio - New Jersey Environmental Issues Bobby Freman, Lieutenant Governor/Congress Davin Ginn - Senate District 35 Jessee Guidry - House District 54 Paul Hardy, Lieutenant Governor William Hays, City Commissioner, Mobile, Alabama Murray Hebert - House District 53 Ted Hicks, EBR Assessor's Race Jiff Hingle, Sheriff, Plaquemines Parish Senator Fritz Hollings - South Carolina Lynda Imes, Baton Rouge Council Race Grady Kelly, Sheriff, Rapides Parish Donald Ray Kennard, House Representative Carson Killen, Congressional race Leonard Knapp, District •Attorney, Lake Charles ' Raymond Laborde, House Representative Raymond LaLonde - House District 39 Leon Langley, Council Race, New Orleans Buddy Leach - House District 30 Sam LeBlanc, Mayor's Race, New Orleans, Louisiana Conway LeBleu - House District 36 Richard Lee, Judge, Alexandria, Louisiana Danny Lemoine - House District 38 Sheriff Elmer Litchfield, East Baton Rouge Parish Gillis Long, U.S. House of Representatives Margaret Lowenthal - House District 35 Bruce Lynn, House Representative Jimmy Martin - House District 37 Jim McCrery, Congressional Campaign Bill McLeod - Senate District 27 Representativgs Henson Moore - United States Senate Race George Mustakas,.Congressional Campaign Richard Neeson, Representative Cliff Newman - Senate District 26 Jewel Newman, Representative/City Council B. R. O'Neal - House District Senator Robert Packwood - Oregon environmental issues Mary Olive Pierson - District Judge Pat Screen, Mayor-President, East Baton Rouge Parish Weldon Russell - House District 72 John Saunders - Senate District 28 John Smith - House District 30 Stewart Thomas, District Court Judge, Jefferson Davis Parish Frances Thompson - House District 19 Sandra Thompson Clerk of Court Race, East Baton Rouge Parish John Travis - House District 62 Richard Turnley, State Senator Faye Williams, Congressional Campaign Ed Watson, Mayor's Race in Lake Charles, Louisiana Peggy Wilson, Council Seat, New Orleans, Louisiana —fr3II1,1-:' • :11r: tissz Nr4,—;%.%; r. rim •sd . • • • Corporate Market Research Acadiana, Inc., Lafayette, Louisiana Affiliated Foods, Lafayette, Louisiana Back Store Jim Bailey, Baton Rouge, Louisiana Balfour, Baton Rouge, Louisiana Baton Rouge Broadcasting (WJBO/WFMF), Baton Rouge, Louisiana Baton Rouge Business Report, Baton Rouge, Louisiana Baton Rouge Magazine, Baton Rouge, Louisiana Boardwalk Title Company, Baton Rouge, Louisiana Bon Marche Mall, Baton Rouge, Louisiana Brown, Koff, & Fried, Butch Baum, Inc., Baton Rouge, Louisiana Cablecast, Baton Rouge, Louisiana Camp-Carmouche, Washington D.C./Baton Rouge, Louisiana Cellular-One, Baton Rouge, Louisiana Community Coffee Place, Inc., Baton Rouge, Louisiana Computer Communications Decision Center Delta Companies Delta Health Network Delta Queen, New Orleans, Louisiana Guaranty Broadcast Corporation, Baton Rouge, Louisiana J. U. Blanchard & Co. Louisiana Dairy Board, Baton Rouge, Louisiana Louisiana State Newspapers, Lafayette, Louisiana Mid-Continent Oil & Gas New Orleans Hilton Santa Maria Development Corporation, Baton Rouge Louisiana sit 7.: .1...r:TM ITVMIT.' •:•". L'•"7..! '',"" "::tr-r"!..• • A'sf 74;gw, f7;`A.1- :* 7:eV s. •71r1'( Speedy Oil Change, Baton Rouge, Louisiana Struman & Associates, Jimmy Swaggart Ministries, Baton Rouge, Louisiana National Food Stores, Lafayette, Baton Rouge, Louisiana Tiger Rag Magazine, Baton Rouge, Louisiana TJM Corporation, New Orleans, Louisiana Tulane University, New Orleans, Louisiana Warner Communications, New York, New York Westminster Corporation, New Orleans, Louisiana Weylock & Associates Whites Auto Parts William B. Reily Company (Luzianne Coffee/Blue Plate Mayonnaise) Witter Enterprises Wolf's Sunbeam Bakery, Baton Rouge, Louisiana WRBT TV - Channel 33, Baton Rouge, Louisiana Public Agencies, Non-Profit and Trade Associations Baton Rouge Alliance for Good Government Baton Rouge Chamber of Commerce Champac Chemical Manufacturers Association, Washington, D.C. Council for A Better Louisiana East Baton Rouge Parish School Board, Baton Rouge, Louisiana Education for a Better Louisiana, Baton Rouge, Louisiana Educational Testing Service, Princeton, New Jersey Faucheux - Farwell Associates James H. Gill, Jr., Baton Rouge, Louisiana Gulf South Research Institute (including Livingston derailment issue) Louisiana Association of Business and Industry Louisiana Association for Retarded Citizens Louisiana Chemical Association Louisiana Department of Commerce and Industry Louisiana Department of Education Louisiana Learning Center Louisiana Nursing Homes Louisiana Office of Tourism i".:.:?•"et •••- •-• iv; • ',II-C.-Y.1'.• - •• • . • • • , • Louisiana Public Facilities Authority Louisiana Retail Association Louisiana School Boards Association Louisiana State Medical Society New Orleans Chamber of Commerce New Orleans Gaming Commission Office of Mental Retardation, State of Louisiana Public Affairs Research Council, Baton Rouge, Louisiana Volunteers of America Corporate Governmental Affairs - Chemical Companies Air Products, Inc. Armtech (Armstrong) BASF Borden Chemical CIBA-GEIGY Corporation Copolymer Dow Chemicals, USA Dupont Exxon Chemicals, USA Melamine Chemicals, Inc. Monsanto Shell Oil Company Vulcan Chemical Waste Management, Inc. '4.‘11.1147Mr2rts',v-tril•f!.‘:•vit.1.t. " ''......'1"‘"E‘."Sr "."!‘"':'...:1"7-''