** 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 88-1886-CIV-HOEVELER UNITED STATES OF AMERICA, et al, ) ) Plaintiffs, ) ) vs. ) ) SOUTH FLORIDA WATER MANAGEMENT ) DISTRICT; JOHN R. WODRASKA, ) EXECUTIVE DIRECTOR, SOUTH FLORIDA ) WATER MANAGEMENT DISTRICT; FLORIDA ) DEPARTMENT OF ENVIRONMENTAL REGU- ) LATION; AND DALE TWACHTMANN, ) SECRETARY, FLORIDA DEPARTMENT OF ) ENVIRONMENTAL REGULATION, et al, ) ) Defendants. ) ___________________________________ ) - - - - - - - - DEPOSITION OF ROBERT BROWN, III, THE WITNESS, TAKEN ON BEHALF OF THE PLAINTIFFS - - - - - - - - DATE: August 24, 1990 PROFESSIONAL REPORTING SERVICE Suite 303, 324 Datura Street West Palm Beach, Florida 33401 (407) 659-4046 ** 2 I N D E X August 24, 1990 DIRECT CROSS ROBERT BROWN, III By Ms. Nash 5 By Mr. Richards 29 ** 3 The deposition of ROBERT BROWN, III, the witness, in the above-entitled and numbered cause, was taken before me, DONNA McCALLEY, Registered Professional Reporter, and Notary Public for the State of Florida at Large, at Suite 110, 324 Datura Street, in the City of West Palm Beach, County of Palm Beach, in the State of Florida, beginning at the hour of 9:59 a.m., on Friday, the 24th of August, 1990, pursuant to the Notice in said cause for the taking of said deposition, which is annexed to the court file herein, on behalf of the Plaintiffs in the above-entitled action pending in the above-named court. The appearances at said time and place were as follows: UNITED STATES DEPARTMENT OF JUSTICE Room 868, 601 Pennsylvania Avenue, N.W. Washington, D.C. 20044-0663 Attorneys for the Plaintiffs, U.S.A. By BEVERLY SHERMAN NASH, ESQ. PEEPLES, EARL & BLANK, P.A. Suite 3636, Two South Biscayne Boulevard Miami, Florida 33131 Attorneys for the Cities of Belle Glade and Clewiston By JOSEPH RICHARDS, ESQ. SKADDEN, ARPS, SLATE, MEAGHER & FLOM 1440 New York Avenue, N.W. Washington, D.C. 20005-2107 Attorneys for the South Florida Water Management District By KATHARINE STOLLMAN, ESQ. ALLISON BURDETTE, ESQ. ** 4 APPEARANCES CONTINUED: ALSO PRESENT: Toni Lafuente Ray Roberts David Buker Frank Draughn ** 5 THEREUPON: ROBERT BROWN, III, having been first duly sworn, as hereinafter certified, testified as follows: DIRECT EXAMINATION BY MS. NASH: Q. Please state your name. A. My name is Robert Tillman Brown, III. Q. Mr. Brown, I'm Beverly Nash, and I represent the United States in this litigation. And we're here to try and understand what computer systems the water management district has, how they're set up, how people in the district both communicate internally and externally using the computers, how data is stored on the computers, how it's formatted, and you're here today as a representative of the district having knowledge of one or more areas. Were you shown the list of categories that we submitted? A. Yes, I was. Q. And what categories are you here as a representative? A. Four, five, six, and nine. Q. What is your present title or position? A. I'm the director of the Geographic ** 6 Sciences Division. Q. And what is your job description? A. I manage both technically and administratively the division which collects and manipulates various spatial data using computers. Q. And how long have you been director of the Graphic Sciences Division? A. Approximately 13 years. Q. Have you had other position at the water management district? A. Yes, I have. Q. What position were those? A. I was a supervisory professional in the Land Resources Division. I worked as a geographer in the Environmental Sciences Division, and originally came as a research assistant/geographer. Q. How long were you a supervisor or professional in the Resources Land Division? A. Approximately three or four years. Q. And what were your job responsibilities there? A. To supervise the planning staff and the technical staff who prepared maps. Q. And how long were you a geographer in the Environmental Sciences Division? ** 7 A. Approximately three years. Q. And what were your job responsibilities as a geographer? A. My responsibilities in that division were to perform mapping functions for or in support of the biologists and their various projects. Q. And how long were you a research assistant/geographer? A. I'm not sure exactly. I'd say several years. Q. What were your responsibilities in that position? A. Again, we prepared primarily land-use maps in support of other projects. Q. What is your educational background? A. I have a Bachelor of Science in physical geography and have completed some graduate work in public administration. Q. Who is your supervisor? A. My supervisor is John Lynch, the department director of technical services. Q. The Geographic Sciences Division is part of the Technical Services Department? A. That's correct. Q. Do you have employees that work for you? ** 8 A. Yes, I do. Q. How many? A. Six. Q. What are their names and job descriptions? A. My systems manager, who admin--or manages the computer systems from a technical standpoint is named Nancy Lynn. She's been with us approximately three weeks and is just getting familiar with the systems. And working for her are five technicians who actually do the hands-on computer work and mapping. Q. What are their names? A. Jimmy Kramp, K-r-a-m-p, Judy Canada, Terry Bennett, Cecilia Conrad--and let's see who I've left out, John Stockum, S-t-o-c-k-u-m. Q. What computers does the Geographic Sciences Division utilize? A. We use IBM Personal System 2's. We have three of those. We use a Computer Vision CADDS system. And we have also a Computer Vision system which runs on a Sun work station. That's the hardware. Q. What software does the Geographic Sciences Division have--utilize? A. We use the Computer Vision CADDS software. That's C-A-D-D-S. We use AUTOCADD, ARC/INFO, a package called CADSI, and the various standard packages that ** 9 the district uses for word processing. Q. What are those standard packages? A. Word Perfect and various text editors contained in the operating systems, such as Egland for dos, the VI Editor in UNIX. Q. Any others? A. No. Q. What work of your division is done on the IBM System 2's? A. We have a software package called PC ARC/INFO, which is a geographic information system package. Approximately 80 percent of our work is done on those systems. I really can't describe the specific projects because we do approximately 30 to 40 a month. Can't recall any specifics. Q. Is there someone who can describe the specifics projects? A. The technicians themselves probably could describe them. Q. Is there a list of the projects that are--have been done on the IBM PC's using this PC ARC/INFO software system? A. Yes. Q. Does that list have a name? ** 10 A. No. Q. What work is done on the Computer Vision CADDS system? A. Primarily mapping applications using polygon processing; and more specifically, processing of land-use maps. Q. What are the mapping applications to which you refer? A. It's quite a wide range. Do you want me to describe all of the applications? Q. Yes. A. The Computer Vision system was purchased in 1977. The first project that we performed using the system was to digitize the USGS seven-and-a-half minute quad sheets. We created a data base of maps for the entire district, 351 7.5 minute quad sheets. This served as a base for displaying all, many other types of spatial data. Following that, we mapped and digitized land use for our entire district, and most of the projects involved a manipulation of those data in some fashion, either tabulating them for specific areas or reselecting them for certain land-use types. Q. Any other mapping applications? A. Computer Vision system was also used to ** 11 create a monthly isohyetal rainfall map for the district. That--those projects were begun seven or eight years ago, have become a standard product which we produce. Mapped other information, such as point information for well locations and data collection sites, various three-dimensional surfaces representing land elevations using the digital terrain model module of the Computer Vision system. Q. You mentioned that the system creates monthly rainfall maps? A. Yes. Q. Where is the data--where does the data come from to create those maps? A. The data are collected from various rainfall stations throughout the district, either administered by the weather bureau or the district or private observers. The data are compiled, I believe, in the water resources division. A draft of the isohyetal map is created and the geographic sciences division digitizes it, superimposes it on the base map information which I described earlier. Q. So the base map you're referencing is the digitized USGS quad sheets? A. That's correct. ** 12 Q. Is that the base map used for all projects done in the division? A. It has been the base map information used for most of the projects until, say, the last two months. Q. What has been used in the last two months? A. We are transitioning to the USGS DLG files and the USGS and Census Bureau Tiger files as our base maps. Q. What procedure or system is used to transfer data files from one division to another? You indicated that the rainfall data is compiled by the Water Resources Division. How is it transferred to your division? A. For that particular project, the draft rainfall map is created on another system, and I'm not sure which system it is. But the product that's created is a plotted draft of the contours representing rainfall. That paper plot is what is then transferred to us, and our technicians trace the contours into the system and superimpose them on the base map. Q. That's a manual process? A. The digitizing is a manual process, yes. Q. Do you have a list of what is on the Computer Vision CADDS system? ** 13 A. Yes, we do. Q. In what form is that list? A. The--the one list which I'm thinking of is a Word Perfect file, which at this point in time is not the most current information. We use a on-line cataloging system to search for specific files, and that's a dynamics process that does not create hard copy files. Q. Where is that on-line catalog system, where is that located? A. That's on the Computer Vision system. Q. And does that on-line catalog system have a name? A. No, it doesn't. Q. Does your division utilize image-processing systems? A. No. Only indirectly in that we're exploring the possibility of using some of the products from the image processing system. Q. Do you know whether other segments of the water management district utilize image processing systems? A. Yes, I do. Q. And what sections of the water management division--districts would that be? ** 14 A. The Environmental Sciences Division uses an image analysis system called I squared S or International Imaging Systems. The planning department has software called ERDAS, E-R-D-A-S, and they are developing prototype applications for image processing. Q. Does Geographic Sciences Division utilize what I believe is called Geographic Information System, GIS? A. Yes, we do. Q. Describe the system the division uses. A. The system we use is called ARC/INFO. It's a product of a company called ESRI in Redlands, California. The system is a combination of graphic displays of mapped information and a relational data base package. Q. What is the source of the information in that system? A. Most of the data used in the ARC/INFO system is obtained from the data which was originally stored in the Computer Vision system. Q. Is there data obtained from elsewhere, also? A. As I described before, the base map information is obtained from the U.S. Geological Survey. That's--that's all. ** 15 Q. You also testified earlier that your division utilizes a Computer Vision system that runs on Sun work stations? A. That's correct. Q. What work is done on that Computer Vision system? A. The same types of applications that I described on the older Computer Vision system. The data are transferred over to that system and processed using the enhanced capabilities of the more modern work station. Q. What are the features of these enhanced capabilities? A. Primarily faster processing speed, greater disk capacity, and multi-tasking capability of the UNIX operating system. Q. Are there what is referred to as map layers on your GIS system? A. They're commonly referred to as map layers, don't actually exist in the ARC/INFO system. The layering concept is primarily a computer-aided design system concept. The layering normally is something that exists within a single CADDS data file where you can turn off certain layers and turn on other layers to represent the data that you're working with. ** 16 In the GIS systems, each theme or type of data exists as a separate map coverage or set of files, and then those can be combined in any fashion that you need. Q. And so that I'm clear, the data in the GIS system, you indicated, comes from the Computer Vision system by and large? A. (Witness nods.) Q. And the data going into the Computer Vision system is from the Water Resources Division? A. The data from Water Resources Division is only the rainfall data. Q. What is the source of the other data in the Computer Vision system? A. The land cover data is collected, mapped and collected, digitized by district personnel. That's the largest data base that is maintained on that system. Base map information was the information that was digitized from the quad sheets and also that which was purchased from the USGS. The point information representing well locations and data collection sites comes from our data management division in the research and evaluation department. Q. So the Geologic Sciences Division does not ** 17 then collect the raw data. A. Only the land cover. Q. What is the procedure for collecting the land cover data? A. We start with a conventional aerial photograph, which is--covers the area of a single seven-and-a-half minute quad sheet. Clear mylar plastic overlay is taped over that photograph. Our technicians then photointerpret that image and delineate areas of activity or vegetation coverage. And once they've completed as much photointerpretation as possible in the office, they then go out in the field and examine areas that they were not sure of or that they could not identify on the aerial photograph. Once the map is completed in that fashion, a final quality check overflight is performed using the district helicopter where the entire sheet is verified, every area on the map is verified. Once that process is completed, the map is then traced with the digitizer and the data are stored in the system for polygon information. Like the land cover information, various processes are performed on it to generate the data bases which make it a useful product. Errors are corrected, such as incomplete closure of boundaries or lines which don't connect to ** 18 other lines, and thus by giving you incomplete topology, which the system needs to process polygons. Once all of those processes are completed, a plot is created, a hard copy from the system. That plot is then overlayed over the original field sheet to check for correspondence to eliminate any errors that might have been created by typing problems or misclassifications. Q. When you say earlier that errors, such as incomplete closure of boundaries, are corrected, what procedure is used to correct those errors? A. Well, both the Computer Vision system and the ARC/INFO system give--when you process the data to create topology, if any of these types of errors exist, there are various messages that the system will give back to you and highlight problems on the screen, such as dangling arcs or incomplete closure. Technicians then go back into the data base, make those adjustments, and attempt to generate the data base again. Only when it's absolutely correct will the system generate a correct data base. Q. The field checks and these checks that you mentioned, are these performed by the technicians you named earlier? A. Yes, they are. ** 19 Q. You mentioned that once the plot is created and it's checked there's a hard copy. Is that--are those hard copies maintained? A. No, they're not. Q. In what manner is the work you've been describing maintained? A. It's maintained as digital data on both the Computer Vision system and the ARC/INFO system. Q. Is there a process to back up the information on the Computer Vision system? A. Yes, there is. Q. What is that process? A. We have a series of magnetic tapes, one for each day for a month, approximately 30 magazine tapes. A daily backup is performed each day at the end of the working day, and those tapes are then cycled over again starting at the end of the month. So that at any point in time, we have a 30-day backup of our active work. Generally when a project is completed, the data are backed up permanently on a magnetic tape where one copy is maintained in our division area, one is maintained in our vault over in Technical Services, and an off-site copy is maintained at our field station. Q. And do you know how far back these ** 20 permanent magnetic tapes are--exist? MS. STOLLMAN: For which system are you referring to? MS. NASH: We're still on the Computer Vision system. MS. STOLLMAN: Okay. A. Well, we only permanently archive what we call primary data, which would be like the land cover information for the district, and the last update was performed in 1988, approximately. So that data is backed up. Prior to that we had 1979 data and various dates around '76--'76, '77, '79, partial coverages of the district. The base maps are also backed up. Q. Does that 1979 data you've referenced still exist? A. Yes, it does. Q. Does it have a name? A. 1979 land cover data. Q. Do you also do backups on the ARC/INFO system? A. Yes, we do. Q. And what's that procedure? A. Again, we only back up primary data, such as land use and the base map information. Those data ** 21 are--don't change, so they are backed up one time. The active projects are backed up on a daily basis until they're completed, and then we generally don't save those once a project is completed. They usually result in a transfer of data to other projects. Q. To what other projects would that data be transferred? A. I can't remember the specific projects. I would have to look at our records. Q. What records exist to show to what project your data has been transferred? A. Every project is logged in to an Oracle data base. Information containing who requested the data, what project the data is--the project is for, who worked on it, how long it took, and the final disposition of the data. Q. Does this Oracle data base have a name? A. No, it doesn't. Q. How is it referenced? A. There's a form which has been created on the--in Oracle for data input which the technicians use. They use this form to input the information about the projects, and it's stored in the Oracle data base. Q. On which of your computers do you access the Oracle data base? ** 22 A. All of our Personal System 2's access Oracle over the network. Those are primarily the systems that are used. Q. Is there any documentation or manuals that exist to assist with the functioning and utilization of the Computer Vision system? A. Yes, there are. Q. Does that documentation or manuals have a name? A. They are the Computer Vision system manuals. Each manual is named for the software module or specific application area that it references, approximately 20 to 30 manuals. Q. Is there similar documentation for the ARC/INFO? A. Yes. Q. What is that called? A. Those are the--again, the system software reference manuals provided by the vendor ESRI. Q. How many of those are there? A. Six to eight. Q. Is there any internally-created water management district documentation or manuals on the Computer Vision system? A. No. ** 23 Q. Is there any internally-created manuals or documentation on ARC/INFO? A. No. Q. Is there a means for someone outside of the water management district to access the Computer Vision system? A. No. Q. Is any of the results that you get on the Computer Vision system provided to entities outside the water management district? A. Yes. Q. To which entities? A. Various counties and private firms, engineering firms. Q. What is the nature of the information provided to the counties? A. Land-use information, base-mapping information. Those are the primary data sets. Q. In what format is the land-use information provided? A. It's actually provided in an AUTOCADD format in most cases. Q. Are there any other formats which you provide land-use information to outside-- A. Not to--well, I should say primarily ** 24 AUTOCADD. On some occasions recently, ARC/INFO format. Q. And what format is the base map information provided? A. AUTOCADD. Q. Is different information provided to private engineering firms? A. Different information? Q. Than the land-use information and base-map information you mentioned-- A. No. Q. --being described previously as provided. A. No. Q. Is the format in which it's provided to the private engineering firms any different? A. No, it's usually in an AUTOCADD format, AUTOCADD drawing files. Q. Is there different information from the ARC/INFO system provided to users outside the district? A. No, it's the same information. Q. Does any of the data that comes into the system come from other than water management district employees? A. The--as I said before, the base-map information comes from the U.S. Geological Survey. The most recent update of our land-use information involved ** 25 some data which was obtained from the regional planning councils. Q. Are those state agencies? A. I'm not sure what--technically what they are. They're regional in nature. Q. You indicated that there is presently no outside access on the computer vision system. Is--would such access be feasible? MS. STOLLMAN: I believe that's been asked and answered. MS. NASH: I asked him whether any did occur. The question now is whether it would be feasible, whether the system is capable of allowing outside access. MS. STOLLMAN: You may answer. A. I suppose it's possible technically. I wouldn't know how to go about it. BY MS. NASH: Q. Are there maps that your division has created that show vegetation distribution? A. Yes, there are. Q. Do those maps have a name? A. Those are the land-cover maps. Q. Are the maps created by your division that show nutrient distribution? ** 26 A. No. Q. Are there maps created by your division that show pesticide distribution? A. No. Q. Mr. Brown, you testified earlier that on your GIS system each type of data, it exists as a separate file and that it can be combined to--in response to different project requests. A. Not separate files but separate groups of files that make up a map coverage. Q. Are there standard guidelines or procedures for doing the combining you mentioned? A. Yes. Q. Are those written procedures? A. The various processes are contained primarily in the ARC/INFO manuals. There are different functionalities that are available in the software. You select the function that best suits the particular project you're working on. Q. But those would be contained in the ARC/INFO documentation-- A. Yes, they would. Q. --you mentioned? A. Yes. Q. Mr. Brown, you mentioned earlier that in ** 27 doing a land-cover data, you utilize photographs? A. Yes. Q. What is the source of those photographs? A. They were obtained from Mark Herd Aerial Surveys, a company, I believe, located in Minneapolis, Minnesota. Q. Is there an index of those photographs? A. They are indexed by the USGS quad sheet name, a district I.D. number, and a Mark Herd I.D. number. We use primarily our own index number to locate specific photos. Q. What is the scale on those photos, if you know? A. One to 24,000 representative fraction and IR one inch equals 2000 feet. Q. Do you know when those photographs were taken? MS. STOLLMAN: I would object to this line of questioning, going into this level of detail on the nature, type of photographs they are, but you may answer the question. THE WITNESS: Would you repeat the question, please? MS. NASH: Please read it back. (Thereupon, the question at line 16 ** 28 through 17 was read by the Reporter as recorded above.) A. Best of my recollection, they were taken in the winter of 1988. BY MS. NASH: Q. Is there also a smooth-line map that's utilized? A. No, there is not. MS. STOLLMAN: Could we go off the record a moment? MS. NASH: Yes. (Discussion off the record.) BY MS. NASH: Q. Are there photographs that your division utilized prior to this group you mentioned that were taken in 1988? A. There was one overflight which took place, I believe, in 1973, and one which took place approximately 1979. Q. Do you know who did those overflights and took the photos? A. Mark Herd Aerial Surveys did the overflights for all of those time periods. The first flight in '73 was contracted by the state. I'm not sure which agency, but they were contracted out of ** 29 Tallahassee, and the district purchased them from the repository at the university of--at Florida State University in Tallahassee. The two subsequent flights were contracted with Mark Herd by the district. MS. NASH: All right, I have no further questions. MS. STOLLMAN: Would you like to take a break before we we continue? THE WITNESS: No. MS. STOLLMAN: You need more coffee? THE WITNESS: No, I'm fine. MR. RICHARDS: I'd like to take a break. MS. STOLLMAN: Okay, we'll take a break. (Short break.) CROSS EXAMINATION BY MR. RICHARDS: Q. Mr. Brown, my name's Joe Richards. I represent the Cities of Belle Glade and Clewiston. Are you aware of what systems of satellite imagery that are utilized at the district? MS. STOLLMAN: Could you define that question? What do you mean by "systems of satellite imagery"? BY MR. RICHARDS: Q. Do you understand the question? ** 30 A. Are you--are you asking about the sources of the satellite data? Q. Yes. A. I know that we use some data from the land sat satellite and possibly other sensors, but the data that I'm most familiar with comes from the Spot Satellite Corporation, a French company. Q. Do you know who at the district is most knowledgeable as to the land sat imagery? A. Well, a couple of people come to mind. Dewey Worth in the Environmental Sciences Division and Brent Moll, M-o-l-l, in the Planning Department. Q. And who is most knowledgeable as to the spot imagery? A. Would be the same names. Q. Same names? A. Um-hum. Q. This satellite imagery is not utilized within your division? A. It's utilized in an indirect way. A composite image created from those data are used in prototype GIS systems, which we are developing, wherein the satellite image is used as a background display for the vector images from ARC/INFO. Q. Could you go into more detail as the ** 31 purposes for this indirect utilization by your division? A. The concept is to provide the users of the GIS system with something on their screen that's roughly equivalent to an aerial photograph so that when they display vectors representing roads or highways or land-use information, then the lines would be superimposed on that satellite image as a reference to allow them to orient themselves and observe current conditions in the area in a very superficial way. Q. Is this satellite imagery utilized by your division for vegetative mapping? A. No, it hasn't been. Q. Is there plans to in the future? A. We intend to move in the direction of utilizing satellite imagery for mapping vegetation and land use wherever possible. Q. Who within your division is likely to be doing this vegetative mapping? A. In the future, it won't be done in our division. Q. When you say "we," you meant the district as a whole? A. Yes. Q. Who would that be? ** 32 MS. STOLLMAN: You can answer to the extent you know. A. Land-use mapping is going to be performed in the future by the Planning Department. Specific detailed vegetation mapping is likely to be done by Environmental Sciences Division. BY MR. RICHARDS: Q. The monthly rainfall maps that you mentioned earlier, are these provided to any particular division within the district? A. They're prepared as a reporting document for our governing board. Q. Do you know the types of information that are contained on these rainfall maps? A. They basically summarize a previous month's rainfall distribution for the entire district. Q. Is water quality information on the rainfall contained on this? A. No. Q. Is this information provided to anyone outside the district? A. I can't answer that in regards to routine distribution of the data. There have been some technical reports prepared by the district for specific storm events that are available to anyone that might ** 33 want them. Q. You also mentioned land elevation maps; is that correct? A. Yes. Q. What areas would these maps cover? A. We have--we have specific elevation data for the C-1 canal basin, some areas in the Palmar Drainage District, some data for the Betsy Danforth Creek area in Martin County, and possibly some data for the Cypress Creek area. Q. Is there any land elevation maps for the water conservation areas? A. I've seen elevation maps in reports from other agencies. I'm not aware of any specific data that we have at the district; at least in my division we don't have any. Q. Are you aware of any such information you mentioned for the water conversation areas in other divisions? MS. STOLLMAN: I don't want you to speculate. If you know, you can answer. A. Yeah, I'm sure it exists, but as far as giving the specific location, it would be purely speculating on my part. ** 34 BY MR. RICHARDS: Q. Is the Environmental signs--Services Division likely to have that information? MS. STOLLMAN: I believe this question has been asked and answered. He says he can speculate but he doesn't know. BY MR. RICHARDS: Q. Who at the district might know where that information would exist? A. I would say engineers in the Water Resources Division. Q. You listed several projects for the Computer Vision CADDS system, including digitizing the quad sheets for base maps and land elevation maps. Are there any other projects contained on that system? A. Well, as I said before, we perform approximately 30 to 40 projects per month utilizing the primary data sets that I described before of various extractions and tabulations of those data. Q. Are there any other projects that you can recall? A. Well, this--there are hundreds of projects. I really can't recall any specific ones. Q. Who would know the specific ones? A. Well, those would be in our Oracle data ** 35 base. Q. Who is most knowledgeable as to the data contained in the Oracle data base? A. Well, the person who developed that data base is named Patrick Edmundson. Q. Anyone else? A. No. Q. You mentioned the land cover maps generated from aerial photography. Do you know what format that photograph is? A. The photograph comes in two formats. One is a nine-by-nine color transparency that's a false-color infrared version. There's also a paper copy which is at the quad sheet's scale one inch to 2000 feet that's a black and white version of the color IR photograph. That's the format that we use to develop the overlay referencing the color IR. Q. Is that true for the--all the years you mentioned, '89 and '79, '73? A. Only the most recent imagery. The previous ones were only the black and white paper copies. Q. You mentioned that the land cover analysis was verified by helicopter; is that correct? A. Yes. ** 36 Q. Do you know when in relation to the data photographs that verification was done? MS. STOLLMAN: Again, I object to going into this level of detail with respect to the information, when they were taken, how they were verified. You may answer the question, if you know. A. Well, the process of mapping the land cover is approximately a five-man year project for the entire district. It generally takes a year or two to complete that update. The helicopter overflights take place at various times during that update, depending on the completion of a group of overlays in a single area of sufficient number to make the helicopter flight cost effective. BY MR. RICHARDS: Q. And the individuals performing these verifications would be the technicians within your division? A. That's correct. Q. Those same individuals are interpreting the photos in the lab? A. Yes. Q. Was the 1979--oh, let's go back to '88. What areas are covered in that land cover map? ** 37 A. The entire district. Q. That would include the water conservation areas? A. Yes. Q. And the 1979 land cover map, was that also verified? A. Yes. Q. That would be the same process as you described for the 1988? A. Exactly the same process. Q. Does the 1979 map cover the entire district? A. No. Q. What areas? A. I can't recall what the distributions were for the different dates in the 1970's. There is an index map available that shows that. Q. Where is that index map located? A. In Geographic Sciences. Q. What would that be called? A. It--it has no name. Q. Do you know if the water conservation areas were mapped for land cover in 1979? A. I can't recall. Q. Who would be most knowledgeable at the ** 38 district as to the 1979 land cover map? A. The technicians in our division. Q. Would they be most knowledgeable also about the other land cover maps prepared in the '70s? A. Yes. Q. Do you know if the 1973 overflight was verified? A. Yes, it was. Q. Same process as described earlier? A. Same process except that we had no computer system, so those ended up as paper maps. Q. Where are these paper maps stored? A. Well, some of them exist in our division. Unfortunately, when the next update was performed, they were used as a base and the updates were done directly on those overlays, so it's not a clear definition of the '73 conditions. Q. Do you know if the water conservation areas were mapped in 1973? A. I can't recall. Q. As far as for '79 and '88, are they contained on the computer? A. Yes. Q. Which computer? A. Computer Vision system, the AUTOCADD ** 39 systems, and in '79 only, on the ARC/INFO system. Q. Do hard copies exist for 1988? A. No. Q. 1979? A. No. Q. And you mentioned a recent land-use map; is that correct? A. The only thing I am aware of as a recent land-use map would be our 1988/89 land cover data. Q. That's that land-cover map we just discussed? A. The digital data. Q. Is there other land-use information? A. Not that I'm aware of. Q. Besides the 1989--'88-89 map, is there land-use maps in the past besides the land cover maps we've already discussed? A. Not that I'm aware of. Q. Do you know why the district is switching from the quad sheets to the USGS DLG and Tiger file for their base maps? MS. STOLLMAN: I object to that question. I don't think it's relevant to know why they're making a change. You may answer to the extent you know. ** 40 A. Well, we--we feel that they are more detailed than our original base maps. They come, in the case of the Tiger files, with a great deal more nongraphic information, such as street names, highway names, census tracts, zip code boundaries, and it's a much more cost-effective solution than our creating them ourselves. BY MR. RICHARDS: Q. Did you experience any particular problems with the quad sheet base maps? A. No more than normal problems digitizing data, error corrections, edge matching. But no specific problems that I can recall that were unusual. Q. What types of data are stored in the info relational data base as associated with the ARC/INFO maps? A. Well, in the case of the land-cover maps, the relational data base information would be the land cover classification code for each polygon, a unique identification number for that polygon, a perimeter distance for that polygon, an area in square feet for that polygon. And that's the--that's about it. BY MR. RICHARDS: Q. Do you have any hydrology or water quality data stored in the ARC/INFO data base system? ** 41 A. No, we don't. Q. Do you make the base map information available to the public? A. Yes. All of our information, once it's finalized, is available to anyone. Q. Is there a charge for providing that? A. We charge according to Florida statutes, which, I think, is basically time and materials. Q. Are those charges the same for the entities that were requested--is there a difference--a different charge for public entities versus private industry? A. If we charge, it's--again, it's according to Florida statutes. Some agencies, like counties, we have an agreement to exchange information, and in that case, there's no charge. Q. And that's for all the information that you generate once it's finalized? A. Anything that's finalized is public information. Q. Any of the types of information we discussed copyrighted? A. No, they're not. MR. RICHARDS: That's all I have. Thank you very much. ** 42 THE WITNESS: You're welcome. (Whereupon, the deposition was concluded at 11:26 a.m.)