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Deposition from United States v. SFWMD, et al.,

Case No. 88-1886-CIV-HOEVELER
 
  STYLE:     US vs. SFWMD
  CASE:      88-1886-CIV-WMH
  JUDGE:   WILLIAM M. HOEVELER
  DATE:      August 24, 1990

  NAVIGATION:
                     Index
                    Appearances
                    Proceeding
                    Page:   10
                    Deponant's Certificate (page 15)
                    Ceritificate of Service (page 16)

 

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION

 

 

UNITED STATES OF AMERICA,

Plaintiff,

vs.

SOUTH FLORIDA WATER MANAGEMENT
DISTRICT; JOHN R. WODRASKA,
EXECUTIVE DIRECTOR, SOUTH FLORIDA
WATER MANAGEMENT DISTRICT;
FLORIDA DEPARTMENT OF ENVIRONMENTAL REGULATION AND DALE TWACHTMANN,
SECRETARY,  FLORIDA DEPARTMENT OF
ENVIRONMENTAL REGULATION, et. al.,

Defendants.

____________________________________________/

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Case No
88-1886-CIV-WMH  

 

DEPOSITION OF ROBERT BROWN, III
TAKEN ON BEHALF OF THE PLAINTIFF

* * *

 

DATE:   August 24, 1990

 

PROFESSIONAL REPORTING SERVICE
Suite 303, 324 Datura Street
West Palm Beach, Florida 33401
(407) 659-4046


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INDEX

 

August 24, 1990

 

DIRECT

 

CROSS

 

REDIRECT

 

RECROSS

 

ROBERT BROWN, III
By Ms. Beverly Nash 5
By Mr. Joe Richards 29

 


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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.

 


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APPEARANCES CONTINUED:

ALSO PRESENT:   Toni Lafuente
                                Ray Roberts
                                David Buker
                                Frank Draughn

 

 

 

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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

 


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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?

 


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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?

 


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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

 


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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?

 


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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

 


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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.

 


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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?

 


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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?

 


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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.

 


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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.

 


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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


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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

 


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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.

 


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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

 


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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

 


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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?

 


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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.

 


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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

 


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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


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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?

 


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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

 


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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

 


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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

 


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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?

 


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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

 


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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?

 


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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

 


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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.

 


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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

 


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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.

 


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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?

 


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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

 


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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

 


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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.

 


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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?

 


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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.

 


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THE WITNESS: You're welcome.

(Whereupon, the deposition was concluded

at 11:26 a.m.)

 

 

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