** 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 ) REGULATION; AND DALE TWACHTMANN, ) SECRETARY, FLORIDA DEPARTMENT OF ) ENVIRONMENTAL REGULATION, et. al., ) ) Defendants. ) / DEPOSITION OF TREVOR CAMPBELL TAKEN ON BEHALF OF THE PLAINTIFF *** DATE: August 28, 1990 PROFESSIONAL REPORTING SERVICE Commerce Center 324 Datura Street, Suite 303 West Palm Beach, Florida 33401 (407) 659-4046 ** 2 INDEX August 28, 1990 DIRECT CROSS REDIRECT RECROSS TREVOR CAMPBELL_ By Ms. Beverly Nash 5 By Mr. Joe Richards 22 ** 3 The deposition of Trevor Campbell, in the above-entitled and numbered cause, was taken before me, KAREN BAUER FRY, C.S.R., Court Reporter and Notary Public for the State of Florida at Large, at Professional Reporting Service, Commerce Center, 324 Datura Street, in the City of West Palm Beach, Palm Beach County, in the State of Florida, beginning at the hour of 8:38 o'clock a.m., on August 28, 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 Plaintiff in the above-entitled action pending in the above-named court. The appearances at said time and place were as follows: Beverly Sherman Nash, Esquire U.S. Department of Justice Environmental and Natural Resources Division P. O. Box 663 Washington, D.C. 20044-0663 Attorney for Plaintiff Joseph Richards, Esquire Peeples, Earl & Blank, P.A. Two South Biscayne Blvd. One Biscayne Tower, Suite 3636 Miami, Florida 33131 Attorney for Cities of Belle Glade and Clewiston ** 4 Katharine Stollman, Esquire Allison Burdette Skadden, Arps, Slate, Meagher, & Flom 1440 New York Avenue, N.W. Washington, D.C. 20005 Attorney for South Florida Water Management District Jackie Waters, Esquire So. Florida Water Management District Box 24680 3301 Gun Club Road West Palm Beach, FL 33416 ALSO PRESENT: Toni Lafuente Mike Rose David Buker Ray Roberts ** 5 THEREUPON, TREVOR CAMPBELL being by me first duly sworn to tell the whole truth, as hereinafter certified, testified as follows: DIRECT EXAMINATION BY MS. NASH: Q. Mr. Campbell, I'm Beverly Nash, counsel for the United States in this litigation. We're here taking these depositions to find out about the Water Management District's computers, how they function, what data is on them, how that data is formatted. You're here as a representative of the Water Management District with knowledge of one or more of the areas in which we're interested. Have you been shown the list of categories? A. Yes, I have. Q. And do you know which categories you're responsive? A. I may have to take a look at that again. Okay. Categories 1, 2, 3, some of 4, some of 5, some of 6, some of 7, none of 8, none of 9. ** 6 Q. What is your present title or position at the Water Management District? A. I'm a data base administrator. Q. In what department or division? A. Technical services department. Q. Are you in one of the divisions in that department? A. No, I'm not. Q. What are your job responsibilities? A. Primarily to coordinate all data base activities within the district, excluding the financial and human resource systems. Q. And how long have you been in that role? A. Since January of 1989. Q. Have you had other positions at the Water Management District? A. Yes. Q. What positions? A. Prior to this position, it was data base manager in hydrology. Prior to that, it was senior applications analyst. Prior to that, it was applications analyst. Q. And how long were you a data base manager in hydrology? A. Roughly a year and four months. ** 7 Q. And what were your job responsibilities as a data base manager in hydrology? A. Primarily to design the new hydraulic data base. It also included responsibilities to develop the RFPs for the preprocessing system. Q. And how long were you a senior applications analyst? A. Roughly a year. Q. In what division were you? A. At that time, it was a computer applications division, I think. Q. What were your job responsibilities as a senior applications analyst? A. To develop software systems on request. Q. And how long were you an applications analyst? A. Three months. Q. And what were your job responsibilities as an applications analyst? A. Also to develop software systems on request. Q. What software systems did you develop while you were an applications analyst? A. For the reference center, I developed the software systems which cataloged all their holdings ** 8 and on which you could search, via, subject matter, title, author, ISPA number, and I started the development of the merit review system. Q. And what's the merit review system? A. It's a system used in personnel for our merit review process. It basically takes your scores from a green sheet and it scans it into the computer, via, an optical scanner, and it verifies that scores are in an acceptable range, and it does some statistics on the scores, et cetera. Q. Did you develop any other software systems while you were an applications analyst? A. No, I did not. Q. What software systems did you develop while you were a senior applications analyst? A. I continued developmental of the merit review system. I started to develop the contract information system. I can't recall any other systems. Q. What is the contract information system? A. The contract information system tracks contract activities at the district -- a project manager, contract administrator, when deliverables are due, and how much -- for how much, among other things, that I can't remember right now. ** 9 Q. You have indicated that while you were data base manager in hydrology, you designed the new hydrology data base? A. Not completely. We started the design and the design was maybe 80 percent complete before I left that job. Q. Did this hydrology data base have a name? A. Yes. Q. What is its name. A. DB Hydro. Q. What was the source of the data to be used in DB Hydro? A. The source was from the preprocessing system, from USGS, from another data base called Rainfall. I'm not sure, but I think the DER may have something there, too. Q. What is your educational background? A. I've got a bachelor's degree in management science and systems. I've got an MBA in computer systems management. Q. And who are your supervisors in the technical services department? A. Currently? Q. Yes. A. John Lynch. ** 10 Q. Do you have any employees that work for you? A. Yes. Q. What are their job titles? A. Senior data base analyst, that's it. Q. Who is that person? A. Ron Metzger. Q. What are the computers that you utilize in your job as data base administrator? A. The PC, the VAX 8820, the VAX 6310, and occasionally a work station. Q. Which of the PCs do you utilize? A. Which of the PCs do I utilize, the one in my office. Q. What model is it? A. Model 70. Q. It's an IBM? A. Yes, it is. Q. What work do you do on the IBM Model 70? A. Primarily word processing. It is also used as an intelligence terminal to connect to the VAX machines that I access. I do some presentations and stuff in it with Harvard Graphics. I do Symphony work sheets. Q. Are there other software packages that you ** 11 use on the IBM PC? A. We're still talking about my current job; is that correct? Q. That's correct. A. That's it now. Q. What work do you do on the VAX 8820? A. The VAX 8820, I log onto the VAX 8820, and most times I monitor CPU utilization as far as the data base systems are concerned. Q. Do you do any other work on the VAX 8820? A. Yes. Q. What is that? A. I access tables and do bench marking work. Q. What is the nature of the tables that you access? A. What is the nature of the tables that I access? MS. STOLLMAN: You can answer if you understand. A. Yeah, could you rephrase that one? Q. (By Ms. Nash) What is the data in the tables that you access? A. Okay. The table is called WM underscore salt underscore data, and it contains some permit information with some sort of chemical information ** 12 also associated with wells. And I do bench marking tests on it to determine what the effective indices are versus how ineffective the table without an index is. I also access some of the tables in DB Hydro, again, to do some other things. Q. What is the data in the tables in DB Hydro that you access? A. It's primarily hydrologic information on weir or gate. Q. What kind of tests do you do on the tables in DB Hydro? A. Bench marking similar to what I do in the WM_salt_data. Q. Can you elaborate what you mean by "bench marking"? A. Again, I determine how effective the indices are on the table, whether it increases performance or not. Q. Do you do any other work on the VAX 8820? A. No. Q. What work do you do on the VAX 6310? A. As a data base administrator again, right? Q. Yeah. A. I really do not do any work on there. Q. And you indicated that you also utilized a ** 13 work station? A. Occasionally I have. Q. Which work station? A. It's a DEC station 3100. Q. And what's the type of work you do on the DEC station? A. Evaluating the CASE tool. Q. Can you explain what that is? A. CASE is an acronym for Computer Assisted Software and Engineering. It's a method of designing data bases and developing entity relationships. Q. As the coordinator of all the data base activities in the Water Management District, do you have an index or a listing of all the data bases in the division? A. In the division? Q. I'm sorry. In the district? A. Yes, I do. Q. Does that index or listing have a name? A. It's called an allocated list of data bases. Q. And does that encompass all of the data bases on all of the computers in the Water Management District? ** 14 A. I'm sure it does not. Q. Do you know what percentage of the data base is in existence in the Water Management District it does cover? A. This would be a guess, but -- MS. STOLLMAN: I don't want you to speculate. If you know, you can answer the question. MS. NASH: Well, to the best of his knowledge. A. I'd say somewhere between 85 and 90 percent. Q. (By Ms. Nash) Do you know which divisions or departments data bases would not be included in that list? A. No. Q. Do you know who might know? A. No. Q. With the VAX 8820, what software do you use on that machine? A. Oracle. Q. Any other? A. No. Q. And on the DEC work station, what software do you use? ** 15 A. Oracle's CASE tools. Q. Any other software? A. No. Q. In your role as a data base manager in hydrology, what computers did you use? A. The VAX 8820, the VAX 6310, and an IBM PC. Q. And what work did you do on the VAX 8820 as the data base manager? A. As data base manager, created tables, populated the tables with data, created indices on the tables, that's it. Q. What was the subject matter of the tables that you created? A. Hydrologic data. Q. And what was the source of that data? A. The source of the data would be the old DB Hydro system. Q. And what was done with the tables you created? A. I do not understand. Q. What use was made of the tables that you created? A. That was in the design stage, and the data base was not fully functional; therefore, no practical use was made of the data. ** 16 Q. While you were a data base manager in hydrology, what work did you do on the VAX 6310? A. Very similar to what I did on the 8820. I created tables, created indices on the tables. May I make a correction here? Q. Certainly. A. When I was a data base manager, it was not a VAX 6310. It was a -- it was upgraded after that to 6310, but it was an 8250. Q. Was there a reason why you did some of the creation of tables on the VAX 8820 and some of them on the other machine? A. Yes. Q. And what was that reason? A. Well, the 8820 came to the district after the 8250. We were originally using the 8250 to do our development work, but once the 8820 was there and up and running, then, we transferred the development work to the 8820. Q. And while you were a data base manager, what work did you do on the IBM PC? A. I primarily used it to access the VAX machines, did some word processing work, and then wrote a couple of -- a few "C" programs. Q. What software did you use on the IBM PC ** 17 while you were data base manager? A. Word Perfect, Lattice C, that was it. Q. What was the subject matter of the "C" programs that you wrote? A. I can't recall it. Q. Did you have any documentation or manuals to assist you in your work while you were a data base manager in hydrology? A. Yes. Q. What was the names of those -- of that documentation of those manuals? A. I cannot remember exactly what it was. Q. What was the subject matter of the documentation or manuals? A. Systems -- the programmer's guide to the preprocessing system, operators guide to the preprocessing system, Schema, S-c-h-e-m-a, for the existing data base hydro. There was some documentation and some plot routines also. Q. Was this Schema for the existing data base hydro a document created within the Water Management District? A. Yes, it was. Q. And who created that document, if you know? ** 18 A. No, I don't. Q. And as data base administrator, are there documentation or manuals that you utilize to assist you? A. I use the Oracle manuals, no documentation. Q. While you were data base manager in hydrology, when you were working on DB Hydro, was that data that was going into DB Hydro from the Cyber? A. The data in the existing DB Hydro was in the Cyber. Q. Do you know whether all of the hydrology data from the Cyber has been transferred to the VAX? A. Today? Q. Yes. Do you know? A. It has not been. Q. Do you know how much of it has been? A. No. Q. Do you know who would know? A. Yes. Q. Who is that? A. Brian Turcotte. Q. You indicated your present responsibility ** 19 is to coordinate all data base activities? A. That's correct. Q. What does that entail? A. It entails developing standards for data base development, relational data base development. It entails insuring that data bases that are being developed in the district supports the district's mission. You've got to minimize system redundancy, develop an annotative list of data bases, develop a data base migration plan, that's what it is primarily. Q. What does a data base migration plan do? A. It's -- the Cyber is leaving the district, and there are a number of data bases which are on the Cyber, which should be migrated to a different hardware platform. There are also a number of data bases on PCs in a Data Flex package, which should also be migrated to a different hardware, software platform, as we'd like to consolidate data base development in one environment. Q. Do you know when the Cyber will be leaving the district? A. Not exactly, no. Q. And this annotated list of data bases you're developing, do you know how many data bases ** 20 are in that list at the present time? A. Roughly, it's 96 tabular data bases and roughly 40 GIS or spatial data bases. Q. Do you know who is developing GIS data bases? A. Some of the people. Q. Which of the people do you know? A. Bob Brown, Brent Moll, maybe Dave Black Bill Haight, Dennis Meierer, that's it. Q. Which of the computers are being utilized to develop the GIS data base? A. Work stations, SUN work stations. Q. Any others? A. I'm not sure. Q. This annotated list of data bases you've referenced, where is that located? Is it on one of the computers? A. It's on a floppy disk somewhere. Q. Does that floppy disk have a name? A. No, it does not. Q. And where is that floppy disk physically located? A. I think Bert Price has it. I'm not sure. Q. Who is Bert Price? What is his title? A. She's a secretary for the department. ** 21 Q. In the tests that have been done on data base development, is any spatial data being used? A. What tests are you making reference to? Q. You referenced doing tests to access tables in DB Hydro, for example, is any spatial data utilized in those tests? A. In a limited sense. Q. What is the spatial data that is being utilized? A. Location. Q. Where is that location information taken from? A. I don't know where it's taken from. Q. In what format is that spatial data provided to do the testing? A. I do not understand that question. Q. If spatial data is being utilized to do testing, how is it -- in what format is it in existence to do the testing? A. I made reference to location, and that's the only spatial quality of the data that was being tested. MS. NASH: All right. I have no further questions. MS. STOLLMAN: Do you want to take a ** 22 break before we continue? THE WITNESS: No. CROSS-EXAMINATION QUESTION BY MR. RICHARDS: Q. My name is Joe Richards. I represent the cities of Belle Glade and Clewiston. In reference to the annotated list of data bases, would that list have any indication as to the subject matter of the different data bases? A. It has -- yes. Q. To what detail would that indicate the subject matter? A. Two or three sentences on the functionality. Q. And you mentioned several individuals developing GIS data bases, do you know whether any of these data bases are operational? A. No, they're not. Q. As the data base manager, are you aware of entities outside the district having access to any of the computer systems? A. As a data base manager, yes. Q. What entities? ** 23 A. Oracle Corporation. Q. Any others that you're aware of? A. No. Q. Are you aware of whether any of the computer systems of the district are capable of providing outside access to entities? A. Yes. Q. Which systems? A. The VAX 8820. Q. Any others? A. The Cyber. That's it. Q. You are not aware of any other systems -- MS. STOLLMAN: What is your question. Q. (By Mr. Richards) -- that are capable of providing outside access? A. Capable of providing access. The VAX 6310 is capable of it. I'm not aware of any others. Q. For these three systems you named, are you aware of whether they provide read only access? A. No. Q. Who would know? A. Bill Hall. Q. Are you aware of whether the district has any formal guidelines or policies on quality assurance and quality control for the data bases? ** 24 THE WITNESS: Can I talk to you for a second? MS. STOLLMAN: Off the record. (WHEREUPON, there was a discussion held off the record.) MR. RICHARDS: Could you read back the last question? (WHEREUPON, the requested testimony was read back by the court reporter.) A. No. Q. (By Mr. Richards) No, you are not aware of any? A. Yes. Q. Are you aware of any policies or guidelines for maintaining data base integrity? A. Yes. Q. Are those policies in a written format? A. You said "policies or guidelines." We have guidelines, not policies. Q. Are the guidelines in a written format? A. In a sense. ** 25 Q. Where are they written? A. They're taken into consideration when the data bases are being designed. Q. Are those guidelines written down somewhere in a manual? A. It would be part of the documentation of the data base. Q. While at the district, are you aware of any accidental loss of data? A. No. Q. Are you aware of the accidental loss of any of the data for the DB Hydro data base? A. No. Q. While you were designing the new DB hydro data base, was that system designed to provide read only access? A. The system is designed to provide read, write access, but depending on the user, you may only have a particular type of access to it. Q. So it is possible to provide read only access? A. Yes, it is. Q. Do you believe that allowing read only access to the DB hydro data base would degrade the system's performance? ** 26 A. It depends. Q. What would that depend on? A. How many users are reading. Q. Do you know how many users can utilize that system at one time? A. That's a function of the operating system. Q. Do you know who would know that for the DB Hydro data base? A. Again, that's a function of the operating system, and Bill Hall would know that. Q. Are you aware of any computer work for the Everglades Nutrient Removal Project? A. No. Q. The Holeyland Restoration Project? A. No. Q. The Water Management Area proposal in the Everglades SWIM Plan? A. No. Q. Do you have any idea when the transfer from the Cyber to the 8820 of the DB Hydro data base will be completed? A. Any idea? Q. Do you know? A. Roughly, yes. Q. When? ** 27 A. By April of next year. Q. In reference to the transfer of the DB Hydro to the VAX computer, are you familiar with the Oracle data base programming language? A. Yes. Q. Do you know who designed the templates for entry of data into the Oracle data base? A. The templates of entry has not been designed yet. Q. Do you know whether, once the transfer is completed, will the hydrology data be available to others who request it in Oracle data base format? A. I don't know who it's going to be available to. MR. RICHARDS: Thank you. I have no further questions. (The deposition was concluded at 9:33 o'clock a.m.)