** 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 BILL HAIGHT 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 BILL HAIGHT By Ms. Beverly Nash 5 By Mr. Joe Richards 17 ** 3 The deposition of Bill Haight, 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 10:15 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, BILL HAIGHT being by me first duly sworn to tell the whole truth, as hereinafter certified, testified as follows: DIRECT EXAMINATION BY MS. NASH: Q. Mr. Haight, I am Beverly Nash. I am counsel for the United States in this litigation. We're here to find out about the Water Management District's computers, and the data that's on it, and how the data can be accessed. You're here as a representative of the Water Management District allegedly having knowledge of one or more of the categories of which we're interested. Have you been shown the list of categories? A. Yes. Q. And do you know to which items you're responsive? A. Yes. Q. And which ones are those? A. 2. ** 6 Q. What is your present title or position? A. I'm the regulatory records management supervisor. MR. RICHARDS: Can I have that back, please? (WHEREUPON, the requested testimony was read back by the court reporter.) Q. (By Ms. Nash) In what division or department? A. Regulation department. Q. And what are your responsibilities as regulatory records management supervisor? A. I oversee microfilming of permit files. I oversee a project to put selective information from the permit files in an on-line system, and oversee the conversion of paper maps to Auto/CADD. Q. And how long have you been in this supervisory role? A. Three years. Q. Have you had prior positions at the Water Management District? A. Yes. Q. And what positions, sir? ** 7 A. The GIS technician and a water chemistry technician. Q. In what division or department were you a GIS technician? A. Technical services department. Q. For how long? A. Three years. Q. And what were your responsibilities? A. Basically generated computer maps. Q. And how long were you a water chemistry technician? A. Four years. Q. In what division or department? A. I was planning department. Q. And what were your responsibilities as a water chemistry technician? A. Collected field samples. Q. What's your educational background? A. I have no formal degree. I am in the process of a business degree. Q. Who are your present supervisors? A. Present supervisor is Ann Roth, R-o-t-h. Q. And what is her title? A. Division director regulatory administration. ** 8 Q. Who was your supervisor while you were a GIS technician? A. Robert Brown. Q. Are there any employees in the regulation department that work for you? A. Yes. Q. How many? A. Three. Q. What are their names and positions? A. Dan Dunn, GIS technician, Carlos Piccirillo, and I can't spell it, he's a regulatory technician, too, and Ken Schroader, a temporary technician. Q. What computers are being utilized in the regulation department? A. We have IBM PCs. We work with the VAX 8820, and that's it. Q. What work is done on the VAX 8820? A. Data base applications. Q. And what are those data base applications? A. I'm not familiar with them. Q. Who would be? A. It would be Marie-Christine Leavitt. Q. And what work was done on the IBM PC? A. We used Word Perfect and Auto/CADD. ** 9 Q. You indicated that you oversee a project to port information from the permit files on-line? A. Yes. Q. Where is that permit information at the present time? A. It's stored on File Server 4 in regulation. Q. Is there a name for the data base in which this permit information is being put? A. It's stored in Word Perfect. Q. Who was doing the actual work? A. The input is done through contract labor. Q. What organization has the contract? A. Personnel Pool. Q. You also indicated that you oversee the conversion of paper maps to Auto/CADD? A. Yes. Q. Who was doing that work? A. The three technicians that work for me, and in addition a contract. Q. Do you know what areas are covered by these papers maps? A. The entire district. Q. Do you know the scale on the paper maps? A. They are varying scales. ** 10 Q. Do you know the source of the paper maps? A. They're varying sources, also. Q. Is there an index or record of the paper maps? A. I don't understand that. Q. Is there some way of knowing what paper maps you have that are being put on-line? A. Well, we use as -- they're based on USGS permit -- or USGS quadrangle maps. Q. Can you explain the process on how these maps are being put on to Auto/CADD? A. We have paper copies of the USGS quadrangles that have the permitted boundaries transcribed on them. The individual sheets are calibrated to the Florida state plane coordinate system in Auto/CADD, and the boundaries are digitized on to the Auto/CADD map. Q. Is there a name for the data base on Auto/CADD that these maps are being put into? A. They're stored in Auto/CADD format. Q. Is there any computer back-up being done on the information being put into Auto/CADD? A. Yes. Q. And who does that back-up? A. Technical services department. ** 11 Q. And what is the schedule for back-up? A. Weekly. Q. What is the retention period? A. I don't know. Q. Who is the contractor that's assisting in converting the maps? A. We haven't signed the contract yet. Q. So there is just, what, an RFP out? A. Yes. Q. Is data, other than permitted boundaries, being entered from the maps onto Auto/Cadd? A. Yes. Q. What other data is being entered? A. Base map information, which includes roads and sections and shoreline. Q. Any other information? A. We're -- water shortage boundaries, special drainage district boundaries, also areas of -- in conjunction with the outstanding Florida waters, that's it. Q. Any other features from the maps being put into Auto/CADD, other than the ones you have described? A. Not that I'm aware. Q. What percentage of the collection of paper ** 12 maps has been put into Auto/CADD? A. Permit boundaries 100 percent, any additional information -- features, I wouldn't have a percentage on, because we are still evaluating information to put on those maps. Q. Is there a target date by which you intend to be completed with the project? A. At this point, it's considered ongoing. Q. Does this digitizing of the paper maps include all the areas of the Water Management District? A. Yes. Q. So that would include the conservation areas? A. Yes. Q. Does that include Everglades National Park? A. Yes. Q. That includes the Loxahatchee National Wildlife Refuge? A. Yes. Q. Are back-ups done on the information you said was stored in the Word Perfect on the permit files that are being put on-line? A. Yes. ** 13 Q. And who does that back-up? A. Technical services. Q. And what's the schedule for that back-up? A. Weekly. Q. And do you know what the retention period is for that back-up? A. No. Q. Is the digitizing of the paper maps being done also going to be utilized by the GIS people? A. Some information will be uploaded to the GIS. Q. Do you know what information that will be? A. At this point, the permitted boundaries are scheduled to be uploaded. Q. Do you know when that's scheduled to occur? A. No date has been set at this time. Q. Other than digitizing the paper maps, does your division do anything else with the maps? A. No. Q. When you were a GIS technician in technical services, you indicated that you generated computer maps? A. Yes. Q. What was the source of the data from which ** 14 you generated those maps? A. It varied. Q. Do you have any examples? A. It's been a long time to remember exact sources of maps. Q. What was done with the computer maps you were generating? A. Hard copies were created for the requesting person. The computer division drawing file was stored on the computer version system and backed up on tape. Q. Do you know whether those were temporary or permanent back-ups? A. I have no idea. Q. Is any coordinating being done between the digitizing that your department is doing with the digitizing and environmental sciences is doing? A. We are not working together on anything on any projects. Q. Are you aware of the fact that environmental science is digitizing satellite maps? A. Yes. Q. Are you aware of any efforts to combine or coordinate those data bases? ** 15 A. Any coordination would be done through the GIS effort as far as I'm aware of. Q. Do you know who would know the sources of the paper maps being digitized? A. Which source maps? Q. You indicated that you're overseeing projects to digitize paper maps to Auto/CADD, who would know the source of those maps? A. The sources would be varied. They are -- MS. WATERS: If you know, you can answer. A. I really don't know, no. Q. (By Ms. Nash) Do you know whether any water quality information will be amongst the features that are being merchandised from the maps? A. We are not working on any water quality information. Q. Do you know whether any vegetation information will be included? A. We're not working on that. Q. Do you know whether any nutrient information will be included? A. We're not working with that. Q. Is there a list available of the USGS quad maps that have already been digitized? ** 16 A. Yes. Q. And where is that list? A. My division would have it as well as geographic sciences division and tech services. Q. Does that list have a name? A. No. Q. Is that list on computer? A. I'm not aware of it being on the computer. It would be a paper list that I'm aware of. Q. Do you know whether there are any outside entities that have access to the information being put on Auto/Cadd? A. Not that I'm aware of. Q. Do you know whether any outside entities have access to the permit files that are being put on-line? A. Not that I'm aware of. MS. NASH: I have no further questions CROSS-EXAMINATION QUESTION BY MR. RICHARDS: Q. Mr. Haight, my name is Joe Richards. I ** 17 represent the cities of Belle Glade and Clewiston. Is it possible to have read only access to the map information in Auto/Cadd? A. Only from within the district's network. Q. And for the permit file information? A. Same. Q. In regard to that permit file information, you said certain information was being put on-line. Can you describe what information is being put on-line? A. Yes, the actual permit sheet, any special or limiting conditions, the staff report, any notice of transfer, an index of drawings and reports contained in the file. Q. Is there an index to the microfilming of the permit files? A. There is a -- currently there is a paper listing of which files have been microfilmed. There is no data base. Q. Will there be a data base? A. There are no plans at this time. Q. Are you aware of a computer index to the permits other than the microfilming? A. I'm aware of the development of a regulatory data base, but I have no involvement ** 18 in the development of the workings in that system. Q. Do you know who is developing that? A. Marie-Christine Leavitt. Q. The maps you generated while you were a GIS technician, what type of maps were those? A. They varied according to user requests. Q. Did you generate any vegetation maps? A. Yes. Q. Of what areas? A. Throughout the entire district. No specific area. Q. For the Water Conservation Areas? A. I don't recall working on those areas myself. Q. Are you aware of any vegetation maps for the Water Conservation Areas? A. Only those generated through geographic sciences. Q. Do you know who is responsible for those? A. That would be Robert Brown. Q. And you said as a water chemistry technician, you collected the field samples? A. Yes. Q. What type of field samples did you collect? ** 19 A. Just general water quality evaluation samples. Q. In what areas? A. Throughout the entire district. Q. And this information is stored on a computer somewhere? A. I have no idea. It's been too long. Q. Now, what computer is the Auto/Cadd map stored on? A. The maps are stored on File Server 4. Q. Is there a naming system for the Auto/Cadd drawings and maps? A. The maps are named in two ways. The individual USGS quad map has an index No. 1 to 351. They have the county, two-letter county code as a prefix, and then the USGS quad number. Q. And the other? A. They are stored as county maps under the county name. Q. Is there a directory to these names, these file names? A. They are -- the path is Server 4, Users 3, and the path is, RES dash CTRL back slash DWGLIB. Q. Do you use any cataloging software to manage and find the Auto/CADD drawings you ** 20 generate? A. We use an archiving program called PK Zip. Q. Do you have any data base that includes descriptions of the Auto/CADD files? A. No. Q. Is this Auto/CADD map information available to the public? A. Currently we allow access to it from our central PC on the network. Q. Would that be read only access? A. Yes. Q. Are you currently allowing access to anyone outside the district? A. Not that I'm aware of. Q. You mentioned that environmental services division is digitizing satellite maps. Do you know what individuals are performing this work? A. Well, I didn't mention they were doing the work. I'm aware that some work is being done in environmental sciences through information I received from the GIS group. Q. Do you know who is doing this work? A. No. Q. Are you aware of any mapping of nutrient information? ** 21 A. No. Q. Are you aware of the mapping of any water quality information by anyone in the district? A. No. MR. RICHARDS: That's all I have. Thank you. (The deposition was concluded at 10:55 o'clock a.m.)