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 28, 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 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

 


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INDEX

 

August 28, 1990

 

DIRECT

 

CROSS

 

REDIRECT

 

RECROSS

 

BILL HAIGHT
By Ms. Beverly Nash 5
By Mr. Joe Richards 17

 


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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

 


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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

 

 

 


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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.

 


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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?

 


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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.

 


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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.

 


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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.

 


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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.

 


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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

 


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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.


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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

 


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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?


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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?

 


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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

 


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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


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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?


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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

 


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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?

 


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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.)

 

 


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I, BILL HAIGHT do hereby certify

that I have read the foregoing transcript of my

deposition given on 28th day, August, 1990; that

together with the correction page attached hereto

noting changes in form or substance, if any, it is

true and correct.

 

_____________________________
BILL HAIGHT

I do hereby certify that the depostion of

BILL HAIGHT was submitted to the witness for reading

and signing; that after he had stated to the

undersigned Notary Public that he had read and

examined his depositon, he signed the same in

the presence of the undersigned authority

on the _____ day of ____________, 1990.

_____________________________
Notary Public
My Commission expires:   _______

 

 

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