** 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 JORGE MARBAN TAKEN ON BEHALF OF THE PLAINTIFF *** DATE: August 29, 1990 PROFESSIONAL REPORTING SERVICE Commerce Center 324 Datura Street, Suite 303 West Palm Beach, Florida 33401 (407) 659-4046 ** 2 INDEX August 29, 1990 DIRECT CROSS REDIRECT RECROSS JORGE MARBAN By Ms. Beverly Nash 5 By Mr. Joe Richards 39 ** 3 The deposition of Jorge Marban, 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 8:50 o'clock a.m., on August 29, 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 Bob Johnson ** 5 THEREUPON, JORGE MARBAN being by me first duly sworn to tell the whole truth, as hereinafter certified, testified as follows: DIRECT EXAMINATION BY MS. NASH: Q. Mr. Marban, I'm Beverly Nash, counsel for The United States in this litigation. We're here to find out about the Water Management District's computers, how they're used, what kind of data is on the computers, how that data is formatted. You have been indicated as a representative of the Water Management District having knowledge of one or more of nine categories. Have you been shown the list of categories? A. Yes, I have. Q. And to which categories are you responsive? A. Seven and eight. Q. What is your present title or position? ** 6 A. I'm division director of the water resources division for the department of research and evaluation. Q. And what are your job responsibilities? A. I supervisor and oversee all the work that is done in that division. Q. Explain the work that is done in the water resources division? A. We do hydrologic and hydraulic analysis and mathematical modelling. Q. And how long have you been in that role? A. About 11 years. Q. Have you had other positions at the Water Management District? A. Yes. Q. And what were those positions? A. Well, I was a senior engineer prior to that. Q. And how long were you a senior engineer? A. About two years. Q. In what division? A. In the same division. Q. And what was your responsibility as a senior engineer? A. Well, I was working on models myself. ** 7 Q. And did have you a position at the Water Management District prior to being a senior engineer? A. No. Q. What is your educational background? A. I have a Bachelor of Science in chemical engineering from the University of Florida. I have a Master of Science in chemical engineering from the University of Florida. I have a Ph.D. in systems engineering from the University of Florida. Q. To whom do you report in the department of research and evaluation? A. To Leslie Wedderburn. Q. How many employees work for you in the water resources division? A. Nineteen. Q. What is the job description or job title of these people that work for you? A. It varies. There are water resources engineers, staff water resources engineers, senior water resources engineers, engineering assistants, senior engineering assistants, administrative secretary, supervising professional, and I have an assistant division director. Q. Who is the assistant division director? ** 8 A. Shawn Sculley. Q. What computers are utilized by the water resources division? A. We used the Cyber system, PCs, and SUN work station. Q. What software packages are used on the Cyber? A. We have our own -- our own models that we develop and that we use there. We access DB Hydro. Q. Do these models that the division has developed have names? A. Yes. Q. What are the names? A. South Florida Regional Routing Model, and South Florida Water Management Model. Q. Any others? A. From time to time we use HEC 2 or DWOPER, or something called SHEET 2D, S-H-E-E-T, 2D. With my accent I have to explain. Q. What does the South Florida Regional Routing Model do? A. Essentially distribute volumes among the different areas, volumes of water, routes the water from one place to another. Q. What data bases are utilized with the ** 9 regional routing model? A. DB Hydro. Q. Any other? A. If all the information is not in DB Hydro, we look at the Corps of Engineers data or the USGS data. Q. And what does the South Florida Water Management Model do? A. It's a more detailed model than the regional routing model, and it provides information on a localized basis. Q. What are the various perimeters that the water management model can look at? A. Rainfall, evaporation, land use, soil characteristics, hydraulic characteristics. Q. Are these the same perimeters that the regional routing model utilizes? A. The original routing model is more general. It doesn't use the rainfall validity. Q. You mentioned a model called HEC 2, what does that do? A. That's a routing model that the Corps of Engineers developed. Q. And what does the model do? A. Route water through a channel. ** 10 Q. You mentioned a model DWOPER, what does that model do? A. It's another routing model. Q. And who was that developed by? A. That was developed by the University of Texas. Q. And you mentioned one more model that's used occasionally? A. SHEET 2D. Q. SHEET 2D? A. That's a developing house. Q. What does that do? A. It's like a wetlands model. Q. And what is the source of the data utilized in that model? A. DB Hydro. Q. Okay. You indicated that you used the Cyber to access DB Hydro. Is other use made of the Cyber? A. Repeat the question, please? Q. You indicated that you used the Cyber to access DB Hydro. Is other use made by the division of the Cyber computer? A. Yes. Q. What? What other uses? ** 11 A. We run the models in the Cyber. Q. Which PCs are utilized by the division? A. IBM personal computers. Q. What software packages are used on the IBM PC? A. Primarily Symphony. Q. Any others? A. Not that I know. Q. What use is made of the IBM PCs? A. It's to present the information on the -- to preprocess the data and process the data -- the information. Q. What are the sources of the data being processed? A. DB Hydro. Q. You also indicated that the division uses the SUN work station? A. Yes. Q. What software is used on the SUN work stations? A. We are developing our own software. Q. Does that software have a name? A. No. Q. And what is that software? What is it intended to do? ** 12 A. Essentially, there are graphic packages that allow us to present information. Q. Who is developing the software on the SUN work station? A. Todd Teizdale, Bill Perkins. Q. Who developed the regional routing model you mentioned earlier? A. Paul Trimble. Q. And who developed the South Florida Water Management Model? A. Initially, it was Tom MacVicar. Later, it was modified by Ray Santee. Q. What water modelling has the division done for the Everglades SWIM Plan? A. We have used the South Florida Regional Routing Model and also a South Florida Water Management Model. Q. And what perimeters were looked at? A. We looked at the movement of the water, the flow of water. Q. And where are the results of the water modelling work for the SWIM Plan located? A. Cyber. Q. Is there a name for the data base or the directory where these results are located? ** 13 A. Each of the runs that we made has a name, but I don't remember. Q. Where would you look to find the name for the various runs? A. Perhaps Paul Trimble has a log of all the runs he has made. Q. Does that log have a name? A. No. Q. Did Paul Trimble do the water modelling runs for the Everglades SWIM plan? A. Ray Santee. Q. Was the water modelling done for LOTAC? A. Some runs were done, yes -- yes. Q. And who did that water modelling? A. Paul Trimble, also. Q. And where would results of that water modelling be located? MS. STOLLMAN: Can we take a 5 minute recess? MS. NASH: Sure. (Short break.) MS. STOLLMAN: I just want to put on the record that Ron Mierau was called to an ** 14 emergency meeting today. He will be here, but he needs to get going to his meeting, so we may need to interrupt George Marban's deposition so that we can take the testimony of Ron Mierau, who needs to go to the emergency meeting later today. MS. NASH: What time did you want Mr. Mierau here? MS. STOLLMAN: He will probably be on his way in about 15 minutes, so we may -- he may not be here for another half an hour, so we may have already concluded at that time or be near our conclusion of Mr. Marban's deposition. MR. NASH: Where were we? (WHEREUPON, the requested testimony was read back by the court reporter.) A. In the Cyber. Q. (By Ms. Nash) Under what name would we be able to find the results of the water modelling model? A. Again, I don't know the names of the drawings. Q. Who would know? A. Ray Santee. ** 15 Q. Has water modelling been done for the proposed water management areas? A. Yes. Q. And what model was used to do that? A. The South Florida Water Management Model. Q. And who did that water modelling? A. Ray Santee. Q. What perimeters were looked at in the water modelling for the water management areas? A. The rainfall, evaporation and flows. Q. Any others? A. Vegetation. Q. And what was the source of the data used to do the model? A. DB Hydro. MS. NASH: I need to take a break. (Short break.) Q. (By Ms. Nash) Do you know when the last modelling runs were done on the proposed water management area? A. About three months ago. I don't really know exactly. Q. And where are the results of those runs? ** 16 A. The Cyber. Q. Do you know when the last runs were done for the Everglades SWIM Plan? A. I don't know the exact date, no. Q. You indicated that Paul Trimble has the log of all the runs made for the Everglades SWIM; is that also true for other runs made using the models? A. Yes. Q. So his log would encompass all uses of the model? A. Yes. Q. Has water modelling been done for the Everglades Nutrient Removal Project? A. No. Q. Has water modelling been done for the Everglades Agricultural Area? A. Would you be more specific? Q. Has water modelling been done for the -- for ENPs for the Everglades Agricultural Area? A. No. Q. Has any water modelling been done that's focused on just the Everglades Agricultural Area? A. Only as a part of the regional system. Q. Has water modelling been done for the ** 17 Loxahatchee National Wildlife Refuge? A. As part of the regional system. Q. And what were the perimeters that were looked at? A. Rainfall evaporation flows, general topographies of the area. Q. Where did the topographical data come from? What's the data base? A. From our geographic science division. Q. Has water modelling been done for any of the other Water Conservation Areas? A. Yes. Q. What is the nature of that water modelling? A. It's power to the original model? Q. And who did that water modelling? A. Ray Santee. Q. And what data bases did he use? A. DB Hydro and geographic sciences. Q. When was the last run made of the model for the water conservation? A. I don't really know. Q. Would the runs done on the Water Conservation Areas be included in Paul Trimble's log? ** 18 A. Yes, or Ray Santee's log. Q. Has any water modelling been done for Everglades National Park? A. Yes. Q. Who did that water modelling? A. Ray Santee. Q. And when was that water modelling done? A. I don't know the exact date. Q. What was the data utilized to do the water model for ENP? A. Same as conservation areas, plus some information provided by the park. Q. Can you explain how the water modelling is performed? A. Can you be more specific on what you want to know? Q. Can you explain the process for doing water modelling? MS. STOLLMAN: The computer process, is that what you're asking? MS. NASH: Yes. A. We take information out of data bases and preprocess that information to put it in a form that the computer model will accept it, input it into the computer, into the model, so the model ** 19 will perform a series of tasks. And we produce an output that will put it as a -- store it in the Cyber. Then, the output is presented in whatever form is required. Q. (By Ms. Nash) Is there documentation to reflect the various tasks that the water models can perform? A. Yes, there is. Q. Does that documentation have a name? A. Yes, it does. Q. What is its name? A. I don't remember the exact name. It's a technical publication produced by the district. Q. Do you know when that publication was produced? A. In 1984, I believe. I'm not completely sure, so I don't know. Q. Has the model been modified in any way since the production of the publication? A. Yes. Q. What modifications have been done? A. Some modifications have been made to the canal conveyance and some features have been added to make it more efficient. Q. What are the nature of the features that ** 20 have been added? A. Well, the movement of the flow, the flow of the water. Some of the modifications that have been made to the system since then have been incorporated into the model. Q. When you say "modifications to the system," do you mean the canal and structure system in the district? A. Yeah, additions. Uh-huh. Q. Have water budgets been prepared for the Everglades Agricultural Area? A. Yes. Q. And who prepared them? A. Paul Trimble and Terry Otero. Q. I'm sorry? A. Terry Otero. Q. What was the data utilized to prepare the water budget? A. Rainfalls, evaporations, flows, that's it. Q. What was the source of that data? A. DB Hydro. Q. When was the last water budget prepared for the EAA? A. I don't know the exact date. Q. Where would the results be located? ** 21 A. Cyber. Q. Is there a list or index of the water budget results on the Cyber? A. There's a log on the information. Q. And who maintains that log? A. Paul Trimble. Q. Is this the same log to which you referred earlier? A. Definitely. Q. And does this log have a name? A. No. Q. Have water budgets been prepared for the Water Conservation Areas? A. You already asked that question. Q. No, I asked you the Everglades Agricultural Area was the prior question. A. Oh, conservation areas, not formally. Q. Have any informal water budgets been prepared? A. We don't. Q. Does anyone in the Water Management District? A. No. Q. Have water budgets been prepared for the Everglades National Park? ** 22 A. No. Q. Have water budgets been prepared for the Loxahatchee National Wildlife Refuge? A. No. Q. Are you familiar with whether the Water Management District has prepared nutrient budgets? A. In what aspect? Q. Do you know whether any has been prepared by any -- A. Yes. Q. Do you know what division or department has prepared nutrient budgets? A. The water quality division. Q. Do you know who within the water quality division? A. No. Q. Does the water resources division have any computer files studying or showing proposed nutrient removal alternatives? A. No. Q. Has the division done any studies using the computer on water quantity impacts of retention of water in the Everglades Agricultural Area? A. Yes. Q. Who has done those studies? ** 23 A. Ray Santee. Q. And when were they done? A. I don't remember the exact date. Q. And where would the results of those studies be? A. The Cyber computer. Q. Do you know the name for the file that would contain those results? A. No, I don't know the name. Q. Who would know? A. Ray Santee would know. Q. Has the division done any water modelling on the Holeyland Restoration Project? A. Yes. Q. And when was that modelling done? A. I don't remember the exact date. Q. And who did the modelling? A. Ray Santee and Paul Trimble. Q. And what were the perimeters that we looked at? A. Flows primarily, rainfall, ET, vegetation conditions in the Holeyland. Q. What was the source of the data? A. DB Hydro and geographic science. Q. Where are the results of the -- ** 24 A. Cyber. Q. What file would those results be contained? A. I don't remember the results. Q. Who would know? A. Ray Santee. Q. Does the water resources division do any GIS work? A. No. Q. You indicated that the water resources division utilizes topographic data from geographic sciences. Is there any other data that's utilized from geographic sciences in the water modelling? A. Land use data, vegetation cover. Q. Any others? A. No. Q. Do you know the data base from which the vegetation cover data is obtained? A. I don't know specifically. Q. Who would know? A. Bob Brown. Q. Mr. Marban, you did a study back in approximately 1987 on the technology being utilized by the Water Management District, do you recall that? ** 25 A. I presented a paper, yes. Q. Has the technology being utilized by the Water Management District changed since you did that paper? A. Not basically, no. Q. The paper indicates a number of models that you have not mentioned, like, rainfall runoffs spreadsheet routing model; is that model being utilized by your division? MS. STOLLMAN: Again, are you referring to models that are done on the computer system? MS. NASH: These are all computer models, this whole paper is on computers. A. It hasn't been used in connection with this, no. Q. (By Ms. Nash) The paper also mentions an interactive seasonal water balance model -- MS. STOLLMAN: Before you answer this question, if you'd like to ask Mr. Marban questions about a document that you have, I would like to give him an opportunity to review that document. MS. NASH: If it becomes necessary, he can review the document. I'm asking him if these models mentioned ** 26 in the paper he wrote some years ago, are still being utilized. MS. STOLLMAN: I understood the question. MS. NASH: If he can answer the question without referring to it, then he can answer the question. If he needs his recollection refreshed, then, he can see the paper. MS. STOLLMAN: I understand your question. I would like Mr. Marban to have an opportunity to review a document -- MS. NASH: No. MS. STOLLMAN: -- that you are asking him questions about. MS. NASH: No. MS. STOLLMAN: Well, then, I will not permit him to answer questions unless you give him an opportunity -- MS. NASH: I'm asking him about models that the Water Management District has. And it's clearly covered under the information he is here to testify about and it's -- MS. STOLLMAN: And I will permit him to answer those questions if you will give him an opportunity to review the document that you are ** 27 asking him questions about. MS. NASH: If there's some reason for him to review the document, I will, but there is not. MS. STOLLMAN: There is a need for him to review the document, because you are asking him questions about it, and I would like for him to review it. MS. NASH: There is no need. He has not indicated that he is not aware of the model that he wrote about. I am asking him whether the model is still being utilized. If he doesn't know or doesn't remember what the model is, he can look to see what he wrote about it, but otherwise there is no need; and I will not show him the paper. MS. STOLLMAN: I would like Mr. Marban to review the document from which you are asking questions. MS. NASH: No. It is not necessary. It is not required. There is nothing that requires me to give him the document I'm referring to to ask him questions about. MS. STOLLMAN: I have not seen the document. You are asking him questions relating to -- ** 28 MS. NASH: It's not necessary for you to see the document I'm asking him questions about. MS. STOLLMAN: Well, I will not permit him to answer questions unless you let him see the document. MS. NASH: Well, then, I suggest we get the magistrate on the phone immediately and get this resolved, because I will not show him the document. MS. STOLLMAN: What is your basis for not showing him the document? MS. NASH: Because there is no need. Perhaps I have notes on it that are of no right for him to see. There is no need for him to see the document. If he is aware of the models and he can tell me about them, then, he can answer questions about them. There is no basis for you to require production of a document that I have in my hand. MS. STOLLMAN: I don't want you to show him your personal notes. I would like him to be able to review a document upon which you are asking questions. MS. NASH: I'm sorry, but there are notes on the document, and I will not show him the ** 29 document. MS. STOLLMAN: Well, then, I will not permit him to answer questions. MS. NASH: Well, then, let's get the magistrate on the phone right now. MS. STOLLMAN: Go right ahead. (WHEREUPON, there was a discussion held off the record.) MS. NASH: Ms. Stollman, I'd like you to state on the record your legal basis for directing the witness not to answer questions. MS. STOLLMAN: My basis for not permitting him to answer questions is that the document became an integral part of your questioning and it became part of the record, and I think we are entitled to see the entire document. I will permit him to answer general questions on the areas that were noticed to which you are entitled which may relate to the document if the document does not become an integral part of the record. MS. NASH: Then, I will ask him questions without utilizing the document. ** 30 Q. (By Ms. Nash) Mr. Marban, are you aware of a model called the interactive seasonal water balance model? A. Yes. Q. And what is that model? A. It's the model that we are developing in our division. Q. What does the model do? A. Essentially, it is a water balance of different areas and they move water from other areas. Q. Is that model currently being used? A. No. Q. When was it last used, if you know? A. I don't know. Q. Are you aware of a model that's abbreviated SWIM? A. This is the South Florida Water Management Model. Q. And that model we have previously discussed; is that correct? A. Yes. Q. Are you aware of a model that's initials are DWOPER? A. D-W? ** 31 Q. -- O-P-E-R. A. That's the DWOPER model I mentioned earlier. Q. What does that model do? A. Essentially, hydrologic routings. Q. And is that model currently being utilized by the Water Management District? A. Yes. Q. And what is the source of the data utilized in that model? A. Essentially, rainfall, flow data. I'm not very familiar with the model itself or all the details. Q. Who utilizes the DWOPER model? A. Steve Lin. Q. Do you know where the results of that model will be located? A. In the Cyber. Q. And how would one locate the results? Is there a log of the results of work done using the DWOPER model? A. Steve Lin would have such a log? Q. Are you familiar with a model that's HSPF? A. Yes. No. Excuse me. I'm not entirely familiar. ** 32 Q. Are you familiar with a model that's HEC? A. You need to be more specific. Q. It's the abbreviation. A. There's several HEC models. Q. Are any of them utilized by your division? A. Yes. Q. Which ones? A. HEC 1 and HEC 2. Q. And what does HEC 1 do? A. It does essentially flow routings. Q. And who utilizes the HEC 1 model? A. Steve Lin. Q. And what is the source of the data for the HEC 1 model? A. Primarily rainfall, topographic information, flows. Q. What is the HEC 2 model? A. It is a channel routing model. Q. And who utilizes the HEC 2 model? A. Various people. Q. Is the HEC 2 model utilized for doing any modelling in the Water Conservation Areas? A. No. Q. Is it utilized for modelling in the Everglades Agricultural Area? ** 33 A. No. Q. Is it utilized for modelling in the Everglades National Park? A. No. Q. Are you aware of a model called CREAMS? A. Yes. Q. And what does that model do? A. That model is an agricultural water shed model. Q. What is the source of the data in that model? A. Rainfall, ET, soil characteristics. Q. And where is the data obtained from to run that model? A. DB Hydro or geographic science -- and geographic science. Q. And who uses the CREAMS model? A. Several people. Q. And where would the results of the CREAMS modelling be located? A. It would be in the Cyber. Q. Is the CREAMS model utilized for remodelling the Water Conservation Areas? A. It hasn't been, no. Q. Has it been utilized for modelling ** 34 Everglades National Park? A. No. Q. Has it been utilized for modelling the Everglades Agricultural Area? A. No. Q. Are you aware of something called Estuarine system computer model? A. Yes. Q. Is that model utilized by the division? A. Yes. Q. Who utilizes that model? A. Todd Teizdale. Q. And what does the Estuarine system computer model do? A. This model modelled the different estuaries. Q. And what is the source of the data utilized? A. Again, DB Hydro, geographic science, and also salinity data from our model scientists. Q. Are you aware of a program that's abbreviated OASIS? A. Yes. Q. And what does that program do? A. That program is a prototype of an expert ** 35 system. Q. Does that prototype input into operation? A. Not to my knowledge. Q. Who was developing OASIS? A. You need to be more specific. Q. Was it somebody in the Water Management District that was developing -- A. Gary Goforth and Venito Floris. Q. And what was the second name? A. Venito Floris. Q. Are you aware of a program called a storm water permit application evaluation expert system? A. Yes. Q. Is that system being utilized by the Water Management District? A. I don't know. Q. What does that system do? A. That was a contract that district -- MS. STOLLMAN: Is this a computer system that you're asking about? MS. NASH: Yes. A. What does that do? Q. (By Ms. Nash) Yes. A. Essentially make the permitting process more user friendly. ** 36 Q. Do you know who would know whether that system is being used? A. Jeannie Hall. Q. And what division is Jeannie Hall in? A. She is the department director of regulation. Q. Are you aware of something called the MAXIMA program, "M-a-c-s-y-m-a" [sic]? A. Not by that name. Q. Are you aware of what remote sensing technology the Water Management District is utilizing? A. In general. Not in a specific. Q. And who would know specifically? A. Dewey Worth. Q. Are you aware of a software package called Prob Plot? A. What? Q. Prob Plot, P-r-o-b P-l-o-t? A. P-r-o-b? Q. P-l-o-t, it's a software package. A. In general, I am. Q. What does that software package do? A. Essentially, plot probability information, statistical information. It's a plotting routine. ** 37 Q. And who developed that software package? A. I don't know. Q. Is it being utilized by your division? A. At times. Q. Is the water resources division doing any projects at the present time relating to the Everglades Agricultural Area? MS. STOLLMAN: This would be computer projects. A. Not at the present time, no. Q. (By Ms. Nash) Is the division doing any projects at the present time related to the Water Conservation Areas? A. No. Q. Is the division doing any projects at the present time related to the Everglades National Park? A. Yes. Q. And what is that project? A. We are awaiting some projects that the Corps of Engineers is proposing for that area. Q. And who is responsible for that project? A. Ray Santee. Q. Does that project have a name? A. There are two specific projects that we ** 38 have already. One, is raised with a C-111 plan, and the other one is a rainfall formula for Taylors Slough. Q. And what is the source of the data being utilized for the C-111 plan? A. Essentially, DB Hydro. Q. And what perimeters are being reviewed on the model? A. Rainfall, ET flows, also Corps of Engineers information. Q. And where would the results of that project be? A. In the Cyber. Q. And what's the source of the data for the rainfall formula for Taylors Slough project? A. Again, same as the other one. Q. Is this also Ray Santee's project? A. Yes. Ray Santee and Calvin Neidrauer, N-e-i-d-r-a-u-e-r. Q. Is there any topographic data that you utilize that is not from geographic sciences? A. Yes. Q. Where is that topographic data from? A. It came from the national park. Q. Any other sources? ** 39 A. Not that I know of. MS. NASH: I have no further questions. MS. STOLLMAN: All right. Could we take a break? MR. RICHARDS: Sure. (Short break.) CROSS-EXAMINATION QUESTIONS BY MR. RICHARDS: Q. Mr. Marban, my name is Joe Richards. I represent the cities of Belle Glade and Clewiston. In these models that you mentioned, do they contain discharge rating curves for the district's structures? A. It contains a modification of those discharge rating curves that we have for that particular model. Q. From where did you obtain the discharge rating curves? A. From the district structure handbooks. Q. Would those be the Corps of Engineers' operational manuals? ** 40 A. Yes. Q. And who at the district performs the modifications on those rating curves? A. Operations. Ron Mierau would be able to answer that question. Q. You mentioned some modelling for the Everglades SWIM plan. Do you know whether the results of these modellings are contained in the plan? MS. STOLLMAN: Could you repeat that question. I'm sorry. I didn't understand the last word. MR. RICHARDS: Contained in the plan. A. No, not that I recall. Q. (By Mr. Richards) Do you know whether water balance has been performed for the Everglades Agricultural Area? A. Yes. Q. Is that that same water modelling that you talked of earlier? A. No. The water -- the water balance was performed as a result of some controversy over the floating. Q. Do you know who in the district performed that water balance? ** 41 A. As I mentioned before, Paul Trimble and Terry Ortel. Q. And the results of that water balance -- MS. STOLLMAN: What is your question? Q. (By Mr. Richards) -- where would they be contained? A. In the Cyber. Q. Were the results ever published? A. They were presented at a board meeting. Q. You mentioned a water modelling for Everglades National Park that utilized some information obtained from the park. What information was obtained from the park? A. Another topographic information. Q. Anything else? A. Not that I can recall. Q. Were the results of this study published? A. They haven't been published yet. We are still working on these results, on these questions. Q. When do you expect those results to be completed? A. I presume by October 1st. Q. For the water balance, that was prepared when, do you know, for the EAA? ** 42 A. That was prepared during the month of March and April, in that time. Q. You said that the water resources division doesn't prepare modelling for the Water Conservation Areas. Do you know who does? A. The Corps of Engineers. Q. Does the district possess the results of those efforts? A. We receive preliminary information on a monthly basis. Q. You mentioned that Ray Santee was doing some assessment of water quantity impacts of retention in the Everglades Agricultural Area. Do you know when this study was performed? A. It was not retention in the Everglades Agricultural Area. It was a Water Management -- the proposed Water Management Areas. What was the question? Q. Do you know when that was performed? A. I don't remember just that date, no. Q. Generally in the last year? In the last two years? A. Oh, yeah, last year, yes. Q. The topographic information you obtained from the geographic sciences division, do you know ** 43 what data base that is contained in? A. I don't know the name of the data base. Normally, when we acquire information, we ask them. Q. Is that information obtained in a computer format? A. Yes. Q. What format? A. I don't know. Q. Does anyone in your division use SAS statistical software for analysis of data? A. We use the statistical software, different packages. Q. For what purpose do you use it? A. To display and analyze information. Q. And who in your division performs these analyses? A. Shawn Sculley, primarily. Q. Has your division ever examined or evaluated the pumping efficiency of any of the district's pumps? A. No. Q. Do you know who would perform that work? A. Operations. Q. You said that occasionally you use USGS data. By what means do you obtain this data? ** 44 A. Through -- you know, through computer -- you know, through tapes, computer tapes. Q. You mentioned that the results of modelling efforts are retained on the Cyber computer? A. Uh-huh. Q. Do you know for what period of time? What length of time the results of modelling efforts are retained? A. Sometimes we don't retain all the information that is in the model, only the one that we need for the specific purpose. Some of these models contain a lot of information, and it's difficult to retain it in the computer all the time. Q. But if it is retained on the Cyber, how long is it retained? A. It varies. It varies with the project. Q. Generally, do you maintain stuff for a year, two years? A. I can't answer specifically. In general, we would maintain it until we feel the project -- until we've published the results of the project. Q. Does your division have quality assurance or quality control procedures for their modelling ** 45 efforts? A. What do you mean by that? Q. Are there formal guidelines set up for running models? A. The computers are -- the models are first calibrated and then verified to be sure that they represent whatever they're trying to model. Q. Is that done each time before a model is run? A. Oh, yes. This is -- this is done initially when the model is -- is being tested. After that -- it's not done unless the model is modified. Q. Is there an official policy within your division for computer operations for quality control and quality assurance? A. I don't know what you mean by "official policy." We are trying to get the best data that we can and the best methods that we can to examine the data. Q. Is there a published document on quality assurance or quality control utilized by your division? A. No. Q. Are you familiar -- ** 46 A. Can I clarify that previous question? Q. Sure. A. We have published the calibration procedures and the verification procedures of all these models. If that constitutes a quality assurance, those have been published. Q. Yes. Where have those been published? A. In the technical publications that refer to the specific models. Q. Do you or people in your division ever request that data be changed in the DB Hydro data base? A. No. Q. Have you ever found the data on that DB Hydro data base to be in error? A. Not personally. I haven't, no. Q. Are you aware of anyone else that has found errors in the data base? A. Not that I know of. Q. Are you aware of any instances where data files have been lost? A. No, not personally. MR. RICHARDS: I have no further questions. Thank you. ** 47 (The deposition was concluded at 10:45 o'clock a.m.)