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Deposition from United States v. SFWMD, et al., Case No. 88-1886-CIV-HOEVELER |
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Deposition from United States v. SFWMD, et al., Case No. 88-1886-CIV-HOEVELER |
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** 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.)
