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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 RONALD MIERAU
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
DOUG RONALD MIERAU
By Ms. Beverly Nash 5
By Mr. Joe Richards 28
** 3
The deposition of Ronald Mierau, 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 10:55 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
Robert Johnson
Ray Roberts
** 5
THEREUPON,
RONALD MIERAU
being by me first duly sworn to tell the whole truth,
as hereinafter certified, testified as follows:
DIRECT EXAMINATION
BY MS. NASH:
Q. Mr. Mierau, I'm Beverly Nash. I'm 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 the computers, and how it's formatted.
You were selected by the district as a
representative having knowledge concerning one or
more of the categories of inquiry which we're
interested relating to the computers.
Have you been shown that list of
categories?
A. Yes, I have.
Q. Do you know which ones you're able to
respond?
A. I believe it's 2, 3, and 6.
Q. What is your present title or position?
A. I'm the director of the operations
** 6
division.
Q. And that's in which department?
A. The operations and maintenance department.
Q. And what are your responsibilities as the
director?
A. I'm responsible for physically moving the
water around to balance flood control, water
supply, and environmental needs. We do that
through operation of gates and pump stations.
Q. And how long have you been director of the
operations division?
A. Since April 1990.
Q. Have you had other positions at the Water
Management District?
A. Yes.
Q. What positions?
A. Previous to that, I was interim director
of the water quality division for a period of
approximately six to nine months. Prior to that, I
was the director of the data management division.
Q. What were your responsibilities as the
director of the water quality division?
A. Essentially, I was performing
administrative tasks to fill-in while they were
recruiting a qualified person with both
** 7
administrative and water quality skills.
Q. How long were you director of the data
management division?
A. I don't recall the exact length of time.
I know it was several years.
Q. And what were your responsibilities in the
data management division?
A. To coordinate the data acquisition and
archival of hydrologic information.
Q. What's your educational background?
A. I have got a bachelor's degree in civil
engineering from the University of Nebraska; and a
master's degree from Colorado State University in
water resources engineering.
Q. To whom do you report in the operations
and maintenance department?
A. Alan Hall.
Q. Do you have employees that work for you?
A. Yes.
Q. How many?
A. Approximately 20.
Q. What is the general nature of the
positions that work for you?
A. I have got some control room personnel
which are technicians and supervisors. We have a
** 8
24-hour shift that monitors the real time
information to determine hydrologic conditions at
any time and operate the gates under emergency
conditions, that's the majority of the staff.
I have currently two computer programers
and one supervisor. Then, I've got a meteorologist
and a temporary meteorologist, and one person
that's working currently on artificial intelligence
systems.
Q. What computers are utilized by the
operations division?
A. We have got a pair of Modcomp computers,
which do our real time data acquisition and
control. We have got several PCs, personal
computer type equipment. That's currently all that
-- the only types that we use directly.
We access also the information on our
Cyber in our system for historical information,
historical hydrologic information.
We had a prototype artificial intelligence
system developed on Symbolics equipment, and we are
not using that anymore.
We will be looking for some other type of
computer equipment to put that platform on, but
that hasn't been decided yet.
** 9
Q. What software is utilized on the Modcomps?
A. That's custom software plus the Modcomp
operating system.
Q. Is that developed by Modcomp or within the
Water Management District?
A. The software applications were developed
within the Water Management District and on
contract to -- by a contractor for the Water
Management District.
Q. Do you know who within the Water
Management District developed the software?
A. Rudi Vyhnanek was in charge of
supervising that. I believe that was -- the
original system was developed considerably before I
got involved with the operations department.
Q. And do you know who the outside contractor
was?
A. I don't recall.
Q. What's the software packages utilized on
the PCs?
A. The PCs routinely use Word Perfect,
Symphony, Picture Perfect, some communication
packages. There may be other less prominently used
ones. Most of those are standard software packages.
Q. Does the division utilize any in-house
** 10
software packages?
A. I don't believe that's the case. There is
an application that we use fairly frequently that's
written on a GEM system that was done in-house
several years ago. It wasn't done within the
division, but we utilized it frequently. That
application accesses data from both our Modcomp --
our -- a summary of the information on Modcomp,
which is stored on Micro VAX computer. I'm sorry.
I neglected that one -- and there we have an Oracle
data base established as an interim type thing
until we get a better data base system developed
to handle that. They had also linked up the Cyber
computer, so we can get merge historic and current
hydrologic information and plot that up through the
graphics package that was -- that application for
that graphics package was developed in-house.
Q. Do you know who developed it?
A. Paul Wright.
Q. Are reports or analyses done of the data
that comes in to the operations division?
A. We routinely make reports that our board
of directors use, our governing board uses, for
informational purposes on a monthly basis called a
water conditions report.
** 11
Q. And what's the data base that's utilized
to do the water conditions report?
A. It comes from a combination of a set of
paper files, which we log our daily water readings
on from our Cyber data base, which is DB Hydro,
again, the historical hydrologic information and
the summary of our Modcomp information, which is
kept on our Micro VAX.
Q. The summary of information you're talking
about being kept on Micro VAX, is that data that's
been processed in some fashion?
A. It's processed through the Modcomp and
gives us information, like, water levels -- the
most critical ones that we use for that report are
water levels, we use gate openings and -- to
compute the flow with. Gate openings aren't
reported directly in the reports. We do compute
the flow, which is used -- indirectly requires the
gate openings, pump rpms, and water levels, in
conjunction with rating curves.
Q. You indicated that you have an employee
working with artificial intelligence systems?
A. Yes.
Q. What is the nature of those systems?
MS. STOLLMAN: This will be the
** 12
computer systems.
A. The computer system, right now we are
still in the process of selecting a computer system
for this to work on. We have originated a
contract. We call this artificial intelligence
system OASIS. And I'm not sure exactly what the
acronym means right now. It's something like --
well, I'm not sure exactly what it means.
Q. (By Ms. Nash) Who developed OASIS?
A. That was originally started under Gary
Goforth, who is no longer with the division. We
had a consultant at that time who did some
prototype work for us. Paul Ryan, which is
currently a programer with our system, did some
work on it; and it's been devaluated as a prototype
model for our next phase, which we are getting in
to now, by two different consultants.
Q. Do you know who the consultant was that
did the prototype work?
A. I don't recall.
Q. You indicated that part of the
responsibilities of the division is to look at
environmental needs or the operation of the gates
in the pumping stations?
A. We try to balance --
** 13
MS. STOLLMAN: Is your question
limited to his work that he does on the computer
systems?
MS. NASH: Well, the computer systems
are utilized to operate these. And I'm trying to
find out the perimeters that they consider when
they're doing the operation.
MS. STOLLMAN: And what was your
question again? Could you read it back for me?
(WHEREUPON, the requested testimony
was read back by the court reporter.)
MS. STOLLMAN: To the extent that
this is work on the computer system, you can answer
that.
A. We don't establish the environmental
criteria. There are times when, within our
operational policy, that it's necessary to balance
environmental concerns with flood protection and
water supply needs.
Q. (By Ms. Nash) Who establishes the
environmental criteria?
A. That's generally done in coordination with
--
** 14
MS. STOLLMAN: I would object to that
question unless you're asking about the
environmental criteria done on the computer.
MS. NASH: They may well be, but let
him answer the question, so I can find that out.
MS. STOLLMAN: Well, I'd like to --
MS. NASH: This is a background
question, Katharine. It is a background question
that I am entitled to have asked to find out who
establishes the criteria.
MS. STOLLMAN: To the extent the
criteria are established on the computer systems,
you may answer the question.
A. The criteria aren't currently established
on the computer systems. They're done through
operational rules that haven't currently been
computerized.
Q. (By Ms. Nash) And who's developed the
operational rules? What office or division?
A. These operational rules are based on Corps
of Engineers criteria, first of all, for operation
of structures and the original project design.
There have been modifications in the past that have
gone through a series of multiagency review, and
regulation schedules have been developed on that
** 15
basis and modified on that basis.
Q. When you were talking about the artificial
intelligence project, do you know what
environmental considerations are taken into account
in that project?
A. That's not currently a function of the
artificial intelligence system. The phase of the
artificial intelligence system we're working on
currently is an intelligence warning system. This
conceptually will give us active warnings on
whether we have information that makes sense
hydrologically, first of all, to apply some sort of
intelligence criteria to the incoming data stream
to verify that this is reasonably accurate
information coming back there. There are times
when senses malfunction and we need to know that.
In addition to that --
MS. STOLLMAN: I think this is
nonresponsive to your question. If we could have
the question read back.
MS. NASH: He's explaining what the
artificial intelligence project considerations
are. It is responsive to the question. He can
finish the answer.
MS. STOLLMAN: I would like to have
** 16
the question read.
(WHEREUPON, the requested testimony
was read back by the court reporter.)
MS. STOLLMAN: The question has been
asked and answered.
MS. NASH: He was finishing -- yes, I
want him to finish the answer he was giving. He
was explaining what the system is currently
considered.
MS. STOLLMAN: Well, he answered
your question that's not currently a part of it.
If you have another question, please ask it.
MS. NASH: Fine.
Q. (By Ms. Nash) What is the current phase
of the system looking at?
A. The current phase of the system is
providing an intelligence warning system to help
detect sensory malfunctions and to project whether
our current operations are going to meet our -- our
current objective is for maintaining water levels
in the areas over which we have control.
Q. Is the operations division the one that
actually receives the raw data from the remote
** 17
sensing locations?
A. Through our telemetry system, we do
receive directly those sensory readings. In
addition, we receive reports from our field
stations on sensors that aren't currently
accessible through the computer. They come in over
radio or paper forms.
Q. And where is that data stored that comes
in?
A. Which data?
Q. The telemetry data initially?
A. The telemetry data is initially stored on
Modcomp computer system then is transferred to our
Micro VAX Oracle data base, which I described
previously as a temporary situation, and nightly is
moved to the preprocessing system under data
management where it goes through further
verification process; and finally, ends up residing
in some reform on DB Hydro, which is also on the
Cyber system at the current time.
Q. What is the further verifications that's
done in the preprocessing system?
A. They check -- the data management
division checks -- at least during the time where
I was actively involved with this process, they
** 18
check for continuity in data sets, continuity of
transmissions to verify whether we really had
continuous information as was indicated on the
files to apply a rate of change checks and to apply
a limit checks in terms of exceeding reasonable
maximum minimums. In addition to that, a cross
station performance was checked manually through
plots of this data.
Q. Is the data that was received in paper
form or over radio put into the computer?
A. I don't believe all of it was put into the
computer, but the more critical ones that people
use all the time are.
Q. When you say, "more critical," are you
referring to more critical field stations or more
critical types of data?
A. More critical types of data. There are
some types of data that -- some locations in which
data is needed periodically, not on a continuous
basis -- that information hasn't currently been in
access. Particularly those that are incurred in very
infrequent intervals simply haven't been provided
for in our electronic system.
Q. Do you know the nature of the data that's
not being computerized?
** 19
A. In general it's what we call staff gauge
readings in very remote sites that we have very
little operational control over. By "staff gauge
readings," I mean readings that are manually
observed from some -- you might say, "ruler," some
way of measuring water levels someplace. Generally
they're very remote and are taken manually. We
don't have any electronic means of acquiring that
information now.
Q. You indicated that incoming data is
checked for rate of change or limit checks. What
procedure is followed if the data exceeds the
limits?
MS. STOLLMAN: Is your question
finished?
MS. NASH: Yes.
MS. STOLLMAN: This would be limited
to computer procedures which are followed.
A. Again, I'm not directly involved in that
process at the current time. That process is being
carried on in the data management division.
Q. (By Ms. Nash) What was the process when
you were in data management?
A. When I was in the data management
division, we looked for a physical cause for that.
** 20
If a physical cause -- if it was determined that
that rate of change really was realistic -- because
our estimates of rate of change are based on
previous experience -- if our professional
hydrologist determined that these rate of changes
were really reasonable, then, we'd change the
limits under which these flags would be made.
If it was determined that it was an
instrument malfunction, which caused the rate of
change problem, then, a probable cause for that was
sought and values were estimated, if possible, to
correct that situation. If it wasn't possible to
correct that rate of change situation with
reasonable confidence, then, those values were
flagged as missing or unavailable.
Q. Are there back-up procedures for the
incoming data?
A. You're referring to which data now?
Q. The raw data that comes in, is there a --
A. From which source?
Q. From any source?
A. The raw data that comes in through the
Modcomp system is backed up on tape on a daily
basis and then goes through the additional
procedures that I mentioned earlier.
** 21
MS. STOLLMAN: Can we go off the
record for a moment?
(WHEREUPON, there was a discussion
held off the record.)
(WHEREUPON, the requested testimony
was read back by the court reporter.)
Q. (By Ms. Nash) Do you know the retention
period for these back-ups tapes?
A. No.
Q. Do you know who would know?
A. Rudi Vyhnanek.
Q. When the data winds up in DB Hydro, do you
know whether that's also backed up?
A. That is backed up.
Q. Do you know the procedure for that
back-up?
A. I don't recall specifically.
Q. Do you know who would know?
A. Bill Hall.
Q. Do you know the retention period for that
back-up?
A. To my knowledge, that was to be retained
** 22
permanently.
Q. Do you know the period of record for the
data in DB Hydro?
A. Yes.
Q. What is that?
A. It dates back to, in some cases, the early
1900's.
Q. Is there a listing of which locations the
data goes back that far?
A. There is a listing available of the dates
for all information. It's not -- to my knowledge,
there is not a list chronologic or sorted by period
of record available.
Q. Where is that list available?
A. From data management.
Q. Does the list have a name?
A. I don't recall what the name of the list
is.
Q. Who would know?
A. Rob Startzman.
Q. When you were in data management, what
computers were utilized?
A. We utilized the Modcomp, some PCs, and we
did access the Modcomp -- or I'm sorry -- the Micro
VAX, which has the Modcomp data summaries on it, as
** 23
through the procedure I mentioned earlier.
Q. And data management is the keeper of the
archive of hydrologic data?
A. That's correct.
Q. And that's in DB Hydro?
A. That's correct.
Q. Is there other hydrologic data that data
management maintains?
A. Would you clarify that question?
Q. Is there hydrologic data maintained by
data management that's not in DB Hydro?
A. Not to my knowledge. I'm sorry. The DB
Hydro does not contain a summary of gate
information.
Q. Where is that summary of gate information?
A. There is another source of files within
data management called Breakpoint Archive System.
The gate information is stored in that area.
Q. What else or what is contained in this
summary of data information that's not in DB Hydro?
A. Gate opening information.
Q. Anything else?
A. And pump rpm information.
Q. I'm sorry?
A. Pump rpm.
** 24
Q. While you were in data management, were
analyses done in that division on the data in DB
Hydro?
A. The primary function of data management
was to maintain accurate archives of that
information and the collection?
A. It was required to do some analysis on
that historical information to further this
validation process.
Q. Can you elaborate on what that analysis was?
A. Things like comparing mean values from
year to year, reasonable ranges in fluctuation.
Q. Anything else?
A. Some -- it was necessary to develop some
feel for intrastation correlations, if not
statistically, at least, qualitatively.
Q. Are these analyses that were done stored
anywhere?
A. What's that?
Q. Are the analyses that were done stored
anywhere?
A. Not to my knowledge.
Q. Were the analyses provided to anyone
outside the data management division?
A. Not to my knowledge.
** 25
Q. Are you aware of any computer water
quality analyses being done as part of the SWIM
Plan?
MS. STOLLMAN: Again, it would be
analyses done on the computer systems.
MS. NASH: That's what my question
asked.
A. There was some work -- some analysis done
in the water quality division on water quality
perimeters for the SWIM Plan.
Q. (By Ms. Nash) Do you know who did that
analysis?
A. I believe Dave Soballe did at least part
of it.
Q. Do you know what water quality perimeters
were looked at?
A. Phosphorus was one.
Q. Do you know of any others?
A. I believe nitrogen was also analyzed, but
I'm not certain about that.
Q. Do you know where the results of these
water quality analyses are?
A. Of the analyses or of the records? Would
you clarify the question, please?
Q. Yes. You indicated that Dave Soballe did
** 26
some analyses as part of the SWIM, and my question
was, where are the results or where are these
analysis stored and located?
MS. STOLLMAN: Are you asking what
computer system they're stored and located on?
MS. NASH: If that's where they are.
A. I don't know that the analyses are stored
on a computer. The results were incorporated in to
the SWIM Plan.
Q. (By Ms. Nash) Who would know?
A. Dave Soballe.
Q. Do you know whether any computer water
quality analyses were done for the Nutrient Removal
Project?
MS. STOLLMAN: You can answer if you
know.
A. I don't know that answer to that one.
Q. (By Ms. Nash) Do you know whether any
computer water quality analyses were done for
Everglades National Park outstanding natural
resource water standards?
A. I'm not aware of the analyses that went on
in that process.
Q. Do you know who would know?
A. Tom Fontaine.
** 27
Q. Do you know whether any computer water
quality analyses were done for state water quality
violations?
A. I don't know.
Q. Do you know whether any nutrient budget
analyses have been done for the Everglades
Agricultural Areas?
A. I'm not aware of any.
Q. Do you know whether any nutrient budget
analyses have been done to the Water Conservation
Areas?
A. I don't know.
Q. Do you know whether any nutrient budget
analyses have been done for Everglades National
Park?
A. I don't know.
Q. Do you know whether any water quality
trend analyses have been done for the Everglades
Agricultural Area?
MS. STOLLMAN: I don't want you to
speculate. You can answer if you know.
A. No, I don't know.
Q. (By Ms. Nash) Do you know whether any
water quality trend analyses have been done for the
Water Conservation Areas?
** 28
A. I don't know.
Q. Do you know whether any water quality
trend analyses have been done for Everglades
National Park?
A. I don't know.
Q. Do you know whether any computerized water
quality analyses have been done for establishing
best management practices in the Everglades
Agricultural Areas?
A. No, not that I know of.
Q. Do you know who might know?
A. I presume Tom Fontaine may know. Tony
Federico is probably a better source than Tom
Fontaine.
MS. NASH: I have no further
questions.
CROSS-EXAMINATION
QUESTION BY MR. RICHARDS:
Q. Mr. Mierau, my name is Joe Richards. I
represent the cities of Belle Glade and Clewiston.
You talked about the Breakpoint Archive
System?
A. Uh-huh.
** 29
Q. How does one access this system?
A. To my knowledge --
MS. STOLLMAN: I don't want you to
speculate. If you know how the system is accessed,
you may answer.
A. At the time that I last accessed it, when
I was involved in that system, most people in your
position would request a period of record from data
management in the form of a listing.
Q. (By Mr. Richards) Pardon me?
A. In the form of a listing for specific
station and period of record. There is a lot of
information on that within that system, so to --
you have to get fairly -- it was necessary to get
fairly specific in the request, otherwise, you'd
simply be overwhelmed with the amount of
information that would come back.
Q. Is it possible to obtain information from
this system in the ASCII format?
A. Yes. At the time that I was involved in
it, there was.
Q. And you can access the information by a
specific structure or period of time?
A. By a specific sensored name and time.
Q. Is there a listing of sensored names?
** 30
A. Yes.
Q. Where would that listing be?
A. In the data management division.
Q. Does it not have a name?
A. There's a computer procedure that can be
used to develop this list of names and that
procedure is called STGPOR.
Q. Do you know who is responsible for
maintaining this Breakpoint Archive System?
A. Data management division. Rob Startzman
is the director of the data management division.
Q. Do you know what computer it's contained
on?
A. It's currently on the Cyber system.
Q. And you mentioned that the data management
division performs some annual mean comparisons and
some other analysis. Do you know if these analysis
are used to change data values?
A. Normally, they're not used to change data
values. They're used to form a picture for the
hydrologist on what is reasonable for reviewing the
data for accuracy.
Q. And these hydrologist would then make a
decision on whether to change data values?
MS. STOLLMAN: I object to that
** 31
question. I don't think that's relevant. I don't
think that's part of this witness' knowledge what
he's here to testify about today.
MR. RICHARDS: He was director of
data management. He's testified about these
analyses and the purpose they're used for, and I'm
just trying to find out, you know, what effect that
has on what is contained in their computers.
MS. STOLLMAN: Could you repeat your
question, please?
MR. RICHARDS: Would you read it
back?
(WHEREUPON, the requested testimony
was read back by the court reporter.)
MS. STOLLMAN: Mr. Mierau is not
currently in that department. He can answer to the
extent that he would be aware of the computer
procedures at the time he was there, but that may
not be the case now.
Q. (By Mr. Richards) Please answer to the
best of your knowledge.
A. There -- occasionally, it was possible to
make fairly reliable estimates to change numbers so
** 32
that they were more realistic.
One way, as an example, that this could
occur was through ASCII transmission of data, you
could gain digits. Let's say, the water levels
were in the range of 14 or 15, all of a sudden you
get one value that reads 114 or 115. There is a
good possibility that in the transmission of this
data, you picked up an erroneous bid coming in,
which caused this type of an error. In that
instance, the number would be changed from the 114
down to the 14 and tagged with an estimated value.
Q. (By Mr. Richards) Are these estimated
values indicated in some way on the data base?
A. Yes, they are.
Q. How are these estimated values flagged?
A. Each value has a quality -- each value has
a time value and a quality tag associated with it.
Q. And who at the district would be presently
most knowledgeable as to this process you just
described?
A. Rob Startzman is in charge of that
procedure. He may have delegated some people that
are more knowledgeable to do the actual procedure.
Q. Do you know whether there is any written
guidelines or policies on this process?
** 33
A. Not to my knowledge.
Q. Are there any informal policies or
guidelines?
A. During the time I was involved with this
process, that type of information had to be -- when
changes were made to actual data values, those
changes had to be cleared through myself or another
qualified professional hydrologist.
Q. When it was cleared through yourself, you
were director of data management at that time?
A. That's correct.
Q. Do you know how frequently those changes
are needed to be made?
A. Changes were made to data values very
infrequently. If the data values were totally
unreasonable, it was much more likely that those
values would be tagged with another type of field,
which means -- which was an "M" for missing
information.
Q. In regard to the artificial intelligence
system you described earlier, you mentioned that
the system is designed to detect if the operations
meet the objectives. What objectives would this
be?
A. That is still under a development process.
** 34
Q. What objectives will there be?
MS. STOLLMAN: I would object to this
question. He can answer what objectives there are
currently in development, but the answer may not be
complete as to all objectives that could be
developed in the future.
Q. (By Mr. Richards) To your knowledge.
A. One of the objectives that we're looking
at implementing is to have target water levels,
which meet our expectations, and compare those
against trends which are currently developing from
our current operational decisions.
Q. Any others?
A. That's the primary mode right now.
Q. Do you know whether there are computer
records of the regulation schedules for the water
conservation areas?
A. Computerized regulation schedules, is
that what's --
Q. Yes.
A. Are those available?
MS. STOLLMAN: What was your
question? Could you repeat it back, please?
Q. (By Mr. Richards) Does the district
possess a computerized regulation schedule for the
** 35
Water Conservation Areas?
A. I would have to speculate on that.
MS. STOLLMAN: I don't want you to
speculate. If you know, you can answer the
question.
A. I'm not positive.
Q. (By Mr. Richards) Who would know whether
their regulation schedules are contained on
computer?
A. If they are contained on the computer,
Jorge Marban would be the most probable source for
knowing that.
Q. Do you know whether there are computer
records of how a particular regulation schedule was
followed for a particular year?
MS. STOLLMAN: Again, you can answer
if you know. I don't want you to speculate.
A. Well, would you rephrase that, please?
Q. (By Mr. Richards) Are there computer
records of how a regulation schedule was followed
for a particular year?
A. There are historical archives which
indicate what actual water levels were.
Q. Where would those historical archives be
contained?
** 36
A. They're contained in DB Hydro and in
detailed form within the Breakpoint Archive
System.
Q. Do you know whether the operation and
maintenance manuals prepared by the Corps of
Engineers are obtained in a computer format?
A. Not to my knowledge.
Q. Do you know, does the district possess
discharge ratings curves for the different
structures?
A. The district possesses computerized
discharge ratings curves for some structures.
Q. Which structures?
A. I don't recall the names of all those
structures. There is quite a few. There is a
considerable number.
Q. Do you have computerized discharge ratings
curves for the S5A structure?
A. Yes.
Q. S6?
A. Yes.
Q. S7?
A. Yes.
Q. S8?
A. Yes.
** 37
Q. S2?
A. I believe the USGS has computerized
discharge equations for S2.
Q. How about S3?
A. The same situation on S3. The district
also has -- on the case of S3, the district also
has a computerized discharge equation, but that's
not used for official records. The USGS maintains
the official records at that station.
Q. And S4?
A. I'm not positive about S4.
Q. S150?
A. The district has computerized equations
for S50 -- S150. I'm sorry.
Q. How about S9?
A. The district has a computerized equation
for S9.
Q. And where are these maintained?
A. At the time I was in data management, they
were maintained in a production program called E034,
E034.
Q. Do you know whether these discharge rating
curves are verified for accuracy?
A. Yes.
Q. Do you know how often?
** 38
A. There is currently an effort to verify all
of these equations through stream gauging.
Q. That is an ongoing process right now?
A. That is an ongoing process right now.
Q. Do you know when the last time that the
discharge rating curves were verified?
A. For which structures?
Q. S5A.
A. S5A has some recent measurements -- I
believe last month, maybe some this month.
Q. And before that, do you know when it was
verified?
A. There was some question posed as to the
reliability of the discharge equations at that
structure earlier this year, and I believe the
ratings were -- stream flow measurements were
started as soon as the water was available this
year, which, I believe, was in late May or early
June.
Q. And for structure S6, when was the last
time?
A. Also, I know there is at least one -- at
least one measurement and perhaps several
measurements since water was available between June
and the current date.
** 39
Q. And S7?
A. Same situation on S7.
Q. S8?
A. Same situation on S8.
Q. S150?
A. I'm not sure when the last stream flow
measurement was made on S50.
Q. S150?
A. S150, I'm sorry. I don't believe there
was any made this year.
Q. What about S9?
A. There has been at least one discharge
measurement made at S9, during this same period,
since water was available this year.
Q. In the past were these verified on any
kind of routine basis?
A. The USGS -- on the stations that the USGS
was involved in, they made measurements on a
frequency which they felt was adequate to maintain
confidence in the rating curves.
The Water Management District did not
follow procedure where they routinely verified the
rating curves.
There was substantial effort, after the
structures were initially established to develop
** 40
rating curves and flow measurements. Once those
were verified, it was assumed that these curves
wouldn't change substantially. This was verified
periodically by spot measurements at stations -- at
some stations.
Q. Do you know which stations?
A. I don't know.
Q. Besides the S3 and S2, what other stations
are USGS responsible for?
MS. STOLLMAN: You can answer if you
know. I don't want you to guess.
A. Would you be more specific in terms of
area or -- I may be able to help someone there.
Q. (By Mr. Richards) In the Everglades area?
A. In the Everglades Agricultural Area?
Q. Okay. Let's start there.
A. The USGS is responsible for the official
records on S5A, S2 and S3, and the associated
revenue flow structures.
Q. What about the S10 structures?
A. The S10 structures are the responsibility
of the Corps of Engineers. I'm not positive, but
the USGS may be involved in that procedure through
contract with the Corps of Engineers, but I'm not
positive on that.
** 41
Q. How about the S11 structures?
A. The same situation with S11.
Q. And the S12?
A. The S12, the USGS computes the flow
for the Corps of Engineers. They also give us
access to that information. I think the National
Park Services is also involved in funding that
station.
Q. When you were the data base management
director, were you aware of any data files lost
from the system?
A. No.
Q. Are you aware of any data lost from the
operations division computers?
A. No. I am sorry. There is times when our
communication system breaks down and we have no
provision at the current time for on site storage
of the telemetry system information. And during
the times that our transmission facilities don't
work, data is lost.
Q. Is that lost data somehow indicated in the
historical archive?
A. That is one of the functions of the data
management division to insure that all those
periods when we weren't receiving information from
** 42
the Modcomp system that those are flagged as
missing periods.
Q. Do you know what individual would be most
knowledgeable as to the discharge rating curves and
where they're maintained?
A. "Most knowledgeable," is sometimes
difficult to put a handle on. As for myself, I
have some knowledge of that. I'm sure Rob
Startzman would have some knowledge of that.
Q. Do you know who performs the
verifications?
A. Data management division.
Q. Do you know who in the data management
division?
A. I believe that the assignment for
verification of information is distributed among
several peoples.
Q. Do you know who those people are?
A. I would suggest talking -- I would suggest
Rob Startzman is the source for those personnel
assignments.
Q. Do you know at what points or steps in the
transfer of data between computers the transfer is
done by ASCII transfer?
A. Would you repeat the question, please?
** 43
Q. At what points or steps in the transfer of
data between computers is the transfer done by an
ASCII transfer?
A. To my knowledge, all the transfers between
computer systems are done in ASCII mode.
Q. Are transfers ever performed by using what
is known as an "error free protocol"?
A. I'm not sure what an "error free protocol"
is.
Q. Are the transfers done over the network?
A. The transfers are done over the network.
MR. RICHARDS: Thank you. I have no
further questions.
(The deposition was concluded at
12:15 o'clock p.m.)
