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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 BRENT MOLL
TAKEN ON BEHALF OF THE PLAINTIFF
***
DATE: August 27, 1990
PROFESSIONAL REPORTING SERVICE
Commerce Center
324 Datura Street, Suite 303
West Palm Beach, Florida 33401
(407) 659-4046
** 2
INDEX
August 27, 1990 DIRECT CROSS REDIRECT RECROSS
BRENT MOLL
By Ms. Beverly Nash 5
By Mr. Joe Richards 23
** 3
The deposition of Brent Moll, 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 1:10 o'clock p.m., on
August 27, 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
** 5
THEREUPON,
BRENT MOLL
being by me first duly sworn to tell the whole truth,
as hereinafter certified, testified as follows:
DIRECT EXAMINATION
BY MS. NASH:
Q. Mr. Moll, I'm Beverly Nash, counsel for
the United States in this litigation.
We're here today to understand how the
Water Management District's computers are set up,
how they're used, what the nature of the data is on
the computers, and how that data is formatted.
You were submitted as a representative of
the district having knowledge of one or more areas
of inquiry that we're interested in.
Have you been shown the list of
categories?
A. Yes.
Q. Which categories are you here to respond
to today?
A. All the ones I have knowledge of.
Q. And what are those?
A. May I have the list, please? Should I go
** 6
through them sequentially?
Q. Yes.
A. Okay. I have knowledge of Area 1. I have
knowledge of Area 2. I have knowledge of Area 3.
I have knowledge of certain areas of Area 4, Area 5
appropriate to the systems in Area 4. I have
knowledge of (6) e., (6) h., (9) a., (9) c., (9) d.
Q. Thank you. What is your present title or
position?
A. I am senior planner of geographic
information systems.
Q. And what division or department is that?
A. Environmental planning.
Q. What is your job description?
A. My function at the district is to design
and develop geographic information systems.
Q. And how long have you been in that role?
A. I've been in that role since September of
1987.
Q. Have you had other positions at the Water
Management District?
A. No.
Q. What is your educational background?
A. I have masters degrees in geography,
geographic information processing, remote sensing
** 7
and computer systems design.
Q. Who are your supervisors in the geographic
information systems?
A. My direct supervisor is David Black.
Q. And what is his title?
A. I'm not aware of what his specific title
is.
Q. Are there employees that work for you?
A. I do not supervise anyone.
Q. Are there others that work with you in
geographic information systems?
A. Yes.
Q. And who are they?
A. To what extent?
Q. Are there others in your office that work
with you?
A. Yes.
Q. And who are they?
A. All the people of the planning
department. There is no -- any specific
individuals whom I work with. I was hired by the
district to plan for the entire district.
Q. What computers do you use at the Water
Management District?
A. I use computers from IBM, Digital
** 8
Equipment Corporation, and SUN Microsystems.
Q. Which IMB computers do you utilize?
A. Personal computer.
Q. Which IBM personal computer?
A. AT.
Q. What work do you do on the IMB AT?
A. Word processing, remote sensing,
geographic information processing, that's all.
Q. What software package or packages do you
use for word processing on the IBM?
A. Word Perfect.
Q. Any others?
A. No.
Q. What software package or packages do you
use for remote sensing on the IMB?
A. ERDAS.
Q. And what software packages do you use for
geographic information processing on the IBM?
A. ARC/INFO.
Q. What work do you do on the DEC?
A. Data access, relational data base
management system access.
Q. Where is the data located that you're
accessing using the DEC?
A. On the computer system. It's not
** 9
physically in my office.
Q. Is the information you're accessing using
the DEC on the DEC or are you using the DEC to
access information on other computers?
A. I used the PC in my office to access
information on the DEC, which is not in my office.
Q. What is the nature of the data on the DEC
that you access?
A. Test data for system development.
Q. Is there a file name for this test data?
A. No specific.
Q. Do you do any other work besides data
access using the DEC?
A. No.
Q. What work do you do on the SUN
Microsystem computer?
A. Develop GIS and remote sensing systems.
Q. What software do you use on the SUN?
A. For what functions?
Q. For whatever functions you used software
for on the SUN?
A. Okay. We have ERDAS for remote sensing.
We have ARC/INFO for geographic information
processing. We have Oracle for relational data
base development.
** 10
Q. Do you use any software that has been
developed internally by the Water Management
District?
A. I program the computer for temporary
programming needs. When I am done programming, I
discard the program.
Q. If I understand your answer, then, there
is not set software packages developed by the Water
Management District that you utilized?
A. No.
Q. What documentation or other manual or
manuals do you use to assist you on your work on
the SUN Microsystems?
A. The documentation provided by the hardware
vendor.
Q. And what documentation or manuals do you
use to assist you in your work with the DEC?
A. The documentation provided by visual.
Q. Are there any internal Water Management
District developed manuals to assist you on these
machines?
A. No.
Q. Can you describe the geographic
information that you're developing on the SUN
Microsystem?
** 11
A. The geographic data on the SUN
Microsystems will be data about spatial
characteristics of the district as stored in a
mapped form, an image form, or a text form.
Q. Does there presently exist data about the
spatial characteristics of the district in map
form?
A. There is no operational data on a system
at this time.
Q. Does there presently exist data on the
spatial characteristics of the district in image
form?
A. Pardon.
Q. Does there presently exist data on the
spatial characteristics of the district in image
form at the present time?
A. No.
Q. Are you doing any GIS work on the Water
Conservation Areas?
A. No.
Q. Are you doing any GIS work on the
Everglades Agricultural Areas?
A. No.
Q. Are you doing any GIS work on Everglades
National Park?
** 12
A. No.
Q. Do you know whether anyone in the Water
Management District is doing GIS work on the Water
Conservation Areas?
A. No, the systems are not done.
Q. Do you know whether anyone in the Water
Management District is doing GIS work on the
Everglades Agricultural Area?
A. No.
Q. Do you know whether anyone else in the
Water Management District is doing GIS work on
Everglades National Park?
A. No.
Q. Are you doing any GIS work related to the
water quality?
A. No.
Q. Do you know whether anyone in the Water
Management District is doing any GIS work related
to water quality?
A. I have no such knowledge.
Q. Are you doing any GIS work related to
vegetation?
A. No.
Q. Do you know whether anyone in the Water
Management District is doing any GIS work related
** 13
to vegetation?
A. I have no such knowledge.
Q. Are you doing any GIS work related to
nutrients?
A. No.
Q. Do you know whether anyone in the Water
Management District is doing any GIS work related
to nutrients?
A. I have no such knowledge.
Q. Have you done any remote sensing work
related to the Water Conservation Areas?
A. No.
Q. Have you done any remote sensing work
related to the Everglades Agricultural Area?
A. No.
Q. Have you done any remote sensing work
related to Everglades National Park?
A. No.
Q. Do you know whether anyone in the Water
Management District is doing any remote sensing
work related to the Water Conservation Areas?
A. Not to my knowledge.
Q. Is anyone in the Water Management
District doing any remote sensing work related to
the Everglades Agricultural Area?
** 14
A. Not to my knowledge.
Q. Is anyone in the Water Management
District doing any remote sensing work related to
Everglades National Park?
A. Not to my knowledge.
Q. Have you done any GIS work for purposes of
the Everglades SWIM project?
A. No.
Q. Have you done any GIS work for the Lake
Okeechobee Technical Advisory Committee Project?
A. No.
Q. Have you done any GIS work for the
Nutrient Removal Project?
A. I don't know what that project is.
Q. Have you done any remote sensing work for
the Everglades SWIM Plan?
A. No.
Q. How about remote sensing work for the Lake
Okeechobee Technical Advisory Committee?
A. No.
Q. What is the procedure you utilized to
access the DEC through your IBM PC?
A. Remote log in.
Q. Could you elaborate on that?
A. Remote log in is the procedure which we
** 15
access the computer network from a terminal. It
allows us to access the different systems on the
network.
Q. Do you forward any of the work you do to
others in the Water Management District by
computer?
A. Could you repeat the question, please?
MS. NASH: Could you read that
back?
(WHEREUPON, the requested testimony
was read back by the court reporter.)
A. I don't understand what you mean by
forwarding. Could you please elaborate?
Q. (By Ms. Nash) Do you transfer data files
or text files --
A. Yes.
Q. -- to others?
A. Yes.
Q. To whom do you transfer those files?
A. I transfer -- I allow other users to
access them. I don't transfer them to anyone
specifically.
Q. Who in the Water Management Division has
** 16
access to your files?
A. In the Water Management Division?
Q. Water Management District.
A. Anyone who has access to a computer.
Q. Is access to your files restricted in any
way?
A. Only by access to the computer system.
Q. Are there entities outside the Water
Management District that have access to your files?
A. If they're allowed access to our system.
Q. Do you know whether there are entities
outside the Water Management District that access
your files?
A. I'm not aware of who has access to the
files of the district outside of the district.
Q. What GIS data do you have on your
computers?
A. Test data.
Q. What is the nature of that test data?
A. To verify the operation of the software
and hardware.
Q. Have analysis been done on this GIS test
data?
A. To test the programs to insure they
operate the function properly.
** 17
Q. Are there reports of these analyses that
have been done on the GIS test data?
A. No.
Q. What remote sensing data do you have on
your computers?
A. At the present time, there is no remote
sensing data on the computers.
Q. You indicated earlier in your answer that
you're knowledgeable about satellite imagery.
A. Yes.
Q. What satellite imagery data is there in
the Water Management District on the Water
Conservation Areas?
A. I'd have to consult the inventory listing.
Q. Where is this inventory listing located?
A. On the computer system.
Q. On which computer?
A. DEC.
Q. Does this inventory listing have a name?
A. I don't recall the name. I'd have to
look.
Q. Who would know the name of this inventory
listing on the satellite imagery?
A. I would have to reference it.
Q. Is there satellite imagery data on the DEC
** 18
on the Loxahatchee National Wildlife Refuge?
A. No.
Q. Is there satellite imagery on the DEC on
the Everglades Agricultural Area?
A. No.
Q. Is there satellite imagery on the DEC on
Everglades National Park?
A. No.
Q. Is there satellite imagery data on any of
the Water Management District's computers on Everglades
National Park?
A. No.
Q. Is there satellite imagery data on any of
the Water Management District's computers on the
Everglades Agricultural Area?
A. No.
Q. Is there satellite imagery data on any of
the Water Management District's computers on the
Loxahatchee National Wildlife Refuge?
A. No.
Q. You indicated that you can respond to the
part of this inquiry on the use of remotely sensed
data to prepare vegetation maps?
A. I can.
Q. How do you use, in the Water Management
** 19
District, remotely sensed data to prepare
vegetation maps?
A. We were developing a system. We do not
use the data.
Q. So you were developing a system, did you
say?
A. That's correct.
Q. There is not presently a system in
existence at the district?
A. The system is being tested.
Q. Can you describe the system that's being
developed?
A. The system is --
MS. STOLLMAN: To the extent that the
system is already in place, you can describe it. I
don't want you to speculate on what further might
be developed.
THE WITNESS: Okay.
MS. STOLLMAN: You can describe what
is being tested now.
A. The system that is being developed will be
a tool for our scientist and engineers to access
and process, and interpret, and analyze, remotely
sensed data in a digital format, which is
integrated within the GIS.
** 20
Q. (By Ms. Nash) Do you know when this
system will be ready to go into operation?
A. I don't want to speculate. We don't know.
MS. NASH: I have no further
questions.
MS. STOLLMAN: Do you want to take
a break?
MR. RICHARDS: I would like to take a
break for 5 minutes.
THE WITNESS: Okay. Let's do that.
(Short break.)
MS. STOLLMAN: Beverly, you asked a
string of questions about the GIS system and work
done on that. I think there was a little confusion
on the part of the witness with respect to your
questions. I'd like to give you an opportunity to
explain what you mean by "work done on the GIS
system with respect to each of those areas."
MS. NASH: I believe my questions
were whether -- Jim Olla testified that he was
developing a GIS system on the SUN Microsystem, and
what I was inquiring is to whether any GIS work had
been done in the various areas I mentioned.
** 21
MS. STOLLMAN: Could you define what
you mean by "work done"?
MS. NASH: Whether -- I mean, GIS is
a -- I mean, he certainly knows what GIS is, and
whether any geographic information processing had
been done in the areas I was inquiring about.
MS. STOLLMAN: Do you want to run
through each area and ask him if any GIS processing
had been done?
Do you understand that?
THE WITNESS: She's got to define
what GIS work is, and I'll also ask her to define
what in her terms GIS means, because it means
different things to different people.
Q. (By Ms. Nash) Well, what does GIS mean to
you, sir?
A. The geographic information system is a
computer system in which we will make our
operational and management decisions upon the
questions posed to it.
At this point in time, the geographic
information system is not functional in an
operational form and it is not used for any
operational decisions.
At the present time, we are installing the
** 22
necessary computer hardware and software. We are
testing this hardware and software. We are testing
the linkages between the systems, and that
comprises the work I do on the system.
We do not perform, extract, or use it for
any operational systems, because it is not
accessible to the users. It is accessible to me,
because I'm the developer; and any data I have on
the system is transitory to test the functionality
of the system.
Q. What you're saying, then, is no work has
been done in the specific areas that I mentioned as
the --
A. No. The work that's been done on the
system is to make sure it works. When we have all
the components in and we can release it to the
staff, then, we -- we expect operational decisions
to be made based upon it.
But at this point in time, we have just
installed some hardware and software and tested
their operability to each other -- the way they
talk to each other.
When we get done testing the system, then,
we will release it to the staff for use in their
specific areas, and in those areas to which you had
** 23
asked me questions about.
But until the system is built -- I mean,
it's my job to build it, we're going to make sure
it's right before we use it, okay?
Q. Did you mention to me, when I asked, the
hardware that you're utilizing to develop the
system?
A. Uh-huh.
Q. And did you mention all the software that
you're utilizing to develop the system?
A. Uh-huh. That's correct.
MS. NASH: I have nothing further.
THE WITNESS: I don't want to leave
any misunderstanding, okay?
CROSS-EXAMINATION
QUESTION BY MR. RICHARDS:
Q. My name is Joe Richards. I represent the
cities of Belle Glade and Clewiston.
A. Okay.
Q. Do you have a bachelor's degree?
A. Yes, I do.
Q. What is that in?
A. I have a bachelor's degree in geography
** 24
and computer science.
Q. And besides developing this GIS system,
what other projects have you worked on since you
started work for the district?
A. None.
Q. Development of this system comprises 100
percent of your time?
A. Yes. With the exception of all the
meetings like this.
Q. When you were describing the GIS system on
the SUN, you said there would be data on the
spatial characteristics of the Water Management
District. Do you know what these characteristics
are?
A. All the elements of the earth that
comprise the district. For example, the soils, the
vegetation, the temperature, any information which
we can gather which will help us make better
decisions about a specific area.
Q. When do you expect this system to be
operable.
MS. STOLLMAN: I believe that's been
asked and answered by Ms. Nash.
A. It's undetermined.
MS. STOLLMAN: I don't want you to
** 25
speculate.
A. Okay. I won't speculate.
Q. (By Mr. Richards) Does the Water
Management District possess any land sat
photography that you're aware of?
A. Yes.
Q. Do you know what areas that photography
is?
A. Yes.
MS. STOLLMAN: Are you asking about
photography that's contained on the computer
systems?
MR. RICHARDS: Yes.
A. There is no data on the system.
Q. (By Mr. Richards) Data that will be used
in the system?
A. Yes.
Q. Could you elaborate on the areas of
photography?
A. The entire 16-county district.
Q. Do you know the dates of these images?
A. I will have to reference them.
Q. Where is this information located?
A. The reference document is on the system
itself. It's indexed to the data the district
** 26
owns.
Q. It's indexed on a computer?
A. Yes, it's a computer file.
Q. Which computer?
A. I believe it's in the PC. I made a
mistake earlier. It's not on the DEC. It's on my
PC.
Q. Does that file have a name?
A. I would have to look. It's a Word Perfect
file. I just -- I would have to look. If I see
it, I'd know what it was. I just don't recall.
Q. Are these recent images in the last two
years?
A. Some have been taken in the last two
years, but again, I would have to reference the
document for the specific area you'd have in mind.
Q. Do you know the dates of images of the
Water Conservation Areas?
A. I would want to refer to the document,
that way I can be more precise.
Q. Do you have images of within the last two
years of the conservation areas?
A. I want to refer to the documents. I'm not
trying to not answer your question, but I just --
there is 16 counties and there is a lot of imagery,
** 27
and I would just have to look.
Q. Do you know what version of land sat
photography these images are?
A. Yes.
Q. Which version is that?
A. Thematic mapper.
Q. Has this land sat photography been put to
use by anyone at the district?
MS. STOLLMAN: You can answer within
the context of the computer system -- if anyone has
used the photography on the computer system.
A. I have used the photography on the system.
Q. (By Mr. Richards) For what purpose?
A. Operational testing of the system.
Q. Do you know of any other use of this data?
A. I have no knowledge of other people using
the data other than myself.
Q. Does the district possess any spot
satellite imagery?
A. Yes.
Q. Do you know of what areas within the
district?
A. The entire district.
Q. Do you know the time frames of these
images?
** 28
A. It's on the document.
Q. It's in the same index?
A. Right. I have all satellite data indexed
in that document.
Q. What information would I be able to obtain
from your index?
A. Row & Column of Imagery, date of
acquisition, type of media stored on.
Q. Pardon me?
A. Row & Column of Imagery, date of
acquisition, type of media it's stored on, sensor
type.
Q. Do you know the approximate date of these
images?
MS. STOLLMAN: I believe that's been
asked and answered.
MR. RICHARDS: I don't think I asked
it in reference to spot.
A. It's on the inventory list. I'd have to
look.
Q. (By Mr. Richards) Has the spot imagery
been used for any purpose other than testing the
system?
A. No.
Q. Do you know whether anyone at the district
** 29
who has requested to use this spot imagery?
A. It has been requested. I have not granted
it.
Q. Who requested it?
A. I don't know the individual's name. There
have been numerous requests.
Q. Is this spot imagery raw or filtered?
A. We purchase raw data. We subsequently
process it into a georeferenced form to fit our
coordinate systems within the GIS. At that level,
we do not process any further at this time.
Q. For the process that has taken place,
could you explain that?
A. When this imagery is received from spot,
it contains errors of geometric correction. For
example, things aren't the way they are on the
earth's surface, because of distortions in the
data. These are distortions caused by satellite
rotation, earth rotations, perpetrations of orbit,
et cetera. We correct this to have the data
georeferenced to our coordinate systems that would
allow it to be utilized within the GIS.
Q. Is there a program used to do this
processing?
A. Yes.
** 30
Q. What is that program?
A. ERDAS.
Q. It hasn't been processed any further than
these corrections?
A. No. We took out that correction to make
it a usable running system.
Q. Is the land sat photography also raw data?
A. Yes.
Q. And has that been processed in any way?
A. No. This has not been processed.
Q. Are you aware of any ground truthing
efforts in regard to this satellite imagery?
A. Could you define the efforts you're asking
about, please?
Q. Verifying what you see in the image as to
what's actually on the ground.
A. No.
Q. It has not been done?
A. No. We have not performed any analysis of
the imagery.
Q. The index -- the information contained on
there, that would apply to both the land sat and
the spot imagery?
A. That's correct.
Q. Has the district hired any consultants or
** 31
subcontractors to utilize the satellite imagery?
A. The imagery the district owns?
Q. Yes.
A. No.
Q. Do you know whether this imagery will be
used to map vegetation in the Water Conservation
Areas?
A. It hasn't been determined what uses the
imagery will be used for.
Q. When you mentioned this process to correct
the geometric distortions, are there certain
variables used in this process?
A. Yes.
Q. What are those variables?
A. Root mean square error. Ground control
points.
Q. Any others?
A. That's it, yeah.
Q. In reference to the testing of the
operation of the system, have you reached any
conclusions as to the viability of the system?
A. The system will be an excellent tool for
the district staff and management to use.
Q. Any other conclusions?
MS. STOLLMAN: Could you be more
** 32
specific?
Q. (By Mr. Richards) Have you reached, just
in general, any conclusions from your testing?
MS. STOLLMAN: I don't want you to --
unless you have a specific question.
Q. (By Mr. Richards) Have you reached any
conclusions?
A. Yes.
Q. What are those conclusions?
A. I've already stated them.
Q. That's it?
A. The system will be used by the
individuals. How the individuals see the system is
a matter of their prerogative. I can only build
the system and give them the tools. What they do
with the tools is something I have no control over.
Q. Do the tools work?
A. I hope so, yes. The ones we have do.
Q. Are you aware of whether this satellite
imagery is copyrighted?
A. Yes, it is.
Q. Do you do any work with aerial
photography?
A. Yes.
Q. What use do you make of aerial
** 33
photography?
MS. STOLLMAN: Again, this is limited
to what use you make of it on the computer system.
A. The computer systems don't use aerial
photography. We use aerial photography to verify
that the imagery is being positioned correctly.
Q. (By Mr. Richards) The satellite imagery?
A. Yes.
Q. Any other uses?
A. Not at this point in time.
Q. Do you know the extent of this aerial
photography, the locations of the images?
A. No, I do not. That's done in many areas
of the district. I don't know the extent of it.
We do -- to the extent of it I do use is in the
form of ortho photo quad maps, which are available
to me and to all other people of the district.
Specific aerial photos, I do not use because they
have limited use to me.
Q. Who developed these photo quad maps?
A. Mark Heard.
Q. Do you know what division he is in?
A. They are contracted.
Q. Pardon me?
A. They were contracted. We had contracted
** 34
this service several years ago.
Q. Do you know what year?
A. 1984.
Q. Those images were of the entire district?
MS. STOLLMAN: I would object to
these detailed questions on the photographs. He's
already testified that they are not used on the
computer system. They have limited purpose. He's
told you what that is. You discussed this with
other witnesses previously, and I don't think it's
relevant here.
Q. (By Mr. Richards) Has the district
developed a program or purchased a program that
will be used to analyze the satellite imagery?
A. Yes.
Q. Do you know what that program is?
A. ERDAS.
Q. Are there any others?
A. Yes.
Q. What?
A. I squared S, that system is being
obsoleted in favor of ERDAS.
Q. Has this program I squared S been used to
analyze photography in the past?
A. I do not use the system.
** 35
Q. Do you know who does?
A. Yes.
Q. Who?
A. Environmental sciences division.
Q. Do you know any individuals?
A. I'm not aware -- I don't know exactly who
uses it there.
Q. Are you doing any work, GIS work to study
the effects of hydroperiod in the wetlands?
A. No.
Q. Do you know of anyone at the district who
is?
A. No.
MR. RICHARDS: I have no further
questions. Thank you.
(The deposition was concluded at 3:15
o'clock p.m.)
