** 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 STEVE REEL 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 STEVE REEL By Ms. Beverly Nash 5 By Mr. Joe Richards 15 ** 3 The deposition of Steve Reel, 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 4:17 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, STEVE REEL being by me first duly sworn to tell the whole truth, as hereinafter certified, testified as follows: DIRECT EXAMINATION BY MS. NASH: Q. Mr. Reel, I'm Beverly Nash, and I'm counsel for the United States in this litigation. We're here to find out what computer systems the Water Management District has, how they're set up, how they're used, what the data is on it, and how the data is formatted. You're here today as a representative of the Water Management District having knowledge in some of the areas in which we're interested in. Have you been shown a list of the categories? A. Yes, I have. Q. Do you know which ones you're here to respond to today? A. Could I take a look at the copy? Q. Sure. A. Okay. 1, 2, and limited knowledge on 2 ** 6 and 6. Q. Okay. What is your present title or position? A. Staff director planning department. Q. And what are your job responsibilities as staff director? A. Administrative in nature. I am responsible for the administrative functioning of the planning department, which includes budget preparation, coordination of personnel matters, records management, financial reporting status, reporting of projects, and those kinds of things. Q. Status reporting of what kinds of projects? A. Planning projects. Q. And how long have you been in that role as staff director? A. One year. Q. Have you had other positions at the Water Management District? A. Yes, I have. Q. And what positions? A. Previously, I was staff director in the office of resource assistance. Q. And how long were you staff director in the office of resource assistance? ** 7 A. A little over a year. Q. And what were your job responsibilities there? A. Same as they are for the planning department except it was a smaller unit. Q. And have you been in any other positions at the Water Management District? A. Yes. Prior to that, I was a supervising professional in the resource planning department, and the water use planning division. Q. And what were your responsibilities there? A. Primarily in charge of the group that coordinated with local governments on comprehensive planning, development, and review. Q. And how long were you in that position? A. Approximately two years. Q. What is your educational background? A. BS in chemistry. MS in environmental engineering sciences. Q. From where? A. University of Florida, Gainesville. MR. RICHARDS: Can I have that answer back, please? (WHEREUPON, the requested testimony ** 8 was read back by the court reporter.) Q. (By Ms. Nash) Who are your supervisors? A. Currently Jim Harvey. Q. And what is his title? A. Deputy director planning department. Q. Are there Water Management District employees that work for you? A. Yes. Q. What positions and what are their names? A. Two senior staff analyst positions. One is held by Alicia Pryor and the other one is currently vacant. And let's see. A staff analyst, Linda Davis, an executive secretary JoJo Shew. Q. What computers are utilized in the planning department? A. We have several different types. We have personal computers, terminals, units, work stations, and Xerox work stations. Q. Which PC do you have? A. Pardon? Q. Which model PC do you have? A. Ranging from an XT to PS2 Model 70. Q. And what is the nature of the work done on the PC? ** 9 A. Primarily word processing, spreadsheets. That's what I'm most familiar with. Q. What packages are utilized to do the word processing? A. Word Perfect on the PC. Q. And what software packages are utilized to do the spreadsheets? A. Symphony. Q. How many PCs are in the planning department? Do you know? A. Oh, I couldn't give you an exact number. I wouldn't want to hazard a guess. Q. You mentioned that there are also terminals, what model? A. DEC. Q. And what use is made of the DEC terminals? A. Primarily word processing and access to the network. Q. And what software packages are utilized on the DEC terminals? A. Well, the software doesn't run on the DEC terminal, but it's used to access Word Perfect, that's running on the VAX mainframe. Q. What use is made of UNIX work stations? A. We just got them in, but they will be used ** 10 for engineering modelling, and GIS and remote sensing applications. Q. Are there other computers in the planning department that were previously used for engineering modelling? A. Yes, let's see. I believe there were two. Q. And what were those? A. There were two SUN work stations. One was used for ground water models, and one for surface water engineering. Q. Are those SUN work stations still being used in the planning department? A. Yes. Q. And were other computers used in the planning department to do GIS or remote sensing applications? A. Yeah, there was one SUN work station. Q. Is that work station still being utilized to do GIS and remote sensing? A. Yes. Q. What is the software that is used on the UNIX work stations? A. I couldn't tell you on the engineering work stations. On the GIS stations, ARC/INFO is the GIS software, and ERDAS is the remote sensing ** 11 software. Q. And what use is made of the Xerox work stations in the planning department? A. Primarily publishing Desk Top publishing. Q. And what software packages are used on the Xerox? A. Viewpoint. Q. Do you know what data files exist on the ground water -- on ground water on the SUN work station? A. No, I don't. Q. Do you know who would know what those data files are? A. Yes, I think so. Q. Who would that be? A. Dave Black for the GIS stations. Maryjo Shine for ground water. Q. And who for remote sensing? A. Brent Moll. Q. And who for surface water? A. Jayantha Obeysekera. You will have difficulty spelling it. His last name is O-b-e-y-s-e-k-e-r-a. Q. And his first name? A. J-a-y-a-n-t-h-a, Jayantha. ** 12 Q. You indicated that the DEC terminal is used to access the network? A. Correct. Q. Is that correct? A. Correct. Q. Can you explain how that occurs? A. Well, I guess it's similar to the PC. There are a series of commands that you can enter to get on to the network. I don't use the terminal on a day-to-day basis, so I can't tell you exactly what those commands are. Q. Are there any manuals or other documentation that exist to assist users in accessing? A. Yes. Q. Do you know the names of those manuals in the documentation? A. For the terminals? Q. Yes. A. I can't recall the exact title, but there was a document that describes how to logo using terminal. Q. Well, what about for the PC, is there documentation or manuals to assist users in utilizing -- ** 13 A. Yes, I don't remember the name. Q. And for the UNIX work station, is there documentation or manuals? A. Yes, I don't recall the names. Q. And for the Xerox work station, is there documentation or manuals to assist? A. Yes. Q. Do you recall the name? A. No. Q. Who would you go to if you had questions on using any of these systems? A. Technical services staff. Q. Anybody in particular in technical services? A. Bill Hall, Lavinia Ricketts. Q. Mr. Reel, you indicated you had some limited knowledge on Question No. 6. I assume that that knowledge is limited to the planning department; is that correct? A. Let me see the question again. Yes, the planning department. Q. Where are the planning department's computer files located? A. Located with individual users within the department. ** 14 Q. Would that be also true of any analysis done by the planning department on data? A. Yes. Q. Do you know if anyone in the planning department is doing work involving the Water Conservation Areas? MS. STOLLMAN: This is limited to anyone doing work on a computer in your department on the Water Conservation Areas. A. I don't know specifically. Q. (By Ms. Nash) Do you know whether anyone in planning department is doing any work on computers on the Everglades Agricultural Area? A. I couldn't tell you. Q. Do you know whether anyone in the planning department was doing work on computers on the Loxahatchee National Wildlife Refuge? A. Same answer. Q. Do you know whether anyone in the planning department is doing any work involving Everglades National Park? A. I don't know. Q. Do you know whether anyone in the planning department is doing work on the computer involving the Everglades SWIM Plan? ** 15 A. I know it's being worked on, but I don't know the specific people. Q. You indicated that Dave Black would know what data files there are in GIS; is that correct? A. Yes. Q. Do you know what work Dave Black is doing with GIS? A. No, I don't. MS. NASH: I have no further questions. CROSS-EXAMINATION QUESTION BY MR. RICHARDS: Q. Mr. Reel, my name is Joe Richards. I represent the cities of Belle Glade and Clewiston. You mentioned you did status reporting on planning department projects; is that correct? A. Right. Basically, once a month, we prepare an update for the governing board on the status of the projects. Q. Would that include the Everglades SWIM plan? A. Yes. But in the report that I put together, it's only maybe a paragraph or two. ** 16 Q. Who would supply you that information? A. The environmental planning division. Q. Do you know what individual is responsible for that? A. The division director is Joe Federico, but there are numerous people who put the information together. I don't know who they are. Q. Do you also report on the status of the Everglades Nutrient Removal Project? A. No. Q. How about the Holeyland Restoration Project? A. No. Q. Rotenberger Restoration? A. No. Q. Are you aware of the accidental loss of any computer files in the planning department? A. No. Q. Are you aware of the accidental loss of any computer files in the district? A. No. Q. You mentioned the use of ERDAS software for remote sensing, do you know which individual utilizes that software? ** 17 A. Brent Moll. Q. Anyone else? A. He is the only one that I am aware of that uses it. Q. What division does Mr. Dave Black work in? A. Environmental planning. Q. Do you know what the name of that division was prior to the reorganization? A. Well, it's been environmental planning up until last week. Q. It's something different now? A. It's called -- MS. STOLLMAN: You can answer if you know. A. It's called lower east coast planning division. Q. (By Mr. Richards) Do you know whether there is a planning division for the other areas of the district now? A. Yes. There is another division that's called, for lack of another name right now, north and west district planning division. Q. Did you have any other positions at the district prior to being a supervisory professional? A. Yes. Prior to that time, I was working in ** 18 the executive office staff. Q. What were your duties in that? A. I was director of the division called special projects. Q. What was the time frame of that position? A. 1979 to 1983. Q. When did you become staff director for the planning department? A. October of '89. MR. RICHARDS: Thank you. I have no further questions. (The deposition was concluded at 4:45 o'clock p.m.)