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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 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.)
