273 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 2 Case No. 88-1886-CIV-HOEVELER 3 UNITED STATES OF AMERICA, ) 4 ) Plaintiff, ) 5 ) vs. ) 6 ) SOUTH FLORIDA WATER ) VOLUME V 7 MANAGEMENT DISTRICT, etc., ) et al., ) 8 ) Defendants. ) 9 ) 10 11 12 1601 Belvedere Road West Palm Beach, Florida 13 December 13, 1990 9:00 a.m. 14 15 16 17 Deposition of Ray Santee 18 19 20 Taken before Jackie Johnson, Shorthand 21 Reporter and Notary Public in and for the State of 22 Florida at Large, pursuant to Notice of Taking 23 Deposition filed in the above cause. 24 - - - - - - - 25 Jack Besoner & Associates, Inc. 274 1 APPEARANCES: 2 3 ON BEHALF OF THE PLAINTIFF: 4 DEPARTMENT OF JUSTICE, ENVIRONMENTAL & 5 NATURAL RESOURCES DIVISION P.O. Box 633 6 Washington, D.C. 20044 BY: Geoffrey Garver, Esq. 7 ON BEHALF OF THE DEFENDANT SOUTH FLORIDA 8 WATER MANAGEMENT DISTRICT: 9 SKADDEN, ARPS, SLATE, MEAGHER & FLOM 1440 New York Avenue, N.W. 10 Washington, D.C. 20005-2107 BY: Don J. Frost, Jr., Esq. 11 ON BEHALF OF THE CITY OF CLEWISTON AND 12 BELLE GLADE: 13 PEEPLES, EARL & BLANK One Biscayne Tower 14 Two South Biscayne Boulevard Suite 3636 15 Miami, Florida 33130 BY: Douglas Wyckoff, Esq. 16 17 - - - - - - - 18 19 20 21 22 23 24 25 Jack Besoner & Associates, Inc. 275 1 (Thereupon the deposition continued as follows) 2 MR. WYCKOFF: Mr. Santee, when we left 3 off yesterday, we were talking about the work that 4 you had performed in your first six months at the 5 District, specifically, your work with the Water 6 Management Model, and you were talking about how 7 you have made adjustments to some of the variables 8 in the model. Where we left off was, calibration 9 and adjusting the values for ET. You testified 10 that ET was a calibrated parameter. 11 CROSS EXAMINATION CONTINUED 12 BY MR. WYCKOFF: 13 Q. Up to this point, do you remember, 14 generally, what we were talking about? 15 A. Yes. 16 Q. You listed a number of other variables 17 that get adjusted when you were adjusting the ET 18 values, including Manning's Coefficient, a 19 hydraulic conductivity coefficient for interaction 20 between canal and ground water, a coefficient 21 which determines the rate of flow of surface water 22 to and through canals and a transmissivity value 23 when there is very little data, correct? 24 A. Correct. 25 I want to point out -- Jack Besoner & Associates, Inc. 276 1 Q. Go ahead. 2 A. -- that a lot of calibration effort was 3 done well after my initial six months at the 4 District. 5 I just wanted to -- I didn't want to 6 leave the impression that I performed all of this. 7 Q. In the first six months to a year at 8 the District, were these efforts that you began in 9 the first six months and carried forward 10 throughout the next some period of years? 11 A. Some calibration effort was performed, 12 I think, more of it at that time by -- it was done 13 by Paul Trimble, and I aided in the data 14 preparation side at the time. 15 Q. Referring to that initial six month 16 period or so? 17 A. Oh. 18 Q. Is that what you're talking about? 19 A. Referring to the initial, I'd say, a 20 year to two years time. 21 Q. You said yesterday that at some point 22 early on in your work on the Water Management 23 Model Mr. Trimble took over that work, and you 24 began preparing input? 25 A. Yes, I began developing programs to Jack Besoner & Associates, Inc. 277 1 facilitate the preparation of input. 2 Q. Why, to your knowledge and best 3 recollection, why did Mr. Trimble begin assuming 4 the role that you had begun? 5 A. Well, I'd say the magnitude of the work 6 load, both working on the program itself and 7 preparing the data, as well as developing programs 8 to facilitate the process got to be too much for 9 one person to handle. So we got Paul involved to 10 keep the project at the time moving and to try to 11 meet the deadlines at the time. 12 Q. Do you remember what kind of deadline 13 you were on, the time frame? 14 A. Since the model was in the development 15 stage, the deadlines were long-term. That's the 16 best I can remember. 17 Q. Do you remember what Mr. Trimble's 18 position was at that time? 19 A. Just at the time I began working with 20 the model, his position was Resource Planning 21 Engineer One, which was the same as mine. 22 Q. Do you know whether at that time Mr. 23 Trimble had more experience than you in working 24 with the Management Model or models like it? 25 A. He had gained some experience with the Jack Besoner & Associates, Inc. 278 1 Regional Routing Model. 2 Q. I was trying to understand your 3 testimony. 4 My understanding so far is that you 5 began working with the model with George Shih? 6 A. Yes. 7 Q. And were in the preliminary stage of 8 calibrating ET and some of these other things. 9 Then Mr. Trimble arrived, and you stopped that 10 activity. He assumed that activity, and you began 11 preparing these input programs? 12 A. I point out, the calibration of ET and 13 other parameters began -- 14 Q. Down the line somewhere? 15 A. -- down the line with Paul. 16 Q. Do you recall when you began working on 17 calibration of ET? Let me approach it in a 18 different way. 19 You have said, now, that this 20 calibration effort began with Paul Trimble, 21 correct? 22 A. Yes. 23 Q. And then at some point you also began 24 working on these things? 25 A. Paul, with help from myself, began the Jack Besoner & Associates, Inc. 279 1 initial calibration effort. 2 Q. What were your specific activities in 3 that? 4 A. I remember helping in adjusting some of 5 the canal parameters. 6 Q. Would those include stage? 7 A. That would include, one, approximating 8 the discharge through the structures by adjusting 9 the level at which flood control releases would 10 begin, perhaps, some of the canal dimensions, such 11 as the width of the canals. 12 Q. Let me ask you a couple of questions 13 about those two, and if you remember more, you can 14 add to your answer. 15 How would you go about adjusting the 16 levels at which flood control releases would begin 17 so that you could approximate discharges through 18 the structure? 19 A. Well, one, we would compare the 20 simulated end of month canal stage with historical 21 canal stage, and at the same time may look at 22 monthly -- look at the comparison of the monthly 23 discharges. 24 Of course, in looking at the 25 combination of the two, you can get a feel or an Jack Besoner & Associates, Inc. 280 1 idea of what quote "regulation stage" would be 2 appropriate for a particular canal. 3 Q. Were the particular canals on a 4 regulatory schedule for flood control releases? 5 MR. FROST: In the context of the 6 model? 7 BY MR. WYCKOFF: 8 Q. In the context of the actual conditions 9 you were trying to simulate with this model? 10 A. Can you repeat the question? 11 Q. The question was whether the canals or 12 the canal stages were on a regulatory schedule for 13 the flood control releases, were they, the canals 14 that you were trying to simulate with the model? 15 MR. FROST: Objection, foundation. 16 THE WITNESS: Yes. Generally, that is 17 true. 18 Operations, generally, do not allow 19 canals to exceed beyond certain levels and will 20 discharge water through the structures to keep -- 21 during wet periods, particularly, to keep the 22 canal at desired levels to minimize flooding and 23 whatnot. 24 BY MR. WYCKOFF: 25 Q. I am just trying to understand your Jack Besoner & Associates, Inc. 281 1 testimony. 2 What I have understood you to say is 3 that by comparing your simulated end of the month 4 canal stage with historical canal stages and 5 comparing the discharges, you would get an idea of 6 the appropriate regulation stage for a particular 7 canal. 8 Was this appropriate regulation stage 9 which you came up with or determined by this 10 comparison method then used in the model? 11 A. Yeah. 12 It determined values used in the model. 13 Q. So you'd take this appropriate 14 regulation schedule that you determined by this 15 comparison method, and from that, you would derive 16 values to use in the model for other parameters; 17 is that correct? 18 Or just tell me in your own words when 19 you determined this appropriate regulation stage 20 for a particular canal, what would you do, then, 21 with that information? 22 A. Well, that information was used to 23 estimate discharges through the structures for 24 flood control. 25 Q. Do you recall whether these appropriate Jack Besoner & Associates, Inc. 282 1 regulation stages that you determined matched the 2 actual regulatory schedule for any of those 3 canals? 4 A. The determined values used in the model 5 were within the ballpark of the actual stage or as 6 a reasonable approximation to how the system is to 7 operate. 8 Q. Was that ever a concern of yours or the 9 people with whom you worked in developing this 10 information, and I am talking about the closeness 11 of these appropriate regulation stages you 12 developed to the actual regulatory schedule? 13 MR. FROST: You're asking: Was there 14 closeness concerned? 15 MR. WYCKOFF: Yeah. 16 THE WITNESS: Yes. 17 The results of the comparison are 18 reviewed by the supervisors. 19 BY MR. WYCKOFF: 20 Q. Do you remember George Shih reviewing 21 this information or data you developed? 22 A. I think he was aware of it. 23 Q. Do you remember any specific 24 conversations or discussions involving this 25 particular information? Jack Besoner & Associates, Inc. 283 1 MR. FROST: With George Shih? 2 MR. WYCKOFF: Right. 3 THE WITNESS: I don't remember any 4 specific conversations. 5 BY MR. WYCKOFF: 6 Q. Do you remember? 7 MR. FROST: Are you finished? 8 THE WITNESS: I know the accuracy of 9 the model at that time was a concern with George 10 Marban and others, because this model was to 11 replace the Analog Model. 12 BY MR. WYCKOFF: 13 Q. Were any features of the Analog Model 14 carried through into the Water Management Model? 15 A. What do you mean by features? 16 Q. Was any of the information which may 17 have comprised some part of the Analog Model used 18 in the Water Management Model? 19 A. I think some of the output, 20 particularly stages, ground water stages was 21 compared with the result of the Water Management 22 Model, both, having identical grid resolutions to 23 check for consistency. 24 Q. Why was the Analog Model being 25 replaced? Jack Besoner & Associates, Inc. 284 1 A. I guess one reason is the advantages in 2 technology, two, the Water Management Model was 3 more efficient and less cumbersome to use. The 4 Water Management Model, I think, because of being 5 a digital model, is more flexible. 6 Q. Did the Analog Model output compare 7 closely with the Water Management Model's results? 8 A. They were comparable. 9 The emphasis of comparison was in Dade 10 County, and a comparison was done -- 11 Q. Let me go back. Go ahead. 12 A. -- with the results from a dryer 13 period. 14 Q. Was any of the Analog Model's output 15 digitized and then used in some fashion for the 16 Water Management Model? 17 A. You mean to say some of the input data 18 used for the Analog Model is digitized? 19 Q. Right. 20 A. Yes, some of the input data used for 21 the Analog Model was used for input to the Water 22 Management Model. 23 Q. Who was responsible for transferring 24 that information in; did you do any of it? 25 A. Yes, I was partly responsible for that Jack Besoner & Associates, Inc. 285 1 with Alan Fox who was working at the District at 2 the time, who worked a lot with the Analog Model 3 or worked some with the Analog Model under the 4 direction of George Shih. 5 Q. Was this ground water stage input data? 6 A. It needed initial ground water stage 7 for each node to execute the Water Management 8 Model. 9 Q. Was there any other input data that was 10 taken from the Analog Model used in the Management 11 Model? 12 A. I think I recall transmissivity was 13 used. 14 Q. And were you, in part, one of the 15 people that made the transfer of information 16 regarding transmissivity? 17 A. Yes. 18 Q. And what process did you go through to 19 put the data in a usable form for the Management 20 Model? 21 A. With transmissivity, I visually 22 extracted the information for each node from a 23 map. 24 Q. How was the information kept by the 25 Analog Model? Let me rephrase the question. Jack Besoner & Associates, Inc. 286 1 What transmissivity data did you begin 2 with? 3 Another way to put it. 4 Was there already data for each node in 5 the Water Management Model? 6 MR. FROST: You mean transmissivity 7 data prior to the transfer from Analog Model. 8 BY MR. WYCKOFF: 9 Q. I want to know how you were able to 10 take transmissivity data and match it to a node 11 which already existed in the Management Model, if 12 that's what you did? 13 A. Well, we had a map showing the contours 14 of transmissivity for the Biscayne Aquifer. I 15 think the source of the data is from the USGS. 16 I just impose the grid net system that 17 is to be used by the Water Management Model onto 18 this map and then just visually estimate the 19 average value of transmissivity for each of the 20 grid cells. 21 Q. To the best of your recollection, how 22 was the transmissivity contour map prepared, if 23 you know? 24 A. We used the map published from a 25 report, I think, by the USGS. Jack Besoner & Associates, Inc. 287 1 I am not sure how the transmissivity 2 values are derived. I know the contours are 3 derived on the basis of partly point value data 4 that's been gathered from pump tests and whatnot. 5 But on my end, I just used a map that's been 6 published in a report. 7 Q. You understand that map published in 8 the report to have estimated the transmissivity 9 values in the contours insofar as contour lines 10 may have been drawn between pump tests that were 11 conducted miles apart? 12 A. Yes. 13 Q. Transmissivity is also one of the 14 variables which you have testified gets adjusted 15 in this ET calibration process we were talking 16 about yesterday; do you remember that? 17 A. Yes. 18 Q. How would you adjust transmissivity 19 values in calibrating ET values? 20 MR. FROST: Objection. That's a 21 mischaracterization. 22 Again, I don't think we are calibrating 23 ET values, but we are calibrating the model. 24 BY MR. WYCKOFF: 25 Q. Mr. Santee, do you remember telling me Jack Besoner & Associates, Inc. 288 1 that ET was a calibrated value up to this point? 2 A. ET is one of the variables that is 3 adjusted in the calibration process of the model. 4 Q. If you said that ET was a calibrated 5 value up to this point, did you use calibration 6 just in the sense of adjustment or tell me what 7 you might have meant by that. 8 A. In the process of calibration, ET is 9 one of the quote "knobs" turned so that the model 10 can reproduce historical conditions reasonably 11 well. 12 Q. ET is a value that you calibrate, 13 correct? 14 A. If you mean comparing results for ET 15 from the model with historical values of ET, no. 16 Q. I just want to understand what you said 17 yesterday when you said that up to this point ET 18 has been a calibrated value? 19 A. I just -- 20 MR. FROST: I think he just explained. 21 MR. WYCKOFF: Well, I didn't 22 understand. 23 MR. FROST: So you want him to explain 24 it, again? 25 MR. WYCKOFF: I want Mr. Santee to Jack Besoner & Associates, Inc. 289 1 explain to me what he means when he said ET was a 2 calibrated value so far. 3 BY MR. WYCKOFF: 4 Q. Did you mean that so far ET adjustments 5 have been made on the basis of historical data? 6 MR. FROST: Asked and answered. 7 THE WITNESS: ET is one of the several 8 variables adjusted in the calibration process so 9 that, basically, simulated stages at selected 10 locations within the model area matched historical 11 values. 12 MR. WYCKOFF: I am just trying to ask 13 questions. 14 MR. FROST: I don't know if Mr. Santee, 15 was finished. 16 BY MR. WYCKOFF: 17 Q. Are you finished? 18 A. Yes. 19 Q. I'm just trying to ask you questions 20 using the terminology that you have used. 21 Do you have a problem with the question 22 that I previously posed, how do you make 23 transmissivity adjustments when calibrating ET? 24 MR. FROST: I think, again, that's a 25 mischaracterization of Mr. Santee's testimony. Jack Besoner & Associates, Inc. 290 1 We went through that yesterday, too. 2 MR. WYCKOFF: We can go back and read 3 back yesterday's testimony where he said ET is a 4 calibrated value so far, if that's what you want. 5 MR. FROST: I think we went through 6 that yesterday. I think it came up in that 7 context. 8 Mr. Santee clarified his testimony that 9 he was not calibrating ET, but they were using ET 10 to calibrate the model. 11 MR. WYCKOFF: I have never heard Mr. 12 Santee say that. I have heard you say it. 13 MR. FROST: I just heard him say it two 14 or three times just now, and he said it yesterday, 15 too. 16 MR. WYCKOFF: Well, I am not satisfied 17 that Mr. Santee has said no, you are not 18 calibrating ET. 19 BY MR. WYCKOFF: 20 Q. In your mind, is there a difference 21 between adjusting ET and calibrating ET. 22 Let me put it another way. 23 Are you only calibrating the model and 24 making adjustments to ET, transmissivity, 25 Manning's Coefficient and the other coefficients Jack Besoner & Associates, Inc. 291 1 we have discussed? 2 A. Yes. 3 In calibrating the model, when I used 4 the term ET is a calibrated parameter, I meant ET 5 is one of the parameters that's adjusted -- 6 Q. In calibrating the model? 7 A. -- in calibrating the model, that's 8 correct. 9 MR. FROST: Would this be a good time 10 for a break? 11 MR. WYCKOFF: Yes. 12 (Thereupon a recess was taken in 13 deposition, after which the 14 deposition continued as follows:) 15 BY MR. WYCKOFF: 16 Q. The pending question now is: How have 17 you adjusted transmissivity values in the 18 calibration process in the model? 19 A. In ways, we look at the comparison of 20 the simulated ground water stages in certain 21 locations over a fairly large area, and we look at 22 the change of the ground water stage over that 23 area and compare, maybe, a change given by 24 historical data and deviation of the gradient of 25 water levels from that of historical -- indicated Jack Besoner & Associates, Inc. 292 1 from historical values may indicate that the 2 movement of ground water through the aquifer may 3 be too fast or too slow, so adjust -- an 4 adjustment of transmissivity values -- maybe I 5 should rephrase that. 6 An adjustment in the transmissivity 7 value may improve the simulated -- 8 Q. Values? 9 A. -- results, values. 10 Q. How would you know, in comparing the 11 simulated water levels to the historical values, 12 that you should make an adjustment in 13 transmissivity as compared to some other value? 14 MR. FROST: You mean other parameter? 15 MR. WYCKOFF: Right. 16 THE WITNESS: A lot of that is 17 engineering judgement. I'd say a lot of that 18 requires engineering judgement. 19 BY MR. WYCKOFF: 20 Q. Tell me how. 21 A. For example, if you -- 22 MR. FROST: Wait. Go ahead. 23 THE WITNESS: If you investigate or 24 look at two gauges in the same hydrologic basin 25 with the same land use -- same land use type and Jack Besoner & Associates, Inc. 293 1 see that the gradient of water levels based on 2 historical data deviates from simulated results, 3 and intuition would tell me that perhaps the 4 volume of the estimation of the transfer of ground 5 water from that one location to the other needs to 6 be adjusted. 7 For example, I drew that conclusion, 8 partly, because both gauges are in areas with the 9 same land use type and same characteristics. So I 10 am able to isolate the parameters needed to be 11 adjusted. 12 BY MR. WYCKOFF: 13 Q. Is there an accepted definition of 14 transmissivity hydrologists use, of which you're 15 aware? 16 A. I am aware of what has been published 17 during the process of adding transmissivity values 18 in the model since additional data are available. 19 Other than that, I am not aware of any quote 20 "accepted value". 21 Q. My question was: Are you aware of an 22 accepted definition of the term transmissivity? 23 A. Transmissivity is, basically, the rate 24 at which a column of water moves through the 25 aquifer. Jack Besoner & Associates, Inc. 294 1 Due to the difference in pressure, 2 transmissivity is usually defined in terms of 3 volume of water moved over a specified period of 4 time per foot difference in head. 5 Q. Do you know whether a transmissivity 6 value depends on geologic formation of the aquifer 7 being measured? 8 MR. FROST: I guess to some extent, I 9 object to this line of questioning. 10 I think we have already established 11 that these values come from a report that was 12 published by the USGS. I don't know why we need 13 to go into extensive questioning on geological 14 principals. 15 MR. WYCKOFF: I want to understand the 16 witness' basis for conducting the changes in 17 values which he has testified he already has in 18 the calibration process of this model. That's 19 why. 20 MR. FROST: I believe he has testified 21 that they changed the parameters in order to make 22 the model more accurate and the results more 23 reasonable. 24 MR. WYCKOFF: Right. Exactly. 25 MR. FROST: That would seem to be the Jack Besoner & Associates, Inc. 295 1 basis. 2 I'll allow you to ask these questions 3 and him to answer these questions. I don't see 4 that it's highly relevant. 5 MR. WYCKOFF: I think it is. 6 So we can just move on with the 7 question and the answer. 8 MR. WYCKOFF: Do you remember the last 9 question? 10 THE WITNESS: Read it back, please. 11 (Thereupon the referred to question was 12 read back by the reporter as above 13 recorded.) 14 THE WITNESS: I believe it does, yes. 15 BY MR. WYCKOFF: 16 Q. Well, in the calibration process, when 17 you were tweaking the model, so to speak, changing 18 the values to reach a more accurate simulation of 19 historical -- let me start over. 20 When you were making these changes in 21 transmissivity in the calibration process, did you 22 or anyone else, to your knowledge, compare the 23 changed transmissivity values with the hydrologic 24 characteristics of the aquifer from which those 25 transmissivity values corresponded? Jack Besoner & Associates, Inc. 296 1 A. Yes. 2 We compared, to the best that we could 3 do at the time, with what data we had available at 4 the time. 5 Q. What was -- I am sorry. 6 A. Our assumption that the aquifer is a 7 water table aquifer, a surface aquifer, is a 8 reasonable assumption. 9 Q. My question was more -- as I understand 10 your testimony, you took a USGS contour map of 11 transmissivity values, and you over laid it on 12 your grid, and you estimated transmissivity values 13 from the underlying contour map, and then you 14 began to calibrate the model and, in some cases, 15 adjusted the transmissivity values you had 16 estimated from the contour map? 17 A. That's not exactly correct. 18 Transmissivity values were adjusted in 19 areas which the contour map did not cover. 20 The contour map was reflective of the 21 data available in the Lower East Coast. There was 22 very little, if any, data available at the time, 23 for example, in Everglades National Park or in the 24 Conservation Areas. It's in those areas, largely, 25 where the adjustments were made, in areas where Jack Besoner & Associates, Inc. 297 1 little or no data was available. 2 Q. Was there any data in these areas in 3 which the transmissivity values were adjusted? 4 Let me ask a preliminary question. 5 Do you know whether transmissivity is 6 calculated from other aquifer characteristics, 7 such as leakage and permeability? 8 A. Permeability is an important parameter 9 or property used in the calculations of 10 transmissivity. 11 I am not aware of exactly how the USGS 12 calculated the values or what all assumptions were 13 made in generating the map; but permeability is an 14 important parameter. 15 Q. Are you done? 16 A. I think in the Biscayne Aquifer, you 17 assume -- I think it's a pretty good approximation 18 that there is little or no leakage to the 19 underlying aquifer, that the layer separating the 20 Biscayne Aquifer, which is a surface aquifer, from 21 the underlying aquifers is impermeable. 22 Q. When you made adjustments to 23 transmissivity values, did you compare your 24 changed value with permeability data? 25 MR. FROST: Objection, foundation. Jack Besoner & Associates, Inc. 298 1 THE WITNESS: No, not in the areas 2 where we made adjustments, because there was no 3 available data for comparison. 4 BY MR. WYCKOFF: 5 Q. Not knowing exactly how the USGS 6 calculated its values or what assumptions were 7 made in the generation of their map, how did you 8 decide how much to change the transmissivity 9 values? 10 MR. FROST: Objection, foundation. 11 THE WITNESS: It's based on a lot of 12 engineering judgement and in comparing the 13 simulated stages at various points in the area 14 with that of historical land use. 15 BY MR. WYCKOFF: 16 Q. Do you know whether any consideration 17 was given to hydrologic abnormalities such as a 18 discontinuity or some other reason which might 19 account for a difference between the simulated 20 stage and the historical stage, other than just 21 transmissivity? 22 MR. FROST: Objection. 23 I believe that question has already 24 been answered. 25 THE WITNESS: Any discontinuities, if Jack Besoner & Associates, Inc. 299 1 any, were smoothed out or averaged out. 2 BY MR. WYCKOFF: 3 Q. My question was really, just, whether 4 when you ran the model and your simulated stage 5 deviated from your historical stage, any 6 consideration was given to the possibility that 7 something other than transmissivity was actually 8 causing the difference? 9 MR. FROST: Again, I object. I believe 10 that's already been answered. 11 THE WITNESS: Yes, other factors were 12 considered. 13 BY MR. WYCKOFF: 14 Q. Does that bring us back to -- go 15 ahead. 16 Were you going to say something? 17 MR. FROST: Which question is pending? 18 You were just asking does that bring us back to -- 19 MR. WYCKOFF: And I am going to ask him 20 now: What were you going to say? 21 THE WITNESS: The parameters to be 22 adjusted can partly be determined through, let's 23 say, sensitivity analysis of various parameters. 24 Part of it can be determined by looking 25 at, by noticing the hydrologic conditions at which Jack Besoner & Associates, Inc. 300 1 the differences occur. 2 A lot of it's a matter of, you know, 3 just experience and judgement and observations. A 4 lot of this is nebulous, and it requires just the 5 best judgement of the engineer, and a lot of it is 6 a trial and error process, as well. 7 BY MR. WYCKOFF: 8 Q. If I understand what you have told me 9 so far about this, when the calibration efforts 10 began, one of the things which you were doing was 11 transferring this transmissivity data; is that 12 correct? 13 MR. FROST: Objection, ambiguous. 14 BY MR. WYCKOFF: 15 Q. Do you understand the question? 16 You took the contour map, the grid and 17 you -- 18 A. Yes, I performed that function. 19 MR. FROST: Are you asserting that that 20 function was a calibration? 21 MR. WYCKOFF: No. 22 MR. FROST: Okay. 23 BY MR. WYCKOFF: 24 Q. I was saying, when the calibration 25 effort began, one of the things that he was doing Jack Besoner & Associates, Inc. 301 1 was making the transfer of information from the 2 contour map to the grid estimating from the 3 contour map values for each node on your grid. 4 Then in the calibration process, adjustments were 5 made to the values for nodes where there was no 6 published data. 7 A. Correct. 8 Q. Specifically, the Conservation Areas 9 and Everglades National Park? 10 A. Yes. 11 Q. At the time that you were conducting 12 these changes to the transmissivity values, did 13 you believe that the experience you had, which 14 would be the basis for exercising engineering 15 judgement, was such that you could make these 16 changes to the transmissivity values in the 17 absence of data? 18 A. At this time, I feel my judgement was 19 adequate, though, I got input from Paul Trimble or 20 George Shih. 21 I think the process that was done was a 22 team effort. 23 Q. Did Mr. Trimble or George Shih give an 24 in-depth review to the transmissivity changes 25 which you made? Jack Besoner & Associates, Inc. 302 1 A. Yes. 2 George Shih was aware of the values 3 used -- 4 Q. Do you recall -- I am sorry if you are 5 not finished. Go ahead. 6 A. -- and was more particularly interested 7 in looking at the results of comparisons and 8 stages and discharges. 9 George Shih was aware of the 10 methodology in input data that we used and trusted 11 our judgement in adjusting these values in this 12 process. 13 It's difficult to make a detailed 14 concrete review of the values, since there was no 15 data available. It's a judgement call. 16 Q. Is George Shih still a District 17 employee? 18 A. Yes. 19 Q. Is Mr. Shih -- is he Doctor George 20 Shih? 21 A. Yes. 22 Q. Is Doctor Shih as knowledgeable as you 23 are in regard to the calibration of the model? 24 A. Can you clarify that a little bit? 25 Q. As I have understood your testimony and Jack Besoner & Associates, Inc. 303 1 the testimony of Tom MacVicar, George Shih was the 2 developer of the Water Management Model. 3 A. That's correct. 4 Q. And he was, also, your supervisor when 5 you began working on the Water Management Model? 6 A. That's correct. 7 Q. And that the activities that you 8 performed in creating the grid, preparing input 9 programs and conducting changes to various 10 variables in the calibration process were done 11 under the direction of George Shih; is that 12 correct? 13 MR. FROST: Again, we are talking about 14 in the early '80's in the early stages of the 15 model? 16 MR. WYCKOFF: Right. 17 THE WITNESS: Talking about like 1979 18 and the early part of 1980, yes, it was under the 19 direction of George Shih, yes. 20 BY MR. WYCKOFF: 21 Q. When did George Shih cease his 22 direction of activities relating to the Water 23 Management Model? 24 A. Of course, to the best of my 25 recollection, his direct supervisor ended Jack Besoner & Associates, Inc. 304 1 approximately a year to a year and-a-half after I 2 began working there. 3 Q. Who, then, assumed George Shih's role? 4 MR. FROST: You mean, his official 5 position or his role, if any, with respect to the 6 Water Management Model? 7 MR. WYCKOFF: I think the question is 8 pretty clear. 9 Do you understand the question? 10 MR. FROST: Objection, foundation. 11 THE WITNESS: I understand the question 12 to mean who replaced George Shih in his role as 13 sort of a role supervisor. 14 BY MR. WYCKOFF: 15 Q. In regard to the Water Management 16 Model? 17 MR. FROST: Objection, foundation. 18 THE WITNESS: There was an interim 19 period where George Marban was supervisor, but 20 George Shih was still consulted heavily on the 21 technical matters. 22 During that interim period, Paul 23 Trimble was considered the program manager. 24 BY MR. WYCKOFF: 25 Q. Did that change later? Jack Besoner & Associates, Inc. 305 1 A. Yes. 2 Q. How did it change? 3 A. Around that time, the U.S. Army Corps 4 of Engineers was interested in using the model in 5 this Water Supply Study. 6 A little later, we were contracted -- 7 I'd say the District was contracted to aid the 8 Corps of Engineers with the study, and a lot of 9 District responsibility was to develop water 10 management -- further develop the Water Management 11 Model and to eventually provide them with the 12 model for them to use. A decision was made for 13 Tom MacVicar to become the program manager or 14 project manager for this Water Supply Study. 15 Q. Did you become custodian of the Water 16 Management Model after that? 17 Was there still someone that you were 18 under in the hierarchy of using the Water 19 Management Model and conducting changes to it? 20 MR. FROST: At what point in time? 21 BY MR. WYCKOFF: 22 Q. After Mr. MacVicar ceased to be the 23 program project manager? 24 A. Right after MacVicar was project 25 manager, Tom Vanlent became custodian of the model Jack Besoner & Associates, Inc. 306 1 for, I guess, for the next year, year and-a-half 2 or so, and this still is part of the Water Supply 3 Study. 4 Then after Tom Vanlent left, I became 5 custodian of the model and have been ever since. 6 Q. When George Shih was no longer your 7 supervisor, in that, I am speaking of the interim 8 period when Marban was the supervisor, Shih was 9 consulted and Paul Trimble was the program 10 manager, did you still work with the Water 11 Management Model? 12 A. I was principally involved in 13 developing and applying preprocessor programs for 14 the model. 15 Q. Is that what we were talking about 16 earlier, about programs to prepare the input data 17 for use in the Management Model? 18 A. Yes. 19 Q. When Mr. MacVicar was the program 20 project manager, during that time period, what 21 were your duties then? 22 A. One of the duties was to modify the 23 subroutines in the model that read in the data so 24 that the data can be read in in the format desired 25 by the Corps of Engineers. Of course, that Jack Besoner & Associates, Inc. 307 1 involved making a number of code changes. 2 I, also, remember being involved in a 3 post-processing program, as well. 4 Q. Are you done? 5 A. Yes. 6 Q. Do you know when Tom Vanlent was first 7 employed by the District? 8 A. I think it was around the early part of 9 1983. 10 Q. Is that when he became custodian of the 11 Management Model? 12 A. Well, he worked for some time under the 13 direction of Tom MacVicar. 14 Tom Vanlent became custodian or program 15 manager of the model for the Water Supply Study 16 when Tom MacVicar left the division to become 17 division director of Data Management. 18 Q. What was Vanlent's position when he was 19 hired, to your recollection? 20 A. I cannot recall the exact title, but he 21 was hired at the Engineer Two level. 22 Q. You were originally hired as a Water 23 Resources Engineer One, correct? 24 A. That's basically correct. 25 An official title is Resource Planning Jack Besoner & Associates, Inc. 308 1 Engineer One. 2 Q. Sorry. 3 A. That's knit picking. 4 Q. And that was in September of 1978; is 5 that right? 6 A. December 1978. 7 MR. FROST: We are not going to go back 8 all through this again? 9 MR. WYCKOFF: All through what? 10 MR. FROST: When he came to the 11 District. We already talked about that to some 12 extent. 13 MR. WYCKOFF: We talked about when he 14 came to the District and his first position. 15 BY MR. WYCKOFF: 16 Q. When did you receive a promotion to 17 some other position and what was it? 18 A. I received a promotion to the Two level 19 in June of '82. 20 Q. Have you received other promotions 21 subsequent to that? 22 A. I received a promotion to the staff 23 level, which is equivalent to, let's say, the 24 Three level back at that time. 25 Q. Is that staff engineer? Jack Besoner & Associates, Inc. 309 1 A. Staff Water Resources Engineer, around 2 October 1987. That's my present position. 3 Q. Does becoming custodian of the 4 Management Model equal some sort of promotion or 5 accomplishment? 6 A. Becoming custodian of the model is an 7 indication of some accomplishment, not necessarily 8 a promotion. 9 MR. WYCKOFF: Off the Record for a 10 second. 11 (Thereupon the deposition was recessed until 12 the following morning) 13 14 15 16 17 18 19 20 21 22 23 24 25 Jack Besoner & Associates, Inc.