310 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 VI 7 MANAGEMENT DISTRICT, etc., ) et al., ) 8 ) Defendants. ) 9 ) 10 11 12 1601 Belvedere Road West Palm Beach, Florida 13 December 14, 1990 9:00 a.m. to 5:00 p.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. 311 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. 312 1 (Thereupon the deposition continued as follows) 2 MR. GARVER: I informed Mr. Frost this 3 morning that the United States is postponing the 4 deposition of Larry Grosser scheduled for next 5 Tuesday, the 18th. 6 We will confirm in writing that we have 7 postponed, both, that deposition and the 8 deposition of Guy Germain. 9 We will renotice those depositions and 10 inform you of the reset dates in the letter. The 11 dates, most probably, will be the week of January 12 13th for Larry Grosser -- I mean, excuse me -- for 13 Guy Germain, and the week of January 20th for 14 Larry Grosser. The reason for this postponement 15 is the unexpected long duration of these 16 depositions. 17 When I wrote to counsel for the 18 District informing them of the dates on which I 19 wished -- the United States wished to begin the 20 depositions of Larry Grosser and Guy Germain, I 21 was under the impression, by the recommendations 22 of Laura Ahearn, that there would only be three 23 deponents in this 30B6 deposition. 24 MR. FROST: I believe that Laura's 25 letter and recommendations were that she was not Jack Besoner & Associates, Inc. 313 1 committing to three deponents, but that we had 2 initially identified three, but were certainly 3 reserving the right to add additional deponents in 4 order to meet our burden under the Federal Rules 5 to fully comply with the requirements of 30B6. 6 I don't think she ever indicated that 7 there would only be three but that we had 8 identified three initial deponents with the 9 reservation that that may not be a complete list. 10 Let's go off the Record. 11 (Discussion off the record.) 12 CROSS EXAMINATION CONTINUED 13 BY MR. WYCKOFF: 14 Q. When we left off yesterday, Mr. Santee, 15 we were talking about the surface water 16 interaction coefficient which you created by 17 modifying Manning's Equation, right? 18 A. Yes. 19 Q. And I believe that covered all five of 20 the variables you identified as being adjusted 21 during the calibration process, is that correct? 22 A. Yes, we identified five of them. 23 Q. Now, we have gone through all those. 24 Did the calibration process entail any 25 other activities which were conducted on the Jack Besoner & Associates, Inc. 314 1 model, other than adjusting the five variables we 2 have already gone over? 3 A. Well, sometimes a byproduct of the 4 calibration process is the verification of the 5 historical data. Sometimes mistakes in historical 6 data can be brought out through this process. 7 Q. Would those be mistakes in the 8 collection and measurements of the data or 9 mistakes in inputting the recorded data into the 10 model? 11 A. It can be a combination of the two. 12 Q. When you were involved in this 13 calibration process, do you recall there being 14 mistakes of both categories? 15 Let me withdraw that question and build 16 up to it. 17 Are there two categories of historical 18 data, historical data in the input, as well as 19 historical data which you used to derive some of 20 the variables which you have gone over in the last 21 couple of days? 22 A. Yes. 23 Q. Were both of those categories of 24 historical data verified in the calibration 25 process? Jack Besoner & Associates, Inc. 315 1 A. Well, the data was verified before the 2 calibration process as much as was possible. 3 Q. Was some of the data impossible to 4 verify? 5 A. Well, at times it would be more 6 difficult, because you'd have different values 7 from different sources. 8 Q. Do you recall -- 9 A. Particularly, the flow data. 10 Q. Do you remember what sources you were 11 using which had different values for flow data? 12 A. All I know is I acquired a lot of the 13 flow data from the data base that we had. 14 I note the Data Management Division is 15 involved a lot in working up the data for the data 16 base, and I am not sure of the exact source of the 17 data. Some of it may come from the USGS. Other 18 sources, I am not sure about. 19 Q. Are you aware of what verification 20 efforts may have been made for that data which the 21 data base already contained? 22 MR. FROST: Objection, scope. 23 What was done to data outside of the 24 modeling effort is beyond the scope of this 25 deposition. Jack Besoner & Associates, Inc. 316 1 I will allow you to ask general 2 questions about the data that Ray used in the 3 modeling effort and in calibration of the model 4 and any manipulation he may have done for 5 verification to the data. 6 But as far as what the Data Management 7 personnel have done and others in the collecting 8 and maintaining the data base, which is outside of 9 the modeling effort, is beyond the scope of this 10 deposition. 11 MR. WYCKOFF: Well, just for the 12 Record, the information that we have just been 13 talking about with the witness is part of the 14 basis of the model as it currently exists today, 15 and that's what the testimony has been for the 16 last how ever many days we have been here, and I 17 think it is entirely within the scope of this 18 deposition notice, but your objection is on the 19 Record. 20 MR. WYCKOFF: Do you remember the last 21 question? 22 THE WITNESS: I will have her repeat 23 it. 24 MR. WYCKOFF: Would you read it back, 25 please. Jack Besoner & Associates, Inc. 317 1 (Thereupon the referred to question was 2 read back by the reporter as above 3 recorded.) 4 THE WITNESS: I don't know. 5 BY MR. WYCKOFF: 6 Q. Insofar as you have testified that 7 verification of historical data is sometimes a 8 byproduct of the calibration process, was there 9 any of the data with which you worked that never 10 was verified? 11 MR. FROST: Objection, foundation. 12 THE WITNESS: No, not that I am aware 13 of. 14 BY MR. WYCKOFF: 15 Q. Do you remember verifying all the data 16 which you used? 17 A. No. 18 The engineering assistants gather and 19 verify the data for the model. 20 Q. Do you remember who were the people 21 responsible for that effort? 22 A. I'd say in the earlier effort, the 23 workup of the time and variant data, such as 24 transmissivity or initial ground water table or 25 land elevation data is, largely, a combination of Jack Besoner & Associates, Inc. 318 1 the efforts of myself, Alan Fox, Lamar Larasi, and 2 I think Karen Lithgow. 3 Q. Was it Larry Lamar; is that two names? 4 A. It was just Lamar Larasi. I don't 5 recall the last name. 6 The time variability data, such as 7 rainfall and flow data, in the early '80's was 8 worked on by, I think, Betty MacVay Diaz-Arido. 9 That's her present name. 10 Q. You're referring to Betty MacVay as -- 11 A. Her last name -- it wasn't her last 12 name at that time that she worked there. So it 13 was a team effort in working up this data. I 14 think Guy Lathrop. 15 Q. You began relating this information to 16 me with the words in the earlier effort. 17 In your mind, are there two or more 18 distinct efforts during the calibration and 19 verification of the model? 20 A. The major bulk of the effort, 21 particularly with the time variability data, was 22 done for the water supply -- as part of the water 23 supply study for the Corps of Engineers in 24 Jacksonville. 25 The rainfall and flow data, of course, Jack Besoner & Associates, Inc. 319 1 was input into the model and, thus, worked up -- 2 let me reword that. 3 The daily data was worked up for those 4 two variables, and the canal and/or ground water 5 data that were used for it as a basis of 6 comparison was month end data. 7 Q. Was there historical canal and/or 8 ground water data which was used for the basis of 9 comparison? 10 A. Yes. 11 Q. And was that data verified? 12 A. Yes. 13 Q. We talked earlier about the different 14 kinds of mistakes that could have been made with 15 the data being transferred as input to the model 16 or collection measurement mistakes in data. 17 What was done for data which you 18 believed to contain errors in the collection 19 measurement stage? 20 MR. FROST: Objection, foundation and, 21 also, scope. 22 THE WITNESS: If we felt that that was 23 the case, we just have Data Management review the 24 calculations or measurements. 25 The process of performing that, I don't Jack Besoner & Associates, Inc. 320 1 know. 2 BY MR. WYCKOFF: 3 Q. Are the five variables which we have 4 gone over which you adjusted during the 5 calibration process all still a part of the Water 6 Management Model? 7 A. The rainfall and the flow data which 8 was worked up for the years at that time, 1969 9 through 1982, is still a part -- is still part of 10 the input for the model. 11 The data has been updated for a longer 12 period and is presently -- let me start again. 13 The present data starts January 1965 14 and goes through 1989. 15 A majority of the simulations that have 16 been performed, particularly for the Water 17 Management Areas, all but a few of the discharges 18 of the various structures are simulated. 19 Q. Let me break down this question. 20 One of the variables you identified as 21 being adjusted in the calibration process was 22 transmissivity data, and you described a process 23 of laying your grid over a USGS contour map and 24 performing interpolations and then adjusting 25 transmissivity during the calibration. Jack Besoner & Associates, Inc. 321 1 Is that data still a part of the model? 2 A. Yes. 3 The transmissivity data is in the 4 process of being updated. 5 Q. Are you performing that updating? 6 A. Yes, with the help of the Planning 7 Department. 8 Q. Is this updating of the transmissivity 9 data similar to the method in which the original 10 transmissivity data was input to the model? 11 A. The Planning Department is in the 12 process of updating and testing the transmissivity 13 data for Palm Beach County. I am not sure of the 14 method that was used in transferring data from the 15 to the -- let me reword that. 16 I'm not sure of the mechanics of the 17 workup of the grid values that they performed. 18 Q. Do you know what source they are 19 obtaining transmissivity data from? 20 A. I am not sure. 21 Q. Do you know, specifically, who is doing 22 that work in the Planning Department? 23 MR. FROST: I object to the scope of 24 the future calibration efforts, in that they were 25 not used. Jack Besoner & Associates, Inc. 322 1 MR. WYCKOFF: Counsel, he just said 2 they are doing it now. 3 MR. FROST: There is no establishment 4 they are doing it in conjunction with the modeling 5 efforts for the Water Management Areas. But I 6 will allow the witness to answer the question. 7 THE WITNESS: Larry Brion from the 8 Planning Department has participated, I think, in 9 conjunction or with the help of either 10 hydrogeology or ground water with the 11 reorganization. I lost track of the names. 12 BY MR. WYCKOFF: 13 Q. Do you know why the transmissivity data 14 is being updated? 15 MR. FROST: Objection to scope. 16 MR. WYCKOFF: I am just trying to 17 satisfy your need, Counsel. 18 MR. FROST: There has, also, been no 19 establishment that transmissivity data in Palm 20 Beach County would in any way effect the results 21 of the modeling analysis for the WMA's. 22 MR. WYCKOFF: We are getting there. 23 THE WITNESS: As I understand it, there 24 is some more recent data available, and we want to 25 incorporate this recent data, if possible, in the Jack Besoner & Associates, Inc. 323 1 model, just to maintain the model as part of the 2 process. 3 BY MR. WYCKOFF: 4 Q. Do you know whether transmissivity data 5 is now available for the WCA's and the Park? 6 A. The Corps published a map with more 7 contours of transmissivity data for the East 8 Everglades region in Dade County in their 1989 9 document of the work done for the South Florida 10 Water Supply Study. I would have to double-check 11 on the source of that map. 12 Q. Have you compared the contour map you 13 just identified with the transmissivity data which 14 you input in the Water Management Model? 15 A. The greatest difference is near the 16 East Everglades region where the transmissivity is 17 about twice as high as what they have as 18 previously been published or what is presently in 19 the model. 20 Q. So you have compared the 1989 21 publication with the Water Management Model's 22 transmissivity information? 23 A. Yes. 24 Q. Have you made any changes to the 25 transmissivity information for the East Everglades Jack Besoner & Associates, Inc. 324 1 which is currently in the Water Management Model 2 since reviewing this publication? 3 A. I haven't incorporated the changes yet, 4 but it will be done in this present calibration 5 effort. 6 I just want to add. A sensitivity 7 analysis was performed by Larry Brion on comparing 8 the new transmissivity values in Palm Beach County 9 and ones that already existed in the model, and 10 though it showed some difference in simulating 11 ground water stages in Palm Beach County, there's 12 actually a negligible difference due to that 13 change in the other areas, and the change 14 decreased the further you go away from Coastal 15 Palm Beach County. 16 Other sensitivity analyses may be 17 performed, if time allows. 18 Q. What other sensitivity analyses? 19 A. As additional transmissivity data 20 becomes available elsewhere. 21 Q. Do you know how the new Palm Beach 22 County transmissivity data differed from that 23 already in the model? 24 MR. FROST: You're asking for a 25 specific difference in values? Jack Besoner & Associates, Inc. 325 1 BY MR. WYCKOFF: 2 Q. Can you characterize it in a way that 3 you have characterized this East Everglades 4 transmissivity information which you said is twice 5 as high as what's in the model currently? 6 MR. FROST: Objection, scope. 7 I believe the witness has testified 8 that it had a negligible, if any, impact on the 9 areas that are of concern with this deposition. 10 MR. GARVER: Are you talking about 11 geographic areas? 12 MR. FROST: Yes, in terms of the 13 model. 14 I mean, the witness testified that the 15 transmissivity values pursuant to a sensitivity 16 analysis showed that there is negligible impacts 17 in terms of the model on the areas that it would 18 be modeling for the WMA's. 19 I will allow the witness to answer that 20 question. 21 BY MR. WYCKOFF: 22 Q. You want me to reformulate the 23 question? 24 A. To the best of my recollection, the 25 transmissivity values in the northern half of Palm Jack Besoner & Associates, Inc. 326 1 Beach County were higher than the -- higher than 2 what is presently in the model. 3 Q. Do you know whether they were twice as 4 high? 5 A. I don't know. 6 I have never actually seen the values 7 themselves, the comparison of the values 8 themselves. I have just seen the comparison, the 9 results of the sensitivity analysis. 10 I learned of the transmissivity -- new 11 transmissivity values being higher in certain 12 areas through personal communication with Larry 13 Brion. 14 Q. Do you know when, rather, do you know 15 whether there is a deadline for the incorporation 16 of the new transmissivity data in the model? 17 MR. FROST: Objection, asked and 18 answered. 19 Several witnesses have already 20 testified about the schedules for the calibration 21 process. 22 MR. WYCKOFF: We are here with this 23 witness today, Counsel. 24 He has not answered this question. 25 MR. FROST: He has also discussed the Jack Besoner & Associates, Inc. 327 1 schedule for the calibration process. But I will 2 let him answer. 3 MR. WYCKOFF: I don't believe that he 4 has. 5 THE WITNESS: We hope to have this 6 present calibration effort completed by sometime 7 in March. 8 BY MR. WYCKOFF: 9 Q. Do you know when the transmissivity 10 information should be actually incorporated into 11 the model? 12 A. Well, updated transmissivity values 13 will be performed before the calibration runs 14 begin. 15 Q. So it's, basically, the same deadline? 16 A. Yes. 17 Q. By the end of March. 18 Since your initial calibration effort 19 in the early '80's, that we have gone over the 20 past couple of days, are you aware of any changes 21 which have been made to the variables that we have 22 identified as the surface water interaction 23 coefficient? 24 MR. FROST: You mean, in general 25 terms? Or do you mean for any possible change Jack Besoner & Associates, Inc. 328 1 within any node for that coefficient? 2 MR. WYCKOFF: I am going to start by 3 asking the witness, is he aware of any changes to 4 the coefficients. 5 THE WITNESS: Well, in performing the 6 simulations for the most recent West Well Field 7 Study, I made a slight change to the coefficient 8 for land use type Swamp 1, which is a land use 9 type, principally, in Water Conservation Area 3A 10 in the Park. 11 BY MR. WYCKOFF: 12 Q. Does this change still exist in the 13 model now? Or did you do it just for the purpose 14 of simulating the West Well Field? 15 A. No, it still exists. 16 Q. What was the change? 17 A. I effectively took out the coefficients 18 dependent on surface water depth. 19 Q. Why did you do that? 20 A. Because I noticed in reviewing the 21 results of the runs, preliminary runs, that there 22 was an instability or, I should say, some 23 oscillations in the simulated daily stages at the 24 3A-28 gauge location. 25 The instability occurred during times Jack Besoner & Associates, Inc. 329 1 of higher rainfall. It occurred when the stage in 2 Water Conservation Area 3A was high and, thus, the 3 depth of water at the -- the simulated depth of 4 water at 3A-28 which was in the southern end of 5 Water Conservation Area 3A was high. Thus, I got 6 us dependent on depth, and as a result, the 7 numeric oscillation was eliminated. 8 MR. WYCKOFF: Could you read me that 9 last part of his answer back. 10 (Thereupon the referred to answer was 11 read back by the reporter as above 12 recorded.) 13 MR. WYCKOFF: You think you can clarify 14 that a little bit or is that clear? 15 MR. FROST: What's your question. 16 MR. WYCKOFF: I am puzzled by the look 17 of puzzlement on the witness' face. 18 MR. FROST: Are you asking him? 19 BY MR. WYCKOFF: 20 Q. Did you complete your answer? 21 A. Yes, I completed my answer. 22 Q. Did you perform a sensitivity analysis 23 in making the change? 24 A. Yes, I made a sensitivity analysis. 25 I tested a couple of values and looked Jack Besoner & Associates, Inc. 330 1 at the results. 2 Q. Did you recalibrate the model after 3 performing this change? 4 A. No. 5 Q. Is this the only change since your 6 initial calibration effort to the surface water 7 interaction coefficient? 8 A. As best as I can recall, yes. 9 Q. Since the initial calibration effort, 10 have any changes been made to the hydraulic 11 conductivity coefficient? 12 A. I have to look at the data files to be 13 able to answer that question. I just can't recall 14 the details. 15 Q. Do you recall any changes having been 16 made, as opposed to details of changes? 17 A. I think I may have made a few minor 18 adjustments in the latest simulations for the West 19 Well Field Study. 20 I don't recall any changes between the 21 time the calibration and verification effort was 22 made for the Water Supply Study and the time that 23 I performed simulations to determine any effect of 24 the Water Management Areas on water supply in the 25 SWIM Plan 1989. Jack Besoner & Associates, Inc. 331 1 The only way you can be sure is if it's 2 possible to compare the data files. 3 Q. Were the simulations you performed for 4 the West Well Field done subsequent to the SWIM 5 Plan simulations? 6 A. Yes. 7 Q. Would whatever changes you made to the 8 hydraulic conductivity coefficient in performing 9 simulations for the West Well Field study still be 10 in the model today? 11 A. Yes. 12 Q. Do you remember if you conducted a 13 sensitivity analysis at the time you made the 14 changes? 15 A. No, I didn't. 16 Q. Did you recalibrate the model after 17 making those changes? 18 A. No. 19 Q. Do you recall now what those changes to 20 the hydraulic conductivity coefficient were? 21 A. I'd have to check the data file. I 22 don't recall exactly. It was very minor 23 adjustments. 24 Q. Do you recall on what basis you decided 25 to change the coefficient? Jack Besoner & Associates, Inc. 332 1 A. I made minor changes on the basis of 2 the new transmissivity, yeah, new transmissivity 3 values that were published in the Corps report in 4 1989. 5 MR. WYCKOFF: You want to take a 6 break? 7 MR. FROST: Now would be a good time. 8 (Thereupon a recess was taken in 9 deposition, after which the 10 deposition continued as follows:) 11 BY MR. WYCKOFF: 12 Q. When we broke, we were discussing the 13 changes that you most recently made to the 14 hydraulic conductivity coefficient variable in the 15 Water Management Model, and you stated that you 16 made some very minor changes to the hydraulic 17 conductivity coefficient based on the new 18 transmissivity values in the 1989 Corps of 19 Engineers report. 20 Do you now remember, in any greater 21 detail, the changes which you made to the 22 hydraulic conductivity coefficient? 23 MR. FROST: Objection, asked and 24 answered. 25 THE WITNESS: No, I'd have to check the Jack Besoner & Associates, Inc. 333 1 file. 2 BY MR. WYCKOFF: 3 Q. Would any of the exhibits to this 4 deposition provide you with something that might 5 refresh your recollection of the changes you may 6 have made, such as the Exhibit RS-4; or would that 7 not help you? 8 A. No, it wouldn't. 9 MR. FROST: Just for clarification, I 10 mean, Ray has not seen all the exhibits to this 11 deposition. 12 MR. WYCKOFF: Right. And I 13 specifically referenced RS-4, which contains the 14 code. 15 MR. FROST: Okay. I just wanted to 16 make sure you weren't asking him to definitively 17 state -- 18 MR. WYCKOFF: No. 19 BY MR. WYCKOFF: 20 Q. Do you recall whether subsequent to the 21 initial calibration effort that we have been 22 talking about for the past couple of days whether 23 any changes may have been made in the model to 24 Manning's Coefficient? 25 A. I'd have to look at the data files to Jack Besoner & Associates, Inc. 334 1 answer that question. 2 Since the completion of the, I'd say 3 the calibration effort that was done for the Water 4 Supply Study, I don't recall making changes to the 5 Manning's Coefficient, but I'd have to check and 6 compare the present data files with the data files 7 back then to be sure. 8 Q. Subsequent to the initial calibration 9 effort that we have discussed, do you recall 10 making any changes to the ET values in the model? 11 A. No. 12 Since the verification process where we 13 compared data results from the data period 1976 to 14 1982 which was done -- I'd say which was completed 15 after the publication of Technical Publication 16 84-3, I do not recall making any adjustments in 17 the input parameters for ET. 18 Q. Are you aware of newer land elevation 19 data which the District has which would be 20 appropriate for use in the Water Management Model? 21 A. Do you mean for future uses of the 22 model or changes in the recent data that was 23 incorporated since the calibration was performed 24 for the Water Supply Study? 25 Q. Are you aware of some land elevation Jack Besoner & Associates, Inc. 335 1 data which has been acquired by the District 2 subsequent to the calibration which was performed 3 for the Water Supply Study? 4 MR. FROST: Is this in addition to the 5 data Mr. Santee has already testified about 6 concerning WCA-1? 7 MR. WYCKOFF: That's correct. 8 MR. FROST: So it's in addition to 9 that. 10 THE WITNESS: Well, we have updated the 11 land elevation data in Everglades National Park 12 based on the data, I guess, provided by the Park. 13 We are probably looking into many 14 sources of land elevation in the Everglades 15 Agricultural Area. 16 Any new information that we may find 17 will be incorporated into the model in this 18 present calibration effort. 19 BY MR. WYCKOFF: 20 Q. When was the Everglades National Park 21 land elevation data incorporated into the model? 22 A. It was incorporated this last Summer. 23 Q. 1989 or 1990? 24 A. 1990. 25 That data was used in the most recent Jack Besoner & Associates, Inc. 336 1 analysis of the West Well Field or of the proposed 2 West Well Field. 3 Q. What efforts were undertaken to verify 4 the data? 5 MR. FROST: Objection, foundation. 6 THE WITNESS: I don't know what efforts 7 were made on the Everglades National Park end to 8 verify the data. 9 We formed the process of, through use 10 of what they call a server package that we had on 11 the PC to transform the format as given to us by 12 the Park to a format -- 13 BY MR. WYCKOFF: 14 Q. That was usable? 15 A. -- that's readable by the model. 16 We, of course, verified that the grid 17 values generated from this post-processing 18 program -- I'd say a preprocessing program 19 reflects what is given to us from the Park. 20 Q. Who conducted that process of 21 transferring or transforming formats and then 22 verifying that the grid values generated 23 accurately reflected the data? 24 A. Cal Neidrauer did. 25 Q. Did you review his work effort? Jack Besoner & Associates, Inc. 337 1 A. Not really. 2 I just, briefly, looked at the values. 3 I trust -- I had trust in his efforts. 4 Q. Regarding the newer land elevation data 5 for Conservation Area 1, what District efforts are 6 you aware of to verify that data? 7 A. You mean to verify the data that's 8 inputted into the model? 9 Q. Correct. 10 A. Like I say, I am not aware of any 11 District effort to verify that land elevation 12 data. The data was based on data -- let me 13 repeat myself -- the data taken from published 14 sources. 15 Part of the problem is, there is more 16 than one source of data, and each source gave 17 different values or different distributions within 18 the Water Conservation Area 1. 19 I guess, till recently when they 20 performed a simulation effort, I guess what's 21 referred to as the twenty-five ton removal as 22 found at the inundation was too high, particularly 23 in the southern half of Water Conservation Area 1, 24 and upon investigating the reason for it, 25 determined maybe the problem may be due -- maybe Jack Besoner & Associates, Inc. 338 1 the problem could be due to the land elevation 2 values that were already input in the model. 3 I found out, as I stated earlier, in a 4 conversation with Karen Lithgow and through 5 looking in reports that were published concerning 6 Water Conservation Area 1 that a source -- there 7 is a source that was considered the most reliable, 8 and that source was different than the source used 9 for the preparation of the data that was already 10 in the model. So I changed the land elevation 11 value for Water Conservation Area 1 to reflect the 12 more reliable source or I'd say the source that's 13 considered the more accurate one. 14 Q. When you say that this new source is 15 considered more accurate or reliable, who is it 16 that you are referring to that considers it more 17 accurate or reliable? 18 A. I learned that Walt Dineen considered 19 that source to be the most accurate. 20 Q. That's what Miss Lithgow told you? 21 A. Yes. 22 Q. Do you remember what this source is? 23 A. I recollect the source is from the Fish 24 and Wildlife Service. 25 Q. Are you aware of whether you conducted Jack Besoner & Associates, Inc. 339 1 a sensitivity analysis for the updated land 2 elevation values for Everglades National Park? 3 A. No, I did not. 4 Q. Did you recalibrate the model after you 5 updated that land elevation data? 6 A. No, I have not, not yet. 7 That's going to be performed very 8 soon. The calibration effort is going to 9 commence, hopefully, the beginning of next year. 10 Q. Regarding the Fish and Wildlife Service 11 land elevation data, did you perform a sensitivity 12 analysis when you incorporated the new data into 13 the model? 14 A. No. 15 Q. Are you finished? 16 A. Yes. 17 Q. Did you perform a recalibration of the 18 model when you incorporated that land elevation 19 data? 20 A. Yes. 21 I did a mini-calibration for Water 22 Conservation Area 1 for the year 1989. 23 Q. You did not recalibrate the rest of the 24 model? 25 A. No. Jack Besoner & Associates, Inc. 340 1 Q. Have you updated any additional data in 2 the model which we have not already discussed 3 subsequent to that initial calibration effort? 4 A. No, I don't recall any additional 5 changes up to this point. 6 Q. When Mr. Garver was asking you 7 questions, you gave some testimony -- that was 8 years ago. I know. (Indicating) that guy over 9 there. 10 A. Okay. I didn't know his last name. 11 Q. -- you gave testimony concerning the 12 new algorithms which you added to the Management 13 Model. 14 Are those the same as the variables we 15 have already discussed? 16 A. I don't quite understand the question. 17 Q. You recall the prior testimony you gave 18 concerning the new algorithms? 19 A. Yes. 20 Q. You will just have to bear with me, 21 'cause I am not a mathematician or a modeler. 22 What is the difference between those 23 algorithms you previously discussed and the 24 coefficients which we have been going over the 25 past couple of days? Jack Besoner & Associates, Inc. 341 1 Would you like me to rephrase the 2 question? 3 A. Well, in adding the new algorithms to 4 the model, new variables were added. 5 Q. Are these variables which will undergo 6 adjustment in the calibration process? 7 A. The coefficients used in calculating 8 the seepage through -- calculating the seepage of 9 surface water through the levees may be adjusted. 10 Q. Whose decision was it to add the new 11 algorithms to the model? 12 A. It was under the directive of George 13 Marban and Shawn Sculley. 14 Q. What did Mr. Marban or Sculley say to 15 you regarding adding new algorithms to the model? 16 A. Due to oscillations which occurred in 17 the simulated canal stages -- let me start over. 18 Oscillations occurred in the simulated 19 daily stages in L-31 North in Dade County and, to 20 a lesser extent, in canals just downstream of L-31 21 North. This was due to the way in which the model 22 was releasing water for water supply to the area. 23 This oscillation was evident in the 24 results that were presented to Dade County from 25 the initial round of -- initial round of Jack Besoner & Associates, Inc. 342 1 simulations that were done for the proposed well 2 field study done in February -- around February 3 1990. 4 As a result of that, George, Shawn, and 5 myself deemed it necessary to add the algorithms 6 to the model to minimize that oscillation and 7 deemed it necessary to improve the model. In that 8 way, we'd have a better, more accurate model for 9 future applications. 10 MR. FROST: Would this be a good time 11 to stop for lunch? 12 MR. WYCKOFF: Sure. 13 (Thereupon a lunch break was taken after which 14 the deposition continued as follows) 15 CROSS EXAMINATION CONTINUED 16 BY MR. WYCKOFF: 17 Q. When we left off before lunch, we were 18 talking about the new algorithms which you have 19 added to the Water Management Model, and the one 20 which we have discussed so far had to do with 21 oscillations in the simulated daily canal stages 22 in L-31 North, correct? 23 A. Yes. 24 Q. Where did the algorithm come from that 25 you added to the model? Jack Besoner & Associates, Inc. 343 1 A. I sort of developed the algorithm from 2 scratch. In other words, I programmed the 3 algorithm into the model. 4 Q. Did the development of this algorithm 5 proceed on a trial and error basis? Or how 6 exactly did you develop it? 7 A. The purpose of the algorithms or I 8 should say the purpose of one of the algorithms 9 added to the model was to quantify the volume of 10 water needed to maintain the canals at desired 11 minimum levels. 12 It was developed so the model would 13 more or less know how much water to deliver to the 14 Lower East Coast for water supply on a daily 15 basis. The algorithm was added to achieve that 16 end. 17 Of course, I had to make many runs to 18 test the algorithm to assure that it was working 19 properly. 20 The subroutine was not developed on a 21 trial and error basis. It was to achieve a 22 definite goal. 23 Q. Did you make any changes to this 24 subroutine? 25 Is subroutine and algorithm synonymous, Jack Besoner & Associates, Inc. 344 1 in your mind? 2 A. They are not necessarily the same. 3 I added the algorithm into the model as 4 a subroutine or in the form of a subroutine. 5 Q. In the course of making these test 6 runs, did you make any changes to this algorithm? 7 A. Yes. 8 In testing the algorithm, I had to make 9 several changes to the code that I initially added 10 to achieve the final goal. 11 Q. Were all the algorithms which you added 12 to the model at that time, together, designed to 13 minimize the oscillations in the L-31 North 14 simulated daily canal stages? 15 A. Although the oscillations that occurred 16 in L-31 North stages was a trigger in adding the 17 algorithm, the purpose of the algorithm was to 18 apply to all the canals in the Lower East Coast 19 Service Areas. The purpose of the algorithm is to 20 improve the models routing of surface water supply 21 releases in -- please read back my answer. 22 (Thereupon the referred to question was 23 read back by the reporter as above 24 recorded.) 25 THE WITNESS: Change in from all the Jack Besoner & Associates, Inc. 345 1 Conservation Areas or from the lake. 2 MR. WYCKOFF: Give me that one more 3 time. I don't understand the way that you have 4 revised your answer. 5 MR. FROST: I object to going into the 6 purpose of these algorithms, because Mr. Garver 7 went into those with Mr. Santee at some length. 8 You're asking for this witness to go 9 back over all the testimony that's already 10 provided on algorithms in the model. 11 MR. WYCKOFF: None of the questions 12 which I have asked Mr. Santee, nor any of his 13 answers, have repeated any of his prior testimony. 14 MR. FROST: I would certainly disagree. 15 He has spoken about the purpose of 16 these algorithms already. 17 The question was asked by Mr. Garver. 18 MR. WYCKOFF: Well, I am not going to 19 withdraw the question. 20 MR. FROST: Could you read back the 21 question. 22 (Thereupon the referred to question was 23 read back by the reporter as above 24 recorded.) 25 MR. FROST: So what it is you don't Jack Besoner & Associates, Inc. 346 1 understand? 2 MR. WYCKOFF: The last thing he said. 3 The last thing I heard you say, Mr. 4 Santee, was the sentence, the purpose was to 5 improve the model's routing of the surface water 6 supply releases from. Then you said change in the 7 Water Conservation Areas and the lake. 8 MR. FROST: I think what he said was to 9 change the word "in" to the word "from". 10 MR. GARVER: That's also my 11 understanding. 12 BY MR. WYCKOFF: 13 Q. So would your answer, then, be the 14 purpose was to improve the model's routing of 15 surface water supply releases in the Conservation 16 Areas? 17 A. No. 18 It would be water supply releases from 19 either the Conservation Areas or Lake Okeechobee. 20 MR. WYCKOFF: Let's take a break. 21 (Thereupon a recess was taken in 22 deposition, after which the 23 deposition continued as follows:) 24 BY MR. WYCKOFF: 25 Q. Before we broke, we had just gone over Jack Besoner & Associates, Inc. 347 1 the purpose of adding the subroutine, which was an 2 algorithm designed to improve the model's routing 3 of surface water supply releases from either the 4 WCA's or Lake Okeechobee. 5 Were there other subroutines which you 6 added to the model? 7 MR. FROST: Objection, asked and 8 answered. 9 BY MR. WYCKOFF: 10 Q. You can answer the question. 11 MR. FROST: Do you mean, other than 12 algorithms? 13 MR. WYCKOFF: Other than the one 14 subroutine we have gone over. 15 MR. FROST: So you're including the 16 algorithm that we went over quite extensively 17 already? 18 MR. WYCKOFF: We have gone over one 19 algorithm that the witness added to the model. 20 MR. FROST: In the last half hour. 21 But we went over several algorithms 22 when the witness described what it is to Mr. 23 Garver when he was asking the questions. 24 BY MR. WYCKOFF: 25 Q. Insofar as the time that I have been Jack Besoner & Associates, Inc. 348 1 asking you questions, we have gone over one 2 algorithm which you added as a subroutine to the 3 model. 4 Were there other subroutines which you 5 added to the model? 6 MR. FROST: Objection, asked and 7 answered. 8 BY MR. WYCKOFF: 9 Q. You may answer the question. 10 A. I added a subroutine to calculate 11 seepage of surface water through the levees. 12 Levees dividing the Water Conservation Areas from 13 the Lower East Coast were included. 14 Q. What triggered the need to add the 15 subroutine? 16 MR. FROST: Objection, asked and 17 answered. 18 THE WITNESS: I triggered it in the 19 knowledge that that seepage simulated in the model 20 by use of the ground water equation, alone, 21 underestimated the seepage through the levees due 22 to the grid resolution. 23 BY MR. WYCKOFF: 24 Q. Is this an algorithm? Well, let me use 25 the word subroutine. That's the word that we have Jack Besoner & Associates, Inc. 349 1 been using. 2 Was this subroutine comprised of one 3 algorithm? 4 A. I'd say that was -- what I just 5 described is the sole purpose of that subroutine. 6 Q. Would you say that this subroutine is 7 what you have characterized the prior subroutine 8 as, an algorithm? 9 MR. FROST: Objection, 10 mischaracterization. 11 THE WITNESS: Yes, I'd clarify it as an 12 algorithm similar to the definition of how that 13 word is used for the other subroutines. 14 BY MR. WYCKOFF: 15 Q. How do you define algorithm? 16 MR. FROST: Objection, relevance. 17 Maybe you could explain to us why how 18 this witness defines algorithm is relevant to 19 anything concerning this deposition. 20 MR. WYCKOFF: It's a basic component of 21 the model as it stands today, as this witness has 22 modified the model. 23 Inasmuch as he has used the term a 24 number of times today, I want to know exactly what 25 he means. Jack Besoner & Associates, Inc. 350 1 MR. FROST: He has explained at length 2 what these algorithms do and how they were added. 3 Why he should define one is certainly 4 beyond me. But I will allow him to answer it. 5 BY MR. WYCKOFF: 6 Q. You may answer. 7 A. I guess my interpretation of an 8 algorithm is a set of principals or equations 9 and/or assumptions that are used to achieve a goal 10 or fulfill a purpose. 11 Q. Do the algorithms which you added to 12 the model describe hydrologic features of the 13 South Florida water conveyance system? 14 A. I don't quite understand the question. 15 Q. Was your purpose in adding the 16 subroutines which you added, in part, to describe 17 the function of the hydrologic system as it 18 presently exists? 19 MR. FROST: Objection, asked and 20 answered. 21 Mr. Santee has already described the 22 purpose of these algorithms and these 23 subroutines. 24 THE WITNESS: The algorithms do 25 incorporate some features of the hydrologic Jack Besoner & Associates, Inc. 351 1 system. 2 BY MR. WYCKOFF: 3 Q. When you were developing or, rather, 4 after you developed these algorithms, did Mr. 5 Sculley and Mr. Marban discuss them with you? 6 A. They encouraged me to document the 7 results of the improvement to show the comparison 8 of appropriate results before and after 9 incorporation of the algorithms. 10 Q. Did you provide them with such 11 documentation? 12 A. Yes, I provided them with some 13 comparisons, and they were presented at one of the 14 meetings with Dade County and a couple of people 15 from the Corps with regard to the latest 16 simulations of the proposed West Well Field. 17 Q. When you added these subroutines to the 18 model, did you perform any sort of analysis? 19 Did you perform any sensitivity 20 analysis? 21 A. No. 22 Q. Did you recalibrate the model? 23 A. No. 24 Q. When changes are made to the Water 25 Management Model, insofar as the changes which you Jack Besoner & Associates, Inc. 352 1 have been associated with, is there someone 2 responsible for interacting with the Corps 3 regarding the changes to the model? 4 MR. FROST: Objection, scope. 5 THE WITNESS: I am not aware of any 6 contractual obligation. 7 However, as a professional courtesy in 8 dealing with other agencies, I think I am largely 9 response for communicating changes that I have 10 incorporated into the model to them. 11 A revised version of the model and the 12 data will be sent to them upon completion of the 13 calibration. 14 BY MR. WYCKOFF: 15 Q. Regarding the two subroutines we had 16 most recently discussed today, did you communicate 17 those changes to the Corps, other than at the 18 meeting regarding the proposed West Well Field? 19 MR. FROST: Objection, scope. 20 What was communicated and what was sent 21 to the Corps is certainly far beyond the scope of 22 this deposition. 23 MR. WYCKOFF: I don't think that it is, 24 Counsel, and certainly as I develop these 25 questions, I think that you will see that. Jack Besoner & Associates, Inc. 353 1 MR. FROST: Has there been any 2 testimony thus far that indicates the Corps was 3 involved in any way with evaluating the potential 4 effects on hydrology, water supply and water 5 quantity? 6 MR. WYCKOFF: Gee, maybe today is the 7 day that we will find that out. 8 MR. FROST: I will let the witness 9 answer the question, but it's far beyond the 10 scope. 11 THE WITNESS: I have only, maybe, 12 mentioned over the phone that I have made changes 13 to the model, but I haven't presented any 14 documentation to them or haven't presented them 15 with any details. 16 BY MR. WYCKOFF: 17 Q. To whom would you have communicated 18 this on the phone? 19 MR. FROST: Objection, scope. 20 THE WITNESS: I have communicated over 21 the phone to Bob Freidman and some to Roland 22 Dealtermarino. 23 BY MR. WYCKOFF: 24 Q. When you presented comparisons at the 25 meeting with Dade County at which the Corps was Jack Besoner & Associates, Inc. 354 1 present or subsequent to that meeting, have you 2 had any feedback from the Corps on the 3 appropriateness or accuracy of the algorithms 4 which you added? 5 A. No. 6 The results that I have presented to 7 them clearly show an improve in the results. 8 Q. To your knowledge, has the Water 9 Management Model been criticized for lacking 10 enough continuous data points? 11 MR. FROST: By whom? 12 MR. WYCKOFF: By anybody. 13 MR. FROST: You mean, for any reason? 14 MR. WYCKOFF: I just gave the reason in 15 the question, Counsel. 16 Would you like it read back? 17 MR. FROST: No. I understand what you 18 said. But there are many reasons why. 19 If they are criticizing for data 20 points, it could be for water supply. It could be 21 for a whole number of reasons. 22 You're just asking for any criticism 23 concerning insufficient data points? 24 MR. WYCKOFF: That's correct. 25 THE WITNESS: That, I don't quite Jack Besoner & Associates, Inc. 355 1 understand. 2 You mean, for an insufficient number of 3 data points using calibration? 4 MR. WYCKOFF: The input to the model. 5 MR. FROST: You mean for inputs? 6 Are you looking at one particular input 7 file? 8 MR. WYCKOFF: Any of the input files. 9 THE WITNESS: No, I am not aware of any 10 criticism along those lines. 11 BY MR. WYCKOFF: 12 Q. We have gone over two subroutines which 13 you added to the model. 14 In regard to the calculation of surface 15 water seepage through the levees, you have 16 responded that you provided Sculley and Mr. Marban 17 with comparisons. 18 Did you also provide them with 19 comparisons of before and after regarding the 20 algorithms you added to quantify the volume of 21 water necessary to maintain desired minimum canal 22 levels? 23 MR. FROST: Objection, ambiguous. 24 BY MR. WYCKOFF: 25 Q. Do you understand the question? Jack Besoner & Associates, Inc. 356 1 A. Yes. 2 The comparisons that I presented them? 3 Q. Including, both. 4 A. Was the comparison between the results 5 after I added that subroutine I just described? 6 Q. The second subroutine, surface water 7 seepage through the levees dividing the WCA's from 8 the Lower East Coast? 9 A. I am sorry. 10 What I presented them with was the 11 comparison I have added, the first subroutine. 12 Q. Did you provide Mr. Sculley and Mr. 13 Marban with comparisons after you added the second 14 subroutine? 15 A. No. 16 Q. Did addition of the two subroutines 17 result in significant differences in the model's 18 output? 19 A. That's a very broad question. I need a 20 little -- some more detail. 21 Q. After you added the algorithm which 22 calculates the surface water seepage through the 23 levees dividing the Conservation Areas from the 24 Lower East Coast, did the model's simulation of 25 flow significantly increase over the results which Jack Besoner & Associates, Inc. 357 1 were produced prior to your adding the subroutine? 2 A. There is a significant increase in the 3 seepage of surface water from the Water 4 Conservation Areas to the Lower East Coast. 5 Q. Did addition of the algorithm to 6 quantify the volume of water necessary to maintain 7 minimum canal levels result in significant 8 simulations, significant differences in the 9 simulated water supply deliveries to the Lower 10 East Coast? 11 MR. FROST: Please read that question 12 back. 13 (Thereupon the referred to question was 14 read back by the reporter as above 15 recorded.) 16 MR. WYCKOFF: I will try again. 17 BY MR. WYCKOFF: 18 Q. Did addition of the algorithm which 19 quantified the volume of water necessary to 20 maintain desired minimum canal levels result in 21 significant differences in simulated model water 22 supply deliveries to the Lower East Coast? 23 A. I can't answer that. I haven't 24 formally made a comparison. 25 Q. We have been going over changes which Jack Besoner & Associates, Inc. 358 1 you made to the Water Management Model. We 2 started off with five variables which you adjusted 3 during the initial calibration stage. Now, we 4 have gone over two subroutine/algorithms which you 5 have added to the model. 6 Are there any other changes to the 7 Water Management Model which you conducted? 8 A. Since what time? 9 Q. Well, I started this at the beginning 10 of your work on the Water Management Model and 11 tried to work my way along. 12 So what have we missed, if anything? 13 A. I have documented changes that are made 14 to the model from the time Technical Publication 15 84-3 was written to the beginning of the year 1987 16 in a memorandum which you have in your possession. 17 Q. Excluding those changes documented in 18 the memorandum, are there any others which we have 19 not identified so far? 20 A. I have added some code to assure the 21 model does not route too much water through the 22 structures within the Conservation Areas in any 23 one time step. 24 Q. Was that additional code based on the 25 structure pump capacity? Jack Besoner & Associates, Inc. 359 1 A. The capacity of the structure is one of 2 the limiting factors. 3 Q. What other factors were used in 4 devising the code which you added to the model? 5 A. I added code to quantify the volume of 6 water that is available to be routed through the 7 structures, and that is to prevent any simulated 8 stages in any one time step upstream of a 9 structure to be drawn down too far. 10 As a result, it may maintain the 11 stability in the stages and discharges on a daily 12 time step. 13 Q. Do you remember any other additions to 14 the code which you made subsequent to the 15 memorandum you previously discussed? 16 A. I don't recall any more at this time. 17 Q. Do you recall incorporating Tom 18 MacVicar's Rainfall Model into the Water 19 Management Model? 20 A. Yes. 21 Q. When you carried out that exercise, did 22 you make any changes in the Rainfall Model as you 23 were incorporating it into the Water Management 24 Model? 25 A. Changes added to the model reflected Jack Besoner & Associates, Inc. 360 1 the features that were documented in the Plan. 2 Q. If I understand your answer correctly, 3 you're referring to changes you instituted in the 4 Water Management Model reflected the features 5 documented in the Rainfall Model or Plan, as it's 6 sometimes called; is that correct? 7 A. Yes. 8 Q. Did you change any of the code or data 9 from the Rainfall Model when you were 10 incorporating it into the Management Model? 11 A. I added any input data and code 12 necessary to properly simulate the Plan, as was 13 documented. 14 Q. Were those changes that were necessary 15 for the Water Management Model to utilize that 16 plan, as compared to changes to the Rainfall Plan, 17 to make it more accurate? 18 A. I don't understand the question. 19 Q. Okay. I will reformulate the 20 question. 21 Mr. MacVicar told me that his Rainfall 22 Model was a statistically based model of the flow 23 into Shark River Slough, and that you incorporated 24 it into the Water Management Model in 1985. 25 When you did that, did you make changes Jack Besoner & Associates, Inc. 361 1 to the Rainfall Model which were unrelated 2 necessarily to having it function as a part of the 3 Water Management Model? 4 To put it another way. 5 Were the changes that you made in the 6 input data and the code intended to improve the 7 Rainfall Model or make it function as a part of 8 the Water Management Model? 9 A. The purpose is to make it function in 10 the Water Management Model. 11 Q. Did you verify the added input data? 12 A. The additional data needed to implement 13 the Plan in the model has been verified. 14 Q. Did you run any sensitivity analysis 15 when you were incorporating the Rainfall Model 16 into the Water Management Model? 17 A. Runs were made to compare the results 18 of the simulation with the Rainfall Plan and 19 without the Rainfall Plan to determine the 20 regional effect of implementing the Rainfall 21 Plan. 22 This is a part of the South Florida 23 Water Supply Study, as I recall. 24 Q. After you incorporated the Rainfall 25 Model into the Water Management Model, did you Jack Besoner & Associates, Inc. 362 1 recalibrate the Water Management Model? 2 A. No. 3 MR. WYCKOFF: Can we take a short 4 break? 5 (Thereupon a recess was taken in 6 deposition, after which the 7 deposition continued as follows:) 8 BY MR. WYCKOFF: 9 Q. Mr. Santee, when we began this portion 10 of the deposition where I was asking questions, I 11 was asking you about continuing education courses 12 which you took after arriving at the District. 13 A. Yes. 14 Q. And we got as far as a course on 15 artificial intelligence, and we went through that, 16 and after we did that, we got off on other 17 things. 18 A. That's very true. 19 Q. And now we have come back. 20 Can you list for me, to the best of 21 your recollection, the other continuing education 22 courses you have taken since you have been 23 employed by the Water Management District? 24 MR. FROST: You mean, formal courses? 25 BY MR. WYCKOFF: Jack Besoner & Associates, Inc. 363 1 Q. Well, if you could, list any sort of 2 seminars, course work at universities, course work 3 affiliated with universities or training sessions, 4 however you want to characterize continuing 5 education. 6 A. We may have covered it, but I will say 7 it just in case my memory isn't correct. 8 I took a course from CDC that lasted 9 about a week. 10 Q. That was on the new operating system? 11 A. That's the new operating system at the 12 time. 13 I took three USGS courses -- four USGS 14 courses that were given in Denver, Colorado. 15 The first course was entitled Finite 16 Elements of Ground Water Flow. The second one was 17 entitled Advanced Solutransport In Ground Water 18 Flow. 19 I took a course in statistical 20 hydrology. I took a technical writing course. I 21 don't remember the exact title. 22 Q. Those last four are the USGS courses? 23 A. Yes. 24 Q. Do you remember the years in which you 25 took these courses? Jack Besoner & Associates, Inc. 364 1 A. I think I took the courses right around 2 between the years of 1985 and 1987. 3 Q. All four of them? 4 A. Yes. 5 Q. Do you recall whether you made separate 6 trips to Denver for each of the four courses? Or 7 were some of them taught during the same trip? 8 A. The first two courses I mentioned were 9 taken on the same trip, and the next two were 10 taken on separate trips. 11 Q. Do you recall how many hours were 12 involved in each course? 13 A. Do you mean credit hours or number of 14 hours the course lasted? 15 Q. Did the courses carry any credit hour 16 numeration of any sort? 17 A. I am not sure. 18 Q. Do you recall how many days the courses 19 lasted? 20 A. The finite elements course lasted about 21 two weeks. 22 The solutransport course lasted a 23 week. 24 The statistical hydrology course, I 25 think, lasted four days. Jack Besoner & Associates, Inc. 365 1 The writing course lasted, I think, a 2 couple of days. 3 Q. Did you attend these courses all day 4 long or some portion of the day? 5 A. The courses lasted all day. 6 Q. Your first trip to Denver for the first 7 two courses you have listed, then, was a 8 three-week trip? 9 A. Yes. 10 Q. Did you receive any sort of grade in 11 these courses? Or was it more like a certificate 12 of attendance? 13 A. A certificate. 14 Q. Subsequent to these four USGS courses, 15 have you taken any other continuing education 16 courses? 17 A. I took a course on the Unix operating 18 system given by, I think it's Sun Micro systems. 19 I can't remember the exact name, but Sun is a key 20 word. 21 Q. S-U-N? 22 A. Yes. 23 Q. How long did that course last? 24 A. It lasted about a week. 25 Q. When did you take that course? Jack Besoner & Associates, Inc. 366 1 A. February 1988. 2 Q. Have you taken any other courses? 3 A. I can't recall any more at this time. 4 Q. Going back to the USGS courses. 5 Is the advanced solutransport in ground 6 water flow course a course regarding the computer 7 modeling of ground water contamination? 8 A. I think contamination was one of the 9 components studied. 10 Q. What else? 11 MR. FROST: Are you just asking for a 12 general response? Or do you want every item that 13 he had in his course? 14 BY MR. WYCKOFF: 15 Q. What were the other main features 16 examined in this course? 17 A. I'd have to review my notes from the 18 course. 19 Q. Have you applied any of the knowledge 20 you acquired in the solutransport course to work 21 that you perform for the District? 22 A. No, I haven't. 23 Q. What were the main features of the 24 course you have identified as the finite element 25 of ground water flow? Jack Besoner & Associates, Inc. 367 1 A. It touched upon the methods of solution 2 to the two-dimensional ground water equation. 3 We had to learn to apply the finite 4 element ground water model that they developed to 5 a sample problem that they gave us. Thus, we 6 learned some of the basic principals used in that 7 model which were the assumptions that were used in 8 the model, as well as some of the input data 9 required to run the model. 10 Q. Did the course deal with any other 11 ground water model and the finite element ground 12 water model? 13 A. It dealt with one model. We went into 14 the details of one model. 15 Q. Do you use -- you are not done? Go 16 ahead. 17 A. The basic principals that we learned 18 that we used in the model included leakage from 19 one aquifer to another. 20 Q. Do you use the knowledge which you 21 acquired in the finite element ground water model 22 course in your work at the District? 23 A. Some of the knowledge I gained from 24 that course helped me in applying a finite 25 elements of the surface water model. In Jack Besoner & Associates, Inc. 368 1 performing the analysis for the Kissimmee River 2 Restoration and the Ice Cream Slough Water Shed, 3 as I had to do in the finite element course, 4 generate fine element grids and prepare some input 5 data to implement the model. 6 Q. Can you think of any other instances in 7 your work at the District in which you have used 8 the knowledge you acquired in the finite elements 9 course? 10 A. No. 11 Q. Have you applied -- well, before we get 12 to that. 13 What was the focus of study in the 14 statistical hydrology course? 15 A. The focus of study, as I recall, was 16 the statistical analysis of hydrologic data. 17 Q. Are there special techniques that 18 applied hydrologic data? 19 A. Yeah, there is statistical techniques 20 in analyzing hydrologic data. 21 MR. WYCKOFF: Can we take a quick two 22 minute break? 23 (Thereupon a recess was taken in 24 deposition, after which the 25 deposition continued as follows:) Jack Besoner & Associates, Inc. 369 1 BY MR. WYCKOFF: 2 Q. We were talking about statistical 3 hydrology and special techniques for the 4 statistical analysis of hydrologic data. 5 I presume that you have used the 6 knowledge that you acquired in that course in your 7 work in the District; am I correct? 8 A. A little, not extensively. 9 Q. Have you used the knowledge you 10 acquired in the statistical hydrology course in 11 any of the modeling which you have conducted on 12 nutrient removal proposals? 13 A. No. 14 Q. Did you acquire a knowledge in the 15 statistical hydrology course which you did not 16 previously have? 17 A. Yes. 18 Q. Did you use the knowledge which you 19 acquired in the statistical hydrology course to 20 revisit any of the analyses or work which you had 21 previously done with the Water Management Model? 22 MR. FROST: You're talking about such 23 things as calibration and verification? 24 MR. WYCKOFF: Changes to the model. 25 Those are the items we have been discussing. Jack Besoner & Associates, Inc. 370 1 THE WITNESS: No. 2 BY MR. WYCKOFF: 3 Q. Have you submitted any articles for 4 publication in referee journals? 5 A. No. 6 Q. Have you prepared any reports or 7 articles, other than South Florida Water 8 Management District technical publications or 9 technical memoranda? 10 A. No. 11 Q. Can you list the technical publications 12 which you have been an author or coauthor of? 13 MR. FROST: Objection, foundation. 14 THE WITNESS: You're talking about 15 formal technical publications? 16 BY MR. WYCKOFF: 17 Q. There's a formal document called 18 technical publication, is there not? 19 A. Yes. 20 Q. Have you been an author or coauthor on 21 any technical publications? 22 A. No. 23 Q. Is there a formal document called 24 technical memorandum? 25 A. Yes. Jack Besoner & Associates, Inc. 371 1 Q. Have you been an author or coauthor on 2 any technical memoranda? 3 A. I coauthored a technical memorandum 4 entitled the Basin Atlas of Martin County. That's 5 the only one I remember. 6 Q. Is Martin County considered to be in 7 the area called the Lower East Coast of the South 8 Florida Water Management District? 9 A. No. 10 Q. Have you prepared any documents to be 11 technical publications which never progressed 12 beyond the draft stage? 13 A. Yes. 14 I worked on one documenting work 15 concerning water supply with Broward County. 16 I worked on a paper concerning water 17 supply availability in Lee County. That project 18 got discontinued. I believe that one was to be a 19 special report. 20 I was part of a project team for the 21 Southwest Broward County Study that was done in 22 1982. There were a number of authors involved in 23 writing that publication. That's all I remember. 24 Q. Why was the Lee County Water Supply 25 availability paper discontinued? Jack Besoner & Associates, Inc. 372 1 MR. FROST: Objection, scope. 2 THE WITNESS: I am not sure exactly why 3 a decision was made. I know I had other 4 priorities that came to the forefront. 5 BY MR. WYCKOFF: 6 Q. Why was the paper documenting work on 7 water supply to Broward County not finished? 8 MR. FROST: Objection, scope. 9 THE WITNESS: Well, a draft was 10 completed, but it never got formally published, 11 and I never knew the explanation for that. It was 12 never communicated to me. 13 BY MR. WYCKOFF: 14 Q. What process does a paper, such as that 15 which has been completed, go through for formal 16 publication? 17 MR. FROST: Objection, scope. 18 THE WITNESS: Well, it has to go 19 through several levels of review, first, by 20 various engineers within the division, the 21 division director, then the department director. 22 Then, as I recollect, that's where it stopped, 23 when it was reviewed by the department director. 24 BY MR. WYCKOFF: 25 Q. Do you know why the 1982 Southwest Jack Besoner & Associates, Inc. 373 1 Broward Study did not get formalized? 2 MR. FROST: Objection, scope. 3 THE WITNESS: That one did get 4 formalized. 5 Paul and I wrote a chapter on the 6 modeling work that was done for the study, and the 7 report was formalized. 8 BY MR. WYCKOFF: 9 Q. Was it formalized as a technical 10 publication? 11 MR. FROST: Objection, scope. 12 THE WITNESS: I am not sure. I'd have 13 to check on that. 14 BY MR. WYCKOFF: 15 Q. In your twelve years at the District, 16 have you ever been passed over for promotion? 17 MR. FROST: Objection, scope. 18 Withdraw the objection. 19 THE WITNESS: From my point of view, I 20 felt I was when Tom Vanlent was promoted to the 21 Three Level and became my supervisor. 22 BY MR. WYCKOFF: 23 Q. What about Paul Trimble, did you feel 24 that he was promoted over you when he became 25 project manager of the calibration efforts on the Jack Besoner & Associates, Inc. 374 1 Water Management Model? 2 A. No. 3 MR. WYCKOFF: No further questions. 4 Thank you for being so patient. 5 RE-DIRECT EXAMINATION 6 BY MR. GARVER: 7 Q. Mr. Santee, will the water management 8 modeling that you are doing now, will the actual 9 model runs be done before or after the 10 recalibration of the model? 11 A. The runs will be done before 12 recalibration. 13 Q. Is there any possibility at all that 14 they would be done after the recalibration? And I 15 am not asking if they would be redone. I am 16 asking if they wouldn't be done until the 17 recalibration was done? 18 MR. FROST: Objection, asked and 19 answered. 20 THE WITNESS: If a decision is made by 21 upper management to do that, I would. 22 At this point, the plan is to perform 23 the runs before the calibration. 24 The possibility of doing it after the 25 calibration would have to be discussed with Tom Jack Besoner & Associates, Inc. 375 1 and other individuals to get their response on 2 that. 3 MR. GARVER: I have no further 4 questions. 5 I, also, thank you very much for your 6 patient, Mr. Santee. 7 THE WITNESS: Thank you. 8 (Thereupon the deposition was concluded) 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Jack Besoner & Associates, Inc. 376 1 CERTIFICATE 2 3 4 5 STATE OF FLORIDA: : SS. 6 COUNTY OF DADE: 7 8 I, Jackie Johnson, being a Notary 9 Public in and for the State of Florida at Large, do hereby certify that I reported in shorthand the 10 deposition of RAY SANTEE, that the deponent was first duly sworn by me; that reading and signing 11 of the deposition were not waived by the deponent; and that the foregoing pages, numbered from 1 12 through 375, inclusive, constitute a true and correct transcription of my shorthand notes of the 13 deposition. I further certify that I am not of 14 counsel, I am not related to nor employed by an attorney connected to the above-styled cause, nor 15 interested in the outcome thereof. The foregoing certification does not 16 apply to any reproduction of this transcript by any means unless under the direct control and/or 17 direction of the certifying shorthand reporter. IN WITNESS WHEREOF I have hereunto 18 affixed my hand this 4th day of February, 1991. 19 Jackie Johnson, NOTARY 20 PUBLIC AT LARGE. MY COMMISSION EXPIRES: 21 4-2-91. 22 23 24 25 Jack Besoner & Associates, Inc. 377 1 READING AND SIGNING 2 3 4 I have read the above transcript, pages 1 5 through 375 and I find: (MARK ONE) 6 7 ( ) The transcript is true, correct, and 8 completely accurate. 9 10 ( ) The transcript is true, correct, and accurate, 11 except as set forth in my List of Corrections 12 attached hereto, citing page and line and reason 13 for the correction realizing that, for this 14 purpose, I am still under oath. 15 16 _______________ _________________________ 17 (DATE) RAY SANTEE 18 19 20 Sworn to and subscribed before 21 me this______day of____________, 1990. 22 ___________________________ Notary Public 23 My Commission expires: 24 25 Jack Besoner & Associates, Inc. 378 1 TO BE EXECUTED BY THE NOTARY IF THE DEPONENT DOES 2 NOT SIGN: 3 4 5 6 I hereby certify that a letter with reference 7 to reading and signing deposition was mailed to 8 the witness through his attorney, on 9 ___________________, 1990, and that the witness 10 ( ) Witness refused to sign, giving the following 11 reason: 12 ( ) Neither the witness nor his attorney has 13 responded to request to read and sign. 14 15 16 _______________ ___________________________ 17 (DATE) Notary Public 18 MY COMMISSION EXPIRES: April 2, 1991. 19 20 21 22 23 24 25 Jack Besoner & Associates, Inc.