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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
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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
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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
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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
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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?
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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.
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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.
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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
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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,
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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
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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.
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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.
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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
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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
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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?
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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
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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
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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
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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
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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
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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.
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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?
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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
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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
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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
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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
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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?
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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
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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
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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.
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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?
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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
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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?
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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,
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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
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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
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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
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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
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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
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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.
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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
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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
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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.
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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
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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
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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?
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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
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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
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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?
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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
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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
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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
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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:
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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?
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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.
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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?
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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?
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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
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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:)
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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.
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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.
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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?
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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
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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
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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
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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)
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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
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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
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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.
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Jack Besoner & Associates, Inc.
