** 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 88-1886-CIV-HOEVELER UNITED STATES OF AMERICA, et al., ) ) Plaintiffs, ) ) VS. ) ) SOUTH FLORIDA WATER MANAGEMENT ) DISTRICT; JOHN R. WODRASKA, ) EXECUTIVE DIRECTOR, SOUTH FLORIDA ) WATER MANAGEMENT DISTRICT; ) FLORIDA DEPARTMENT OF ENVIRONMENTAL ) REGULATION; AND DALE TWACHTMANN, ) SECRETARY, FLORIDA DEPARTMENT OF ) ENVIRONMENTAL REGULATION, et. al., ) ) Defendants. ) / DEPOSITION OF DEWEY WORTH TAKEN ON BEHALF OF THE PLAINTIFF *** DATE: August 29, 1990 PROFESSIONAL REPORTING SERVICE Commerce Center 324 Datura Street, Suite 303 West Palm Beach, Florida 33401 (407) 659-4046 ** 2 INDEX August 29, 1990 DIRECT CROSS REDIRECT RECROSS DEWEY WORTH By Ms. Beverly Nash 5 By Mr. Joe Richards 32 ** 3 The deposition of Dewey Worth, in the above-entitled and numbered cause, was taken before me, KAREN BAUER FRY, C.S.R., Court Reporter and Notary Public for the State of Florida at Large, at Professional Reporting Service, Commerce Center, 324 Datura Street, in the City of West Palm Beach, Palm Beach County, in the State of Florida, beginning at the hour of 1:40 o'clock p.m., on August 29, 1990, pursuant to the Notice in said cause for the taking of said deposition, which is annexed to the Court file herein, on behalf of the Plaintiff in the above-entitled action pending in the above-named court. The appearances at said time and place were as follows: Beverly Sherman Nash, Esquire U.S. Department of Justice Environmental and Natural Resources Division P. O. Box 663 Washington, D.C. 20044-0663 Attorney for Plaintiff Joseph Richards, Esquire Peeples, Earl & Blank, P.A. Two South Biscayne Blvd. One Biscayne Tower, Suite 3636 Miami, Florida 33131 Attorney for Cities of Belle Glade and Clewiston ** 4 Katharine Stollman, Esquire Allison Burdette Skadden, Arps, Slate, Meagher, & Flom 1440 New York Avenue, N.W. Washington, D.C. 20005 Attorney for South Florida Water Management District Jackie Waters, Esquire So. Florida Water Management District Box 24680 3301 Gun Club Road West Palm Beach, FL 33416 ALSO PRESENT: Toni Lafuente Mike Rose David Buker Ray Roberts Bob Johnson ** 5 THEREUPON, DEWEY WORTH being by me first duly sworn to tell the whole truth, as hereinafter certified, testified as follows: DIRECT EXAMINATION BY MS. NASH: Q. Mr. Worth, I'm Beverly Nash, counsel for the United States in this litigation. We're here to find out about the Water Management District's computers, and what information is on them, and how that information is stored and formatted. You have been indicated as a representative of the district having knowledge of one or more of the 9 categories of inquiry. Have you been shown our list of categories? A. Yes. Q. And to which are you responsive? A. I'll have to take a look at the list, because there is too many. No. 1, really only in terms as it deals with our division. You've probably had access to ** 6 information from Bill Hall describing in grave detail the operations throughout the district. No. 2, only in regards to text information within our division. No. 3. No. 4, as it regards to some GIS information, CADD, the I square S, Auto/CADD System 600. No. 5, as it pertains to these above systems. No. 6, as it pertains to the environmental sciences division. And No. 9, I believe that's it. Q. What is your present title or position? A. I'm acting division director of environmental sciences. Q. And what department is environmental sciences? A. It's the department of research and evaluation. Q. What are your responsibilities? A. Right now, it's for administration of the division. Q. And how long have you been acting head? A. Since February of this year. Q. Have you had other positions at the Water ** 7 Management District? A. Yes. Q. What were they? A. Well, prior to that, supervising professional in the planning department under the environmental planning division. For six months prior to that, supervising professional in environmental sciences division for a year, I believe. And then prior to that, various professional positions with any internal sciences division. Q. And what were your job responsibilities? A. Going backwards or -- Q. Yeah. Why don't you start with your supervising professional position in planning? A. It was largely for macro skill planning efforts in South Dade County including portions of SWIM Plan activities, Everglades National Park. Q. And what were your responsibilities as supervisoring professional in environmental sciences? A. Supervising a number of technical and professional people involved in environmental research as well as conducting my own independent research. ** 8 Q. And what other job functions did you perform when you were in environmental sciences before you became supervising professional? A. As a research scientist conducting various studies. Q. What is your educational background? A. I have a bachelors from University of South Florida, some graduate course work from the University of South Florida, and additional course work in computer sciences at FAU. Q. Who are your immediate supervisors? A. Currently? Q. Yes. A. Pete Rhoads. Q. And what is his title? A. He is department director. Q. Are there employees of the Water Management District that work for you? A. Yes. Q. How many? A. Seventeen. Q. What is the nature of their job titles? A. Research scientist, technicians, one supervisory professional. Q. Who is the supervisory professional? ** 9 A. Steve Davis. Q. What computers are utilized in environmental sciences? A. Desk top IBM PCs primarily and Techtronics, and then, hardware involved in image processing, which is a VAX, Micro VAX. Q. What software is utilized on the PCs? A. Word processing, spreadsheet, some contouring packages, a variety of statistical packages, and I believe that's it. Q. And what specific contouring packages, if you know? A. Geez, I can't recall the name off the top of my head. Q. Who would know? A. Ken Rutchey. Q. What statistical packages are utilized? A. BMDP, SAS, Sokal and Rohlf, STAT Graphics, I think that's it. Q. What software packages are utilized on the Micro VAX? A. Image processing for the most part. It's the I squared S System 600 software. Q. While you were a supervising professional in environmental sciences, what independent ** 10 research did you do? MS. STOLLMAN: This will be limited to your research done on the computer systems. MS. NASH: Or utilizing the computers in this research. MS. STOLLMAN: To the extent that it involves the computers, you may answer the question. A. In terms of image processing, creating various kinds of vegetation maps. I'm not sure how the question should be answered in terms of all research. MS. STOLLMAN: Could you clarify that, please? MS. NASH: Well, he indicated that he did independent research while he was a supervising professional. I'm trying to find out the areas in which he did independent research. MS. STOLLMAN: Which involved or you used the computers. A. Well, that's everything. Q. (By Ms. Nash) Is that right? A. Studies of hydrology and nutrients within the Water Conservation Areas, Lake Okeechobee, the Loxahatchee River, C-111, and I believe that's it. ** 11 Q. The studies that you did on hydrology and nutrients in the Water Conservation Areas, when were those done? A. From about 1980 to '85, or '86. Q. And what data did you utilize to do those studies? A. Field data that was collected in conjunction with the study to draw down impacts in the Water Conservation Areas. Q. Does the data base that that data was from have a name? A. No, not specifically. It's a variety of information that was collected including water quality data, water elevation data, water depth data, vegetation data. Q. Who collected the data you utilized? A. Myself and others. Q. Others in the environmental sciences or other divisions? A. It could be environmental sciences, some from other divisions. Q. Were the results of that research on the Water Conservation Areas published? A. Yes. Q. Does the document in which it was ** 12 published have a name? A. It's technical publications by the South Florida Water Management District. Q. Do you know when it was published? A. 1983 and again in 1988, I believe. Q. Are the analyses that you did for that study on the computer? A. No. I'd say most of it is on disks, floppy disks. Q. Is there a name associated with those floppy disks? A. They're labeled accordingly, depending on what data is stored on the disk. Q. And where are those disks located? A. In environmental sciences. Q. Do you know who has responsibility for those disks now? A. Excuse me? Q. Who has responsibility for those disks now? A. I suppose I do. Q. Do you recall what the source of the nutrient data was you utilized in that study? A. The source is South Florida Water Management District. ** 13 Q. What locations was that data obtained from? A. Do you mean in terms of the actual locations in the environment where it was collected or the location within the building? Q. Well, first the location in the environment, the geographic location? A. Water Conservation Area 2A. Q. And from what data base was that data obtained? A. The water quality data base. Q. Does that data base have a specific name? A. Well, I believe it's called LIMS now. I'm not sure if that was still the same data base at the time of collection or not. Q. Has the environmental sciences division done any studies on nutrients since your study that you're aware of? MS. STOLLMAN: Again, this would be studies using the computer systems. A. Yes. Q. (By Ms. Nash) Who has done the studies. MS. STOLLMAN: You can answer if you know. I don't want you to speculate. A. Nancy Urban, Marguerite Cook. ** 14 Q. What was the specific subject matter of the study Nancy Urban did involving nutrients? A. Looking at water quality associated with cattails. Q. And when did she do this study? A. Well, it's an ongoing study. Q. What geographic locations are covered in the study? A. Water Conservation Area 2A. Q. Where are the files on the study located, the computer files? A. Nancy Urban would have to tell you that. Q. When was this study begun? A. I can't be sure of an exact date, probably two years ago. Q. What is the nature of the study that Marguerite Cook has been doing involving nutrients? A. Looking at soil nutrients within Water Conservation Area 2A. Q. Which one was that? A. 2A. Q. And is that study completed or still ongoing? A. No, it's ongoing. Q. And when did that study begin? ** 15 A. A year ago. Q. Do you know the source of the data being utilized for that study? A. It's being collected by those individuals. Q. Have any other studies been done by environmental sciences involving nutrients? A. Yes. Q. What other studies? MS. STOLLMAN: Again, that would be studies which involve the computer system. You can answer to the extent that the studies do involve those systems. A. Steve Davis is looking at nutrients in relation to saw grass and cattail. Q. (By Ms. Nash) In what geographic area? A. Water Conservation Area 2A. Q. And is Steve Davis' study ongoing or completed? A. I believe it's completed. Q. Was a report done on that study? A. Yes. Q. Was that report published? A. I don't believe so yet. Q. Are there plans to publish it? A. Yes. ** 16 Q. Is the data going into that report on one of the computers? A. You'll have to ask him that. I don't know. Q. Has the environmental sciences division done any wetland productivity studies? A. I guess I need some clarification on "productivity." Q. Any studies involving the changes in the wetlands? A. Changes, yes. Q. Who has done the studies? A. Well, all of the people that have been listed so far have conducted studies involving looking at changes in the wetlands. Q. In what geographic area? A. Water Conservation Area 2A. Q. Are any studies being undertaken by the environmental sciences division in other parts of the Water Conservation Areas? A. Currently, no. Q. Have any been done in the past? A. Yes. Q. What are the nature of the studies? A. Bird studies, vegetation studies, water ** 17 quality. Q. What vegetation studies have been done? A. Looking at changes in vegetation characteristics in area 3A in relation to structures. Q. And when was this study done? MS. STOLLMAN: You can answer if you know. A. I'm trying to recall the time frame. I can't be sure. Q. (By Ms. Nash) More than five years ago? A. Yes. Q. Do you recall who did the study? A. Mark Zaffke. Q. Have the results of that study been published? A. Yes. Q. Do you know the name of the publication? A. No, not off the top of my head. Something to do with vegetation in Water Conservation Area 3A. Q. Have any other vegetation studies been done? A. There may have been before I came to the district. ** 18 Q. You indicated that water quality studies have been done in other parts of the Water Conservation Areas. What water quality studies have been done? A. In Water Conservation Area 3, and in Water Conservation Area 1. Q. What was the nature of the study done in Water Conservation Area 1? A. It was a background study of water quality characteristics. Q. And when was that study done? A. I believe '79 to '83. Q. And who did this water quality study in Water Conservation Area 1? A. Dave Swift. Q. You mentioned a water quality study done in Water Conservation Area 3, what was the -- A. The same person. Q. And when was that done? A. Same time frame. Q. Were the results of these studies published? A. Yes. Q. Do you know the name of the publication? A. It's the district publication, technical ** 19 publication. Q. Has the environmental sciences division done any studies in the Everglades Agricultural Area? A. No. Q. Has the environmental sciences done any studies on the waters flowing out of the Everglades Agricultural Areas? A. Not directly. Q. Can you explain what you mean by, "not directly"? A. When the water enters the canal systems, the primary canal system, and we have water quality in the primary canal system as it enters the Water Conservation Areas. Q. Are these studies the studies you've already mentioned or are these -- A. Uh-huh. Q. Has the environmental sciences division done vegetation mapping? A. Yes. Q. What geographic locations? A. Water Conservation Area 2A, Water Conservation Area 3, and I believe that's it. Q. What is the source of the data for the ** 20 vegetation mapping that's been done? A. A combination of satellite imagery and aerial photography. Q. Which satellite imagery? A. Land sat and spot. Q. Do you know the dates on the satellite imagery that's been utilized? A. No, not off the top of my head. There's a variety of dates. Q. Is there a listing of the dates of the satellite imagery that environmental sciences uses? A. Yes. Q. Does that listing have a name? A. Not specifically. Q. Who would have that listing? A. Ken Rutchey. Q. Has the satellite imagery data been classified? MS. STOLLMAN: Are you talking about classification on the computer system? MS. NASH: Yes. A. Some, yes. Q. (By Ms. Nash) Do you know for which locations? ** 21 A. For Water Conservation Area 2A and 3. Q. What is the source of the aerial photos that you mentioned are used in the vegetative mapping? A. They're contracted by the district. Q. Do you know who the contractor was? A. I believe Abrams Aerial Surveys, Hughes Aerial Surveys. There may be some others, but I can't recall the names. Q. Do you know the dates on the aerial photographs? A. No, not specifically. Q. Who would know? A. No one probably. Q. Is there a listing of the dates of the aerial photos? A. Partially. It's one that's being compiled. Q. Who's compiling the list? A. I am. Q. Do you know what the scale is on the aerial photos? A. It's a variety of scales. Q. For what projects have the environmental sciences division done to utilize the aerial ** 22 photos? MS. STOLLMAN: Again, this would be projects involving the computer systems. A. Primarily efforts related to the vegetation mapping. Q. (By Ms. Nash) Where is the data for the vegetative mapping stored? A. I guess I need some clarification on what you mean by "data." Q. Or the vegetative mapping themselves, what computer do you store the information on? A. It's on tape for the most part. Q. Is there a name associated with the tape? A. Yeah, it's the name of the respective area in the vegetation map. Q. To what scale is the vegetation mapping being done? A. Roughly 1 to 50,000 scale. Q. Have the vegetation maps been verified? A. Not completely. Q. Do you know what geographic locations have been verified? A. Portions of Water Conservation Area 2A. Q. Any other areas? A. No. ** 23 Q. Is environmental sciences doing any water quality impact maps? A. No. Q. Do you know whether anyone in the Water Management District is doing any water quality impact maps? A. No, I don't know. Q. Is environmental sciences doing any nutrient distribution maps? A. No. Q. Do you know whether anyone in the Water Management District is? A. No. Q. Is environmental sciences doing any studies on the effects of water quality on vegetation? A. Some of those were already referred to earlier. Q. Any others that you haven't previously mentioned? A. I don't believe so. Q. Is environmental sciences using the satellite imagery to show vegetation changes? A. Yes. Q. What are the projects in which that's ** 24 being done? A. It's primarily Water Conservation Area 2A. Q. And who's doing that work? A. I am and Ken Rutchey. Q. What data in addition to the satellite imagery is being utilized to do that study? A. Aerial photography. Q. Does the environmental sciences division have an aerial photography flight line map? A. A portion of one. Q. And where is that map located? A. Environmental sciences. Q. What portion is covered in the map? A. Water Conservation Area 2A, Water Conservation Area 3. Q. Has environmental sciences done any modelling on vegetation changes? A. No. Q. Has environmental sciences done any modelling on nutrient changes? A. No. Q. Has environmental sciences done any modelling on water quality trend analysis? A. No. ** 25 Q. Do entities outside of the Water Management District have access to any of the data or files in environmental sciences? MS. STOLLMAN: That would be access to data or files which are on the computers. A. No. Q. (By Ms. Nash) Is environmental sciences doing any GIS work? A. Yes. Q. What is the nature of the GIS work being done? A. We are building data bases. Q. Have any projects been done utilizing GIS? A. None that have been completed. Q. Are there ongoing projects? A. Yes. Q. Involving what locations? A. Water Conservation Area 2A. Q. And who is doing the projects? A. Myself, Ken Rutchey. Q. Is environmental sciences doing any work using the CADD system? A. Yes. Q. What work is that? A. A variety of uses related to production of ** 26 maps. Q. What are these maps utilized for? A. Visual display, base maps. Q. Do these maps have titles? A. Yes. Q. What would those titles be? A. There's a variety of them. I wouldn't know what all of them are. Q. Is there an index to the maps? A. No. They're generated by individual users. Q. Do any of the maps cover Everglades National Park? A. No. Q. Do any of the maps cover the Loxahatchee National Wildlife Refuge? A. No. Q. Do any of the maps cover the Water Conservation Areas? A. Yes. Q. Which Water Conservation Areas? A. Area 2 and Area 3. Q. Do any of the maps cover the Everglades Agricultural Area? A. No. Q. Have any of the maps been published? ** 27 A. Probably, yes. Q. Do you know on what documents? A. A variety of documents. Q. Can you recall any specific ones? A. A drawn down study, the water quality studies, and I'm sure there are others in other divisions. Q. The environmental sciences division's files would be stored on which computer? A. We don't have a central location. Q. The GIS work that you mentioned was ongoing, is that done on ARC/INFO? A. Not currently. Q. Is it done on I squared S? A. Yes. Q. Does the work being done have names or titles? A. Yes, I'd have to look at the computer to tell, though. Q. What's the file you'd look at to find the name? A. I'd have to look at the directory of what information has been stored on the disk. Q. Is the disk labeled in some identifiable way? ** 28 A. Disk 1. Q. And that would be located in the environmental sciences division? A. Yes. Q. You mentioned doing GIS work in Water Conservation Area 2A, is this the same project that you were mentioning earlier that's been going on in Water Conservation Area 2A, or is this GIS work a different project? A. The GIS is attempting to compile some of the existing information that's already been collected. Q. What is the nature of the information being compiled? A. Vegetation cover, soils, locations of gauges, pump stations. Q. Any nutrient data? A. Not yet. Q. Any topographical data? A. Not really. Not yet. Q. Has the environmental sciences division done any studies for the Everglades SWIM Plan? A. Not specifically for that. Q. Have any data or analysis been provided for use in the SWIM Plan? ** 29 A. Yes. Q. What is the nature of the data or those analyses? A. Water quality data and vegetation data. Q. Where is the water quality data stored that was provided for the SWIM plan? A. You'd have to ask the individuals involved in the SWIM Plan. Q. It's not stored in environmental sciences? A. We give them bits and pieces of information they might need, and what they do with it after that is up to them. Q. What was the source of the data within environmental sciences that you gave to them on water quality? A. Previously published information. Q. And what was the source of the vegetation data that you provided? A. It was also previously published information. Q. Has environmental sciences done any work for the C-111 GDM? A. Yes. Q. What's the nature of that work? ** 30 A. Water quality, vegetation, estuary. Q. And who's been doing that work? A. Some of it was done under contract to other outside agencies. Some of it was done internally by the staff. Q. Which outside agencies? A. Everglades National Park, USGS. Q. Any other outside entities? A. I don't think so. Q. And who within environmental sciences worked on the C-111 GDM project? A. Peter David, he's the only one still in the division that may have worked on it. Q. Is there anyone else who's still employed by the Water Management District, although, in a different division? A. Dave Swift. Q. Anyone else? A. No. THE WITNESS: I guess I want to take a break at this point. MS. NASH: Sure. (Short break.) ** 31 Q. (By Ms. Nash) Mr. Worth, are there any manuals that assist you in utilizing I squared S? A. Yes. Q. Do those manuals have a name? A. They're user guides for the I square S system 600 software. Q. Are there any in-house guidelines or procedures for utilizing the I squared S? A. No, not really. Q. Do you know whether the data from I squared S can be converted or translated into the formats to be used on other GIS systems? A. Yes, it can. Q. Do you know the procedure for doing that? A. Yes. Q. Can you explain that? A. Well, it's basically just outputting the information in a Raster format that's readable by another system that's capable of reading Raster data. Q. And I squared S is capable of putting the data out in a Raster format? A. Yes. MS. NASH: No further questions. ** 32 CROSS-EXAMINATION QUESTION BY MR. RICHARDS: Q. Mr. Worth, my name is Joe Richards. I represent the cities of Belle Glade and Clewiston. When did you begin work at the Water Management District? A. June 16, 1980. Q. And you mentioned you had a bachelor's degree in what area of study? A. Zoology, and a minor in chemistry. Q. Besides the work you already mentioned on the GIS system, are you presently doing any other research? A. No. I am a bureaucrat. Q. In the work you did in conservation area 2A in the early eighties, did you use remote imagery for that work? A. Some. Q. What imagery did you use? A. Aerial photography. Q. Do you know the dates of that photography? A. It was based on 1979 Mark Hurd's, some 1983 photography that we did ourselves, and the 1984 Mark Hurd's. ** 33 Q. And did you use this aerial photography to map vegetation in conservation area 2A? A. Yes. Q. Was any ground truthing efforts performed in relation to that vegetation map? A. Yes. Q. When in relation to the dates of the images was the ground truthing efforts performed? A. During the time we were requiring the 1983 photography and shortly after the 1984 Mark Hurd's were supplied to the district. Q. How long after the images were taken, the '84 images, was the ground truthing performed? A. It was probably two or three months. Q. And when you say -- for the 1983 images, when you say "during" the photographing, would you consider that coincident ground truthing? A. In some cases, it was. Q. Do you know in what areas the ground truthing was coincident? A. It was water concentration area 2A. Q. Any particular portions of 2A? A. A variety of the locations, mostly study sites. Q. Do you know what study sites? ** 34 A. I do, but they won't mean anything to you. Q. Could you tell us which study sites? A. A variety of tree islands, sloughs, saw grass. Q. Were these along transects or any other locations that are identified in the publications? A. Yes. Q. Could you indicate which areas in specific? A. I guess I'm not sure I understand your question. Q. You said the areas are identified in the publications. I was wondering if you could tell us what areas? A. They're in Water Conservation Area 2A. Q. Specifically what areas? A. Within saw grass, sloughs. Q. Do you have station -- A. Tree islands. Q. Do you have station names or numbers? A. 1, 2, 3, 4, 5, 6, 7, 8, 9. Q. Along a particular transect? A. Those may be transect numerical locations. Q. Was any ground truthing done for the 1979 images? ** 35 A. No. Q. Do you know what color aerial photography this was? A. Which? Q. 1979. A. Color infrared. Q. And the 1983 imagery? A. Color infrared. Q. And the 1984? A. Color infrared. Q. You indicated that the analysis performed for this Water Conservation Area work you did in the Eighties was contained on floppy disk? A. Yes. Q. Do you have the names of those disks? A. They're identified as to the kinds of information contained on the disk, such as, water quality data, vegetation data, and they're usually named in abbreviations, such as, WCA-2, WQ-1. Q. Are they dated? A. No. Q. Are the sampling sites that are listed in the publications indicated in the names of the disks? A. They're probably contained within the files ** 36 stored on the disk. Q. Do you know whether Mr. Zaffke is still with the district? A. He is not. Q. Do you know where he is now? A. No, I don't. Q. In regard to the land sat satellite imagery, do you know what program is used to analyze this imagery? A. It's the I square S software. Q. Is there an alga rhythm used to analyze the imagery? A. Yes. Q. Do you know what that is? A. Well, there is a variety of alga rhythms involved. Do we go through this now or -- MS. STOLLMAN: Well, to the extent that it involved something on the computer system, a computer procedure, you may answer the question to the extent that it's necessary to identify the different files that you will be asked about. A. Well, it's just not that straightforward. MS. STOLLMAN: Could you clarify your question, please? MR. RICHARDS: Well, I'd like him to ** 37 list the alga rhythms, if he could, that are being used. MS. STOLLMAN: For what? A. Well -- MS. STOLLMAN: Well, let him finish the question. Q. (By Mr. Richards) Do you understand the question? MS. STOLLMAN: I would like to get the question clarified. We can have it read back or you can rephrase it. MR. RICHARDS: I would just like him to indicate the alga rhythms used in the computer analysis of the imagery. MS. STOLLMAN: Which imagery? MR. RICHARDS: Land sat satellite imagery. A. I will assume you mean in general terms. There's a geometric correction that is done. There is a radiometric correct that is done, and then, there is a variety of classifications that might be done. Q. (By Ms. Nash) What would be those classifications? A. On supervised and unsupervised ** 38 classifications. Q. Do you know the names of the alga rhythm used for the geometric work you mentioned -- correction? A. It's a standard map projection. Q. Do you know what it's called? A. It's basically a conversion of the data to a USGS Transverse Mercator Projection. Q. Do you know the name? A. That's it. Q. That's it? A. That's it. Q. How about for the radiometric correction? MS. STOLLMAN: I would objection to these detailed questions on the alga rhythms. I don't believe they're necessary to identify the nature of the files that you're interested in looking on the computer system. MR. RICHARDS: It's computer information that we have already been discussing. If we could just finish this up. MS. STOLLMAN: You may answer the question if you know. I don't want you to guess at the name. If you can't recall the name, I don't want you to answer. ** 39 A. I don't know. Q. (By Mr. Richards) Do you know who would know? A. Maybe Brent Moll. Q. Are any variables considered in the analysis of the land sat imagery? A. What do you mean by "variables"? MS. STOLLMAN: I would object to that question. I don't think the variables analyzed in land sat imagery is relevant here. MR. RICHARDS: This is all computer work. I am just trying to find out what's being done with the imagery. Q. (By Mr. Richards) By "variables," I mean fire, water, density of vegetation. MS. STOLLMAN: Do you understand the question? A. They're taken into consideration. Q. (By Mr. Richards) Similarity of vegetation? A. Yes. Q. And for the spot satellite imagery, what program is used to analyze that? A. They're virtually identical to the ones used for the land sat. ** 40 Q. In reference to the vegetation map you discussed, is comparison being made with historical images? MS. STOLLMAN: This would be a comparison done on the computer system. A. Yes. Q. (By Mr. Richards) What historical images are being used for this comparison? A. The earlier data of land sat. Q. Do you know the date of this earlier land sat information? A. 1979. Q. When was this imagery obtained by the district? A. I can't recall a specific date. Q. Was it obtained in 1979? A. No. Q. In the last two years? A. In the last two years. Q. Are any other images being used for comparison purposes? A. On the computer systems, no. Q. You stated that this vegetation map was in the process of being verified, when do you expect this process to be completed? ** 41 A. Right now, I couldn't tell you. Q. Is there a projected date for when the vegetation map for WCA 2A will be completed? A. There was an original projection. Q. When was that? A. End of September of this year. Q. That's not going to be met? A. No. Q. Do you have any idea when it will be? MS. STOLLMAN: This has been asked and answered. Q. (By Mr. Richards) Does the district have plans to acquire any more land sat or spot satellite imagery? A. Yes. Q. When is that likely to take place? MS. STOLLMAN: You can answer if you know. A. Scheduled within the next fiscal year. Q. (By Mr. Richards) You mentioned that portions of the vegetation map for 2A have been verified, do you know what particular portions of the area have been verified? MS. STOLLMAN: I believe this has been asked and answered. ** 42 MR. RICHARDS: I don't believe it has. MS. STOLLMAN: You may answer the question. A. Areas around various tree islands and downstream of the S10 structures. Q. (By Mr. Richards) You mentioned that you're doing GIS work on an I squared S format, is that being converted to ARC/INFO? A. Not yet. Q. Do you have plans to convert it? A. Eventually, yes. Q. Do you know when that conversion is likely to take place? A. It's contingent upon purchase of equipment. Q. Do you know what GIS coverages currently exist within the environmental sciences division? MS. STOLLMAN: Do you need clarification of that question? THE WITNESS: Yes. Q. (By Mr. Richards) Do you know what a GIS coverage is? A. Do I know what a GIS coverage is? Q. Yes. ** 43 A. If you're talking in terms of data layers, yes. Q. Could you explain which of those currently exist in the environmental sciences division? A. Some layers concerning vegetation coverage. Q. Anything else? A. Some layers concerning structural locations, additional layers concerning gauges. Q. And what layers do you plan to add? A. Eventually hydrology, soils, fire histories. Q. Any others? MS. STOLLMAN: I don't want you to speculate about areas. THE WITNESS: Yeah, okay. Q. (By Mr. Richards) You mentioned that in your GIS work you're attempting to compile existing information on vegetative cover, what is the source of this info that's being put into the GIS system on vegetative cover? A. It's land sat or spot data. Q. Any other data? A. Some photographic data. Q. Is any of this data being obtained from ** 44 other departments or divisions outside of environmental sciences? A. No. Q. You mentioned that there was some CADD system work on conservation areas 2 and 3, do you know the nature of this work? A. There are just a variety of map drawings, structural locations, major features, roadways, canals, levies. Q. Anything else? A. Some vegetation. Q. Are you aware of any water quality data that is not stored in the district's Chemical Analysis System, the Britton-Lee computer. MS. STOLLMAN: Could you break that question down, please? A. Yeah, it's speculative on my part. MS. STOLLMAN: Well, I don't want you to answer. I don't want you to speculate. Q. (By Mr. Richards) Do you know of any water level data collected by the environmental sciences division that is not stored in the DB Hydro data base? A. Would you say that again? Q. Are you aware of any water level data that ** 45 was collected by environmental sciences division that is not stored in the DB Hydro data base? A. Yes. Q. What is that data? A. A variety of individuals have collected data specifically at various study sites, which might not be in DB Hydro. Q. Does that include study sites within the Water Conservation Areas? A. Yes. Q. Do you know what data is stored on the environmental sciences division's Micro VAX computer? A. Yes. Q. What is that data? A. It's primarily the image processing data. Q. Any other data? A. No. Q. Are you aware of any data lost from the I squared S system? A. Data lost? Q. Yes. A. I don't understand your question. Q. Were any data files lost from that system accidentally? ** 46 A. Yes. Q. What data files? A. Some of the operating software. Q. What operating software? A. The VAX VMS operating software. Q. Were you able to recover that? A. Yes. Q. Anything else? A. No, I don't believe so. Q. Does the environmental sciences division have a written policy on quality assurance and quality control for the use of data in computers? A. No. Q. Is there any written policy on the input of scientific data into computers? A. Could you be more specific? Q. Are there written guidelines for the input of data into computers? A. Yes. Q. Is there a manual or something? Where are those guidelines written? A. They're probably in reference to the LIMS or the water quality division. Q. None specific to the environmental sciences division? ** 47 A. No. Q. Is the environmental sciences division responsible for the input of any data directly on to the computers? A. Only for our own usage. Q. Do you know what version of the land sat photography the district has? A. It's land sat 5. MR. RICHARDS: That's all I have. Thank you. (The deposition was concluded at 3:20 o'clock p.m.)