1 1 Division of Administrative Hearings 2 Department of Administration, State of Florida 3 SUGAR CANE GROWERS COOPERATIVE) OF FLORIDA; ROTH FARMS, INC.; ) 4 and WEDGEWORTH FARMS, INC., ) Petitioners, ) 5 V ) DOAH SOUTH FLORIDA WATER MANAGEMENT) Case 92-3038 6 DISTRICT, an agency of the ) State of Florida, et al., ) 7 _____________Respondents._____) ) VOLUME I 8 FLORIDA SUGAR CANE LEAGUE, ) INC.; UNITED STATES SUGAR ) 9 CORPORATION; and NEW HOPE ) SOUTH, INC., ) 10 Petitioners, ) V ) DOAH 11 SOUTH FLORIDA WATER MANAGEMENT) Case 92-3039 DISTRICT, an agency of the ) 12 State of Florida, et al., ) _____________Respondents._____) 13 ) FLORIDA FRUIT AND VEGETABLE ) 14 ASSOCIATION; LEWIS POPE FARMS;) W.E. SCHLECHTER & SONS, INC., ) 15 and HUNDLEY FARMS, INC., ) Petitioners, ) 16 V ) DOAH SOUTH FLORIDA WATER MANAGEMENT) Case 92-3040 17 DISTRICT, an agency of the ) State of Florida, et al., ) 18 _____________Respondents._____) 19 Deposition of Kenneth Rutchey 20 Taken before Robin L. Merker, Court 21 Reporter and Notary Public in and for the State of Florida at large, pursuant to notice of taking 22 deposition filed by the Petitioners in the above cause. 23 - - - Monday, February 7, 1992 24 319 Clematis Street West Palm Beach, Florida 33401 25 9:10 - 12:15 p.m. 2 1 APPEARANCES: 2 On behalf of the Petitioners Florida Sugar Cane League, Inc., United States Sugar Corp, 3 and New Hope, Inc.: 4 Earl, Blank, Kavanaugh & Stotts One Biscayne Tower 5 Suite 3636 Two South Biscayne Boulevard 6 Miami, Florida 33131 By: MARK KOBELINSKI, ESQUIRE 7 On behalf of the Petitioners Sugar Cane Growers 8 Cooperative, Roth Farms, Inc., and WEDGEWORTH Farms, Inc.: 9 Hopping, Boyd, Green & Sams 10 123 South Calhoun Street Tallahassee, Florida 32314 11 BY: WILLIAM H. GREEN, ESQUIRE and CAROLYN S. RAEPPLE 12 On behalf of the Respondent SFWMD: 13 Popham, Haik, Schnobrich & Kaufman, Ltd. 14 100 Southeast 2nd Street Miami, Florida 33131 15 BY: GREGORY M. CESARANO, ESQUIRE 16 On behalf of the Intervenor, United States of America: 17 THOMAS A.W. FITZGERALD, ESQUIRE 18 Assistant United States Attorney 155 South Miami Avenue 19 Suite 600 Miami, Florida 33130-1693 20 ALSO PRESENT: 21 JOE B. BIRCH, Ph.D. 22 EDWARD DOWNING MICHAEL SOUKUP 23 MICHAEL STORY 24 25 3 1 - - - 2 I N D E X 3 - - - 4 WITNESS: DIRECT CROSS REDIRECT RECROSS 5 Kenneth Rutchey 6 BY MR. KOBELINSKI: 5 BY MS. RAEPPLE: 226 7 - - - 8 E X H I B I T S 9 - - - 10 Rutchey Exb. No. 1 8 Development of an Everglades Vegetation Map 11 Using a SPOT Image and the Global Positioning System 12 Rutchey Exb. No. 2 33 WCA-2A Field Data Collection Sites for 30 13 classes 10-2-91 to 1-13-92 14 Rutchey Exb. No. 3 56 WCA-2A Tree Islands 15 Rutchey Exb. No. 4 67 16 WCA-2A Accuracy Assessment 3-23 to 4-24-92. 17 Rutchey Exb. No. 5 80 Laboratory Notebook 18 Rutchey Exb. No. 6 105 19 WCA 3S for SPOT 5-11-92 20 Rutchey Exb. No. 7 105 WCA 3N for SPOT 5-11-92 21 Rutchey Exb. No. 8 108 22 Inland Wetland Change Detection in the Everglades Water Conservation Area 2A Using a Time 23 Series of Normalized Remotely Sensed Data 24 Rutchey Exb. No. 9 196 Holeyland file, Bates Nos. 1220441 through 25 1220572 4 1 Rutchey Exb. No. 10 228 2 Color Map of WCA-2A, using SPOT image 4-4-87 3 Rutchey Exb. No. 11 273 Satellite imagery as of 1-25-93 4 Rutchey Exb. No. 12 278 5 Resume of Ken Rutchey 6 Rutchey Exb. No. 13 298 Memorandum dated 11-5-92 from Ken Rutchey 7 Rutchey Exb. No. 14 316 8 Memorandum dated 3-30-1990 from Michael Maceina 9 Rutchey Exb. No. 15 354 Latitudes and longitudes, coordinates 10 Rutchey Exb. No. 16 355 11 Review of Remote Sensing activities by John Jensen. 12 Rutchey Exb. No. 17 357 13 Phosphorus data 14 Rutchey Exb. No. 18 364 Memorandum from Ken Rutchey and Les Vilchek 15 dated 10-22-92 16 Rutchey Exb. No. 19 370 Memorandum from Ken Rutchey dated 7-29-91 17 Rutchey Exb. No. 20 370 18 Memorandum from Ken Rutchey dated 6-18-90 19 Rutchey Exb. No. 21 373 Memorandum from Ken Rutchey dated 10-30-89. 20 Rutchey Exb. No. 22 382 21 WCA-2A fire records 22 Rutchey Exb. No. 23 384 Draft page of Everglades SWIM Plan with 23 handwritten note on back. 24 25 5 1 P R O C E E D I N G S 2 3 - - - 4 Thereupon, 5 Kenneth Rutchey 6 being by the undersigned Notary Public first duly 7 sworn, was examined and testified as follows: 8 THE WITNESS: I do. 9 DIRECT (Kenneth Rutchey) 10 BY MR. KOBELINSKI: 11 Q. Good morning, Mr. Rutchey. My name is 12 Mark Kobelinski. Have you been deposed before? 13 A. Yes. 14 Q. You have, all right. Good. I think I 15 knew that. 16 And I think you're aware that a deposition 17 is a means by which people involved in litigation can 18 ask questions of individuals who may or may not have 19 facts dealing with the issues in the case under oath. 20 I'll be asking you a number of questions. I believe 21 one or another of the attorneys here will be asking you 22 some questions. I'd like you to answer to the best of 23 your ability as truthfully as possible. If you don't 24 understand a question, please let me know and I'll 25 attempt to rephrase it in a manner in which you can 6 1 understand. If you don't know the answer to a question 2 or don't remember, I don't know or I don't remember are 3 the best responses you can give. 4 If you do assume something, please let us 5 know. Otherwise we're going to go on our own 6 assumption that you are not assuming. If you feel 7 compelled to assume, please tell us. 8 Under those ground rules, you were served, 9 sir, I believe with a subpoena duces tecum? 10 A. Right. 11 Q. All right. 12 You were given a notice and, as I 13 understand it, you've gathered documents in response to 14 that? 15 A. Yes. 16 Q. You produced those all to us? 17 A. No. 18 Q. All right. 19 A. This morning I brought in, after reading 20 it further, a report. You might have this, you might 21 not. I don't think that was -- the C-51 study, you 22 said all publications that I've been involved in. 23 Q. Okay. 24 A. And this is another one that was by Dewey 25 Worth in the early '80's, work that he did in 7 1 documenting the vegetation, and I have basically all 2 the data for that report since Dewey has now left the 3 District. 4 Q. Great, all right. 5 Well, we'll get some copies of that later. 6 A. And the other item I was asked to provide 7 was the digital data also. 8 Q. Um-hum. 9 A. The techs and I haven't put that all 10 together yet. 11 Q. All right. 12 A. I'm working on that. 13 Q. Now I note that you have a document there 14 in front of you, titled Development of an Everglades 15 Vegetation Map Using a SPOT Image and the Global 16 Positioning System. Is that the final or most recent 17 copy of that particular paper? 18 A. Yes. 19 Q. All right. 20 And I know you did produce that; is that 21 correct? 22 A. Yes. 23 Q. All right. 24 Well, why don't you give me few moments to 25 go through it. We weren't quite sure which was the 8 1 final version. 2 (Thereupon, a discussion was held off the 3 record.) 4 MR. KOBELINSKI: All right. We all set? 5 Why don't you mark that as 1? 6 (Thereupon, the document was marked 7 Rutchey Exb. No. 1 for Identification.) 8 BY MR. KOBELINSKI: 9 Q. Mr. Rutchey, I've handed you what we've 10 marked as Petitioner's Exhibit 1 to your deposition, 11 which is a document entitled Development of an 12 Everglades Vegetation Map Using a SPOT Image and the 13 Global Positioning System, dated September of 1992, 14 Bates No. 1220147 through 1220440. Would you look 15 through that and identify that for me, please, if you 16 can? 17 A. This is the work that Les Vilchek and I 18 did, looking at vegetation in the Everglades and using 19 multispectral satellite data to delineate the 20 vegetation. 21 Q. Okay. 22 And what portion of Everglades was that? 23 A. Water Conservation Area 2A. 24 Q. Okay. 25 When was this work done? When did you 9 1 start on this project? 2 A. I'd say initially right after the data was 3 acquired on 8-10-91. 4 Q. Okay. 5 And when did you finish this project? 6 A. I'd say approximately eight months after 7 the actual -- all the data was collected and then maybe 8 another four months the final report was done. 9 Q. So that was just about September '92 is 10 when you finished up with this? 11 A. Yeah, I'd say that was the last, you know, 12 the revised. You know, you get comments back and... 13 Q. What we've marked Exhibit 1 is the final 14 product from that study, or are there any additional or 15 subsequent drafts? 16 A. There was drafts prior to this, yes. 17 Q. Were there any drafts subsequent to, after 18 this? 19 A. No. 20 Q. Okay. 21 Who is Les Vilchek? 22 A. He's a co-worker, same level as I am, 23 working for South Florida Water Management. 24 Q. What does he do? 25 A. He's -- he does pretty much what I do. He 10 1 has a strong background in aerial photography 2 delineation, dealing with aerial photography. He 3 worked with the National Wetland Inventory before he 4 came to the District and basically learned the image 5 processing from me, the digital image processing and we 6 used his background in aerial interpretation pretty 7 extensively in this project. 8 Q. Thank you. 9 Prior to August of '91, did you have any 10 experience in using satellite imagery, showing 11 vegetation through satellite imagery? 12 A. Yes. 13 Q. Could you just briefly take me through 14 when you first started doing that actually through 15 today, what your experience has been? 16 A. Okay. 17 I'd say I started, I would say it was in 18 '87 when I first became interested in this method. I 19 basically had done a lot of research in the Everglades 20 prior to that using standard ground reconnaissance, you 21 know, going out in the field as a biologist and looking 22 at vegetation, put a transect out. Basically that's -- 23 the results of that are in contained in this report 24 that Dewey Worth did. But we saw there was so much 25 more out there that we weren't covering, so we wanted 11 1 to move on to maybe looking at the area in its 2 entirety. And then initially we started just taking 3 photographs from helicopters, putting poles out in the 4 fields so we can basically tell distances, so that when 5 we delineate the vegetation we can come up with an 6 acreage of what things were that we were delineating 7 were or so -- were on the ground. 8 And so we then basically moved to 9 satellite data and Dewey, you have to give Dewey the 10 credit. He's the one that really headed us in that 11 direction. I just sort of, I guess, tagged along. But 12 it piqued my interest and I became very interested in 13 it. In fact, it became my niche at the District. And 14 at that time we had the I2S system, which is an image 15 processing system and I learned it and I did some 16 initial work. And basically at this point I was 17 getting a real education at the District learning the 18 software and different techniques and... 19 Q. Put an approximate period of time around 20 this. 21 A. I'd say '87 to '89. 22 Q. Okay. 23 A. I did a preliminary map of Water 24 Conservation Area 2A using a 1987 SPOT scene. And then 25 I started working on this -- this project, completed 12 1 this work. At this point I'm moving more now towards 2 using satellite imagery and aerial photography. I 3 consider all remotely sensed data or image processing 4 of data. That's it pretty well. 5 Q. Okay. 6 A. Sums it up. 7 Q. You say a 1987 SPOT vegetative map, was 8 that -- what area was that? 9 A. Water Conservation Area 2A. 10 Q. With regard to the photo surveys using 11 helicopters for use in vegetative mapping, what period 12 of time was that? 13 A. (No response.) 14 Q. I believe you said you used, did some 15 photo surveys using helicopters where you put posts in 16 or poles in to mark -- 17 A. That was before any actual digital image 18 processing. That was real early like, I'd say, in the 19 '81 through '85. 20 Q. Okay. 21 Do you recall what areas you did using 22 that method? 23 A. Basically it was sawgrass areas, tree 24 islands and slough areas. 25 Q. Okay. 13 1 Was that in any of the Conservation Areas? 2 A. Water Conservation Area 2A. 3 Q. Did you cover the entire Conservation 4 Area? 5 A. No. 6 Q. Do you still have the results of those 7 surveillances or not? 8 A. Some of it. 9 Q. Did you publish a report or put out any 10 type of report based on that? 11 A. Basically all that work is probably in 12 here. 13 Q. Okay. 14 A. We collected a lot of data and we put this 15 report together. We didn't use all the data. We used, 16 you know, we collected a lot of data, so it was... 17 Q. Okay. 18 Going then towards this report which we 19 marked as Exhibit 1, if you could walk me through the 20 process. 21 And I believe, just for the record, the 22 copy that has been marked as Exhibit 1, I do not 23 believe has color photos on the back of it. I know 24 that you have another copy of that here -- is that a 25 fact, Mr. Rutchey -- 14 1 A. Correct. 2 Q. -- of this report which does have color 3 photos? 4 A. (Shakes head up and down.) 5 Q. Feel free if, during the deposition you 6 need to refer to color photos as opposed to those black 7 and white photocopies to do so. We will then attach a 8 corrected one with the color photos to the deposition 9 itself. 10 If you could literally, from the point 11 where you became involved, walk me through the steps it 12 took to get to this final report, and if I need a 13 little more detail I'll ask you. Otherwise -- 14 A. Okay. 15 Q. When did you -- I assume the first part of 16 that was selecting a -- well, you tell me. Step Number 17 1, when did you get the assignment? 18 A. Well, we got the imagery that was 19 collected on August 10, 1991 from SPOT data 20 multispectral imagery. 21 Initially the first thing we do is went 22 out and got ground truth information to rectify the 23 imagery. 24 Q. Before you get to that point, how was the 25 August SPOT imagery selected? 15 1 A. Basically the overriding consideration was 2 availability. In the Everglades we don't have a lot of 3 clear days where we have a satellite where it's totally 4 cloud free. 5 Q. Um-hum. 6 A. So that was why that one was selected. 7 Q. Okay. 8 Who actually made the selection of the 9 August 10, '91 SPOT imagery? 10 A. I did. 11 Q. Okay. 12 And was this -- was SPOT imagery the only 13 satellite imagery that you considered at this point? 14 A. No, no. We looked at LandSat too. Again 15 the overriding consideration though was a scene that 16 was totally cloud free for that area. 17 Q. Okay. 18 A. And there was some other work done using 19 LandSat in the Everglades, and they compared it to 20 SPOT, and they showed that SPOT was the better way of 21 looking at the vegetation and delineating. 22 Q. Okay. 23 Who had done this LandSat work and 24 compared it to SPOT? 25 A. Terry Gilbert of Game and Fish. 16 1 Q. Did you consult with Gilbert with regard 2 to selecting the SPOT imagery? 3 A. Yes. 4 Q. Had you worked with the LandSat before? 5 A. Yes. 6 Q. And did you concur with Mr. Gilbert's 7 opinion that SPOT would be a better imagery to use as 8 opposed to LandSat? 9 A. Yes. 10 Q. Okay. 11 What was the specific purpose or goal at 12 this point in time of the assignment? What were you 13 attempting to do? 14 A. Use satellite imagery to delineate the 15 vegetation in Water Conservation Area 2A. 16 Q. Any particular vegetation types or 17 literally all the vegetation you could? 18 A. All the vegetation we possibly could. 19 There was no emphasis on any specific species. 20 Q. Okay. 21 And did you select 2A as the area of study 22 or was that just, again, part of the assignment? 23 A. Selected it. Because that's where I had 24 worked since my beginning of employment with South 25 Florida Water Management District, and that area also 17 1 has had the most work done in it in previous. 2 Q. Okay. 3 Was the assignment literally just to map 4 any area within the Water Conservation Areas, open area 5 selection? How was the assignment developed? 6 A. Basically just we mapped Water 7 Conservation Area 2A. 8 Q. I'm just curious whether or not the 9 assignment was we need to start doing a vegetative 10 mapping, and you said fine, I'd like to do 2A because 11 that's what I'm most familiar with. How was that 12 assignment developed? 13 A. I would say that the direction at that 14 point came from Dewey Worth to start off doing Water 15 Conservation Area 2A. 16 Q. Okay. All right. 17 Did you review various SPOT imagery for 2A 18 and then select August 10 from a number of options or 19 was August 10 essentially the one that was proposed to 20 you? 21 A. Again, there wasn't a whole lot available 22 due to cloud cover. And it's -- I didn't want to go 23 back to a scene that was collected earlier because then 24 it makes it hard to ground truth. So I had to wait for 25 a scene to become available and then start working on 18 1 it. 2 Q. Okay. All right. 3 In what format did you receive the August 4 10 SPOT imagery data? 5 A. In digital format. 6 Q. Did you still have those digital files? 7 A. Yes. 8 Q. Unaltered, unmodified? 9 A. Yes. 10 Q. Okay. 11 Once you received the digital files for 12 the '80 -- excuse me -- 8-10-91 SPOT imagery, what did 13 you do next? 14 A. I went out, collected ground truth data 15 for rectification of the imagery. We collected 20 16 ground control points. That was the first thing we 17 did. Then we cut the actual area out that we were 18 interested in, which was Water Conservation Area 2A, 19 out of the imagery. 20 Q. Okay. 21 So let me -- first, after getting the 22 data, I assume you load it on to a computer, then went 23 up to selected 20 sites to ground truth -- 24 A. To ground truth for rectification 25 purposes. 19 1 Q. And what does ground truthing for 2 rectification purposes mean? 3 A. When you get the data it's not to any real 4 world map projection. So we wanted to get it into a 5 real world map projection using real world ground truth 6 information. 7 Q. Now in other words, when you get it, it 8 doesn't have the boundary of 2A drawn on it; is that 9 right? Is that -- 10 A. No. The way you get a boundary is to cut 11 the imagery from the satellite, original satellite 12 data. This rectification is so that when you look at 13 an area and -- you know where the location is at. 14 Q. Okay. 15 A. You don't know that when you first get it. 16 You have to establish ground controls and rectify it. 17 Q. So what are the types of sites you use for 18 that purpose? 19 A. Some of the fish camps within the area and 20 then points all the way around the outside perimeter. 21 Q. That including the structures? 22 A. I believe so. 23 Q. And did you do the 20 sites, inspection of 24 the 20 sites for ground truthing? 25 A. Les Vilchek and myself. 20 1 Q. Approximately how long did that take? 2 A. I would say a day to two days to collect 3 the information. 4 Q. Okay. 5 What's the next step? 6 A. Okay. 7 Initially we took the raw data and did an 8 unsupervised classification and we chose 30 clusters. 9 We did the unsupervised classification within the 30 10 clusters. We tried to find areas that we can visit in 11 the field. And this was all based on the accuracy of 12 the GPS. So basically the imagery was initially 13 rectified to .4 RMS, root means square, it means that 14 pixel within it is accurate to approximately eight 15 meters. 16 Q. With regard to this process, how many 17 classes did you -- did the computer or did you collect? 18 A. 30 clusters. 19 Q. 30 clusters, all right. 20 Let me ask you this, perhaps as we go 21 through, for the sake of -- we received a fair number 22 of documents, a lot of which are, as you know, lists of 23 data. With regard to Step 1, which was selecting the 24 August 10, 91 imagery, did you produce any documents 25 specifically related to that fact? 21 1 I'm just trying to organize the documents 2 that you produced. 3 A. Could you repeat that question? 4 Q. You've produced to us about a foot and a 5 half of documents in the last few days. 6 A. Okay. 7 Q. We're trying to order them to understand 8 exactly what they are and identify them. Perhaps it 9 might be easiest to see which of those documents fit in 10 a particular project you were doing and in what steps. 11 I'm asking you, did you produce any documents with 12 regard to your selection of the August 10, 91 SPOT 13 imagery? 14 A. Yes. 15 Q. Okay. 16 What documents would have you produced in 17 regard to that? 18 A. If I remember, all -- I think you have all 19 the GPS location points that were used in the 20 rectification process, in the ground truthing and in 21 the your analysis of the mapping project. 22 Q. Okay. 23 I understand we probably have all the 24 documents. Our problem is trying to figure out which 25 documents are for what task. Are there specific 22 1 documents with relation to your selection of the August 2 10, '91 SPOT imagery? 3 A. I don't think so. 4 Q. With regard to your selecting 20 sites for 5 ground truthing and for rectification purposes, were 6 there any documents specifically related to that task 7 that you've produced to us? 8 A. I believe so. 9 Q. What would those look like? 10 A. Well, I identify them based on the folder 11 that I have them in. 12 Q. Well, we received those things clipped or 13 rubber banded together. There's the first batch, 14 perhaps if you went through that and can identify the 15 20 sites or the documents related to the 20 sites for 16 ground truthing. 17 While you're doing that, let me ask a 18 quick question. Are you aware that we received your 19 documents in two batches? 20 A. No. 21 Q. Okay. 22 So that wouldn't help, telling you I 23 received it in Batch 1 or Batch 2. 24 (Thereupon, a discussion was held off the 25 record.) 23 1 BY MR. KOBELINSKI: 2 Q. It's not there. Okay. This is another 3 set of documents we received. 4 A. I don't see them. 5 Q. Okay. At the break we can take a closer 6 look at that. 7 Moving on to the next step that you 8 described to me as taking the raw data and looking at 9 the computer, doing an unsupervised classification, 10 would there be any specific documents generated from 11 that? Would the computer generate a particular file 12 or -- 13 A. I believe all it's all digital. I don't 14 think there's any hard copy of that. 15 Q. Okay. 16 Now, do I understand correctly that the 17 computer collected more than 30 classifications, but 18 ultimately narrowed it down to 30? 19 A. No. 20 Q. How does that work? 21 A. I chose 30. 22 Q. Oh, you essentially told the computer I 23 want 30 classifications, go through and find them? 24 A. I want 30 clusters to be my final number 25 of classes. 24 1 Q. Okay. Well, you have to excuse me, I'm -- 2 the difficulty is you have someone who is not expert in 3 your field deposing an expert in your field. 4 When it's an unsupervised classification 5 by the computer, does that mean the computer just goes 6 through and selects what it considers to be vegetation 7 of the same class or cluster? 8 A. Basically it looks at the band information 9 of the satellite data and clusters it out based on 10 means, basically it's a standard deviation, into 30 11 separate clusters. 12 Q. But you're the one that first plugs in to 13 the computer and tells it I want 30 to start with? 14 A. Right. 15 Q. So you could have done 40 and it would 16 have given you 40? 17 A. That's correct. 18 Q. Or you could have given it one and it 19 could have -- would have given you the entire map I 20 guess; is that essentially correct? 21 A. Yes, I think that's probably what would 22 happen. 23 Q. Did you write any memos or anything 24 related to that particular document? 25 A. Not to my knowledge. 25 1 Q. Okay. 2 After you received then the computer 3 classification of 30 clusters -- would that be the 4 appropriate term? 5 A. Yes. 6 Q. Okay. 30 clusters. 7 -- what was the next step you did? 8 A. Okay. 9 Basically, we tried to go out in the field 10 and identify what those clusters were. 11 Q. Okay. 12 How did you go about doing that? 13 A. We used GPS, Global Positioning System, 14 and tried to pick a minimum of five points in each one 15 of these clusters, geographically locate it throughout 16 the area. And that's what we used for trying to 17 determine those 30 clusters. 18 Q. Okay. 19 Just so I understand how you went about 20 determining the 30 clusters, did you print out a map? 21 Was there a map printed out of it showing the 30 22 clusters, where they were? 23 A. That's correct. 24 Q. All right. 25 Do you still have a copy of that map? 26 1 A. It's digital. 2 Q. All right. 3 Did you allow the computer to select the 4 sites where you would go out and ground truth or 5 determine what clusters represented or did you do it 6 yourself? 7 A. Did it myself. 8 Q. Okay. 9 Do you have any type of map or -- showing 10 where those sites were that you visited for the 11 determination of classes? 12 A. Yes. I -- there might be a hard copy, I 13 can't remember. But there's definitely a digital copy. 14 Q. Okay. 15 And in the digital copy, would it have the 16 coordinates of where you were going? 17 A. That's correct. 18 Q. Okay. 19 How did you go about selecting sites you'd 20 visit? 21 A. It was based on whether we were able to 22 accurately navigate to them use GPS technology. There 23 was some inaccuracy in the actual GPS and some 24 inaccuracy in the rectification process of the 25 satellite imagery. So basically we determined that we 27 1 had to have a minimum of 3 by 3 pixel cluster in order 2 to accurately navigate to. In most cases we prefer to 3 have bigger than that. 4 Q. Now with a 3 by 3, you're talking about, 5 what is that, 60 meters squared? 6 A. 60 meters on side. 60 by 60 by 60 by 60. 7 Q. All right. 8 And how many sites did you go to identify 9 the clusters? 10 A. 129. 11 Q. All right. 12 And that was yourself who picked the 129 13 sites? 14 A. I would say I picked them along with Les 15 Vilchek. 16 Q. Okay. All right. 17 What was the next step then, visiting the 18 sites? 19 A. We visited the sites and we wrote down 20 what we saw there and came back and wanted to see if 21 the cluster was accurate and it -- it had broken it out 22 into 30 clusters, whether they were all unique. And at 23 this point we determined they weren't unique, that 24 there was real heterogeneity with a number of clusters. 25 Q. Now prior to the visitation to the site, 28 1 how did you get to the site? 2 A. Either by air boat or helicopter. 3 Q. Okay. 4 And you did that using GPS, I believe you 5 mentioned? 6 A. That's correct. 7 Q. Okay. 8 Once you got to the site, I believe you 9 stated you identified the vegetation? 10 A. That's correct. 11 Q. What would you do, check a site in the 12 center of the pixel, in the center of the 9 square or 9 13 pixels? 14 A. Approximately. 15 Q. Then how would you go about identifying 16 what was there? 17 Who would do that? Let's start with that. 18 A. We stuck with one person so that we 19 wouldn't -- it's just better if you do it with one 20 person than have a number of people working on that 21 aspect of it, because he stays consistent throughout 22 the process. 23 Q. Okay. 24 A. And Les Vilchek was that person. 25 Q. Okay. All right. 29 1 Once you arrived at a site, where would he 2 look to make the identification? 3 A. If we were in a helicopter he would look 4 down at the site, because you want to try to determine 5 what the satellite was seeing. If you were on an air 6 boat, we have cages on the air boat, we got on top of 7 the cage and looked basically down so we can see was it 8 sparse or moderate or dense or what the prevailing 9 vegetation signature was for that area. 10 Q. Okay. 11 With regard to the helicopter, were you 12 hovering, trying to hover at any particular level or... 13 A. Yeah, I'd say it was approximately 50 14 feet. 15 Q. Okay. 16 A. 25 feet. 17 Q. All right. 18 You now -- as I understand it, you are in 19 the approximate, what you've identified as being in the 20 approximate center of a 9 pixel square, each pixel 21 being 20 meters by 20 meters. Was Les attempting to 22 identify the community in all 9 pixels or was he trying 23 to look at what he considered to be the boundary of 24 that center pixel? 25 A. I would say he was looking at a 20 meter 30 1 by 20 meter area. 2 Q. Was that something you discussed with him 3 so you know that or is that just your -- 4 A. No, we discussed that. 5 Q. Okay. 6 Now at -- during this trip would you also 7 observe and take any notes if, for instance, if there's 8 a change in the type of vegetation surrounding -- from 9 what you've identified as the center pixel? 10 A. I believe he did that, yes. 11 Q. Now were there written documents? Were 12 there written observations from this trip? 13 A. I believe there is, yeah. I think he -- 14 they might be included here somewhere. 15 Q. But he made field notes of every, all 129 16 visits? 17 A. I believe so, yeah. 18 Q. Okay. 19 Was he keeping the field notes or were 20 you? 21 A. He kept them pretty much. 22 Q. Okay. 23 Did you make any separate observations or 24 field notes of any sort? 25 A. No. I was basically the GPS man. I 31 1 also -- I put it in in navigating to points and making 2 sure we got to the right place. 3 Q. Okay. 4 Now, is it your belief that the field 5 notes from these site visits were included in the 6 documents that were produced to us? 7 A. I think so, but I'm not positive. 8 Q. Okay. 9 Can we go through and again identify those 10 so we can start segmenting out what these documents 11 are? If it's easier, as I said, take all the rubber 12 bands off. 13 (Thereupon, a discussion was held off the 14 record.) 15 THE WITNESS: This is in digital form. I 16 don't see the -- 17 BY MR. KOBELINSKI: 18 Q. Let's set that aside for the moment. 19 Everything that's -- everything you have that relates 20 to the -- is it just that one document you have in your 21 hand or is there anything underneath that also? 22 A. Well, this actually gives you the 23 coordinate and what we saw there. I'll keep looking 24 through. 25 Q. Well, I'd like to see if we do have field 32 1 notes. Let's -- why don't we set that aside. I'll 2 identify that for the record in a moment. But if 3 there's anything else related to that visit to the 129 4 sites in the field and the identification of 5 vegetation. 6 A. I think this pertains to that too. I 7 think these are it. We actually made sheets up, field 8 inspection sheets. I think this is it. 9 Q. All right. Let me try find these here. 10 MR. CESERANO: You want the number? 11 MR. KOBELINSKI: Yes. 12 MR. CESARANO: 1202944. 13 THE WITNESS: No, this, I think, was for 14 ground truthing. 15 BY MR. KOBELINSKI: 16 Q. Why don't we put -- this is yours, and I 17 think you turned some stuff over here. I just want to 18 make sure. 19 MR. CESARANO: Pardon me, let me look at 20 this for a moment if I could. 21 MR. KOBELINSKI: All right. What does 22 that start with? 23 MR. CESARANO: 1203. 24 MR. KOBELINSKI: All right. And I think 25 we'll just mark this as a large composite 33 1 exhibit. 2 (Thereupon, the document was marked 3 Rutchey Exb. No. 2 for Identification.) 4 BY MR. KOBELINSKI: 5 Q. Mr. Rutchey, did you -- were there any 6 photos taken during the three site visits, the 129 7 sites? 8 A. I think we did do it for this one, I'm not 9 sure. 10 Q. Who would have those photos? 11 A. I'd have to look in my slides for that, 12 because we have gone there on and off on different 13 things. 14 Q. Would they be in just slide form or would 15 you also have photos, do you know? 16 A. They'd be slides. 17 Q. Okay. 18 Who would have taken the -- snapped the 19 photo or slide or whatever, done the camera work? 20 A. Yeah, I -- if I recall, I don't think we 21 did it for this particular project, we didn't take 22 pictures. I'm not sure. 23 Q. Okay. 24 A. I'd have to look. 25 Q. All right. 34 1 Mr. Rutchey, I'm showing you a composite 2 exhibit that we've marked as No. 2. There's actually a 3 number of different portions to it, but the first page 4 appears to be a photocopy of a possibly a file folder 5 which reads WCA-2A field data collection sites for 30 6 classes, 10-2-91 through 1-13-92. And all these 7 documents bear consecutive Bates numbers in the lower 8 right-hand corner, 1202881 all the way through 1203072. 9 Some of these are stapled together. 10 I'd ask you first of all, is this a -- one 11 entire file that you keep, this particular file? 12 A. It's not an entire file, it's a number of 13 different files. 14 Q. Perhaps -- because it was produced to us 15 in this consecutive order, I'd like you to go through 16 and perhaps see if you can identify each set, the first 17 portion of which is stapled together at 1202882. Do 18 you know what that particular document relates to? 19 A. This is the actual data that I sent to 20 John Jensen of the 30 ground truth sites and their 21 coordinate location. 22 Q. And it's actually referring to 129 sites? 23 A. Yes. 24 Q. Okay. 25 Now -- so this does relate to this initial 35 1 site identification of the 129 sites and the classes 2 that are listed there in this document. Where did you 3 get that information? 4 A. These are the classes that we determined 5 from looking during our aerial reconnaissance is the 6 site locations. 7 Q. Okay. 8 Just going through this top page here, 9 1202882, the first column there are a number of 10 numbers. What would that indicate? 11 A. Just basically it was a way of telling the 12 different ones apart, 1 through 129. 13 Q. So that's just essentially the numbers 14 that, for instance that first page we're on, 61, 63, 15 80, these are just the various sites; is that correct? 16 A. Um-hum. 17 Q. All right. 18 The next one is labeled class, I believe 19 you just stated that classification, you identified it 20 based upon your observations; is that correct? 21 A. Yes. 22 Q. I'm still on Page 1202882. 23 A. Yes. 24 Q. The next has UTM. 25 A. That's correct. 36 1 Q. What is that UTM, coordinate? 2 A. Universal Transverse Mercator 3 Q. That's your GPS coordinates there? 4 A. Yes. 5 Q. All right. 6 Next document that, at least it's stapled 7 together, bears Bates No. 2202885 through 887. And 8 could you -- do you know what this document reflects? 9 A. I'm going to tell you these don't look 10 like they're in order to me. And not to have my 11 folders here, my original stuff, I'm guessing basically 12 what I'm seeing here. 13 Q. All right. 14 Well, to the best of your ability do you 15 do you recognize what this could be? 16 A. It's basically -- it's classes grouped 17 together and their location, such as Class 1 is -- you 18 see all together and Class 2 and so on, and so on to 19 30. 20 Q. This is based upon the original 129 sites? 21 A. I believe so. 22 Q. Okay. 23 And the first column there says point old, 24 what does that mean? 25 A. I'm going to have to go back. We had two 37 1 sites, point old and -- well, not point old. And we 2 had new and old -- not new. It was basically two 3 different trips. We combined them together in the 4 final documents or data set. 5 Q. When you say two different trips, is this 6 all part of identification of the 129 sites where the 7 vegetation was? 8 A. Yes. Two different trips that basically 9 it might have been more than two trips, but at one 10 point in time we had one data set and then we had 11 another data set, then we combined them, the old data 12 set, old and new date set. 13 Q. Good classifications. All right. 14 Well, let me back up a moment. How long 15 did it take you to visit all 129 sites? 16 A. I think we did it over a period of two or 17 three months. 18 Q. Okay. 19 And what months would those be? 20 A. I think it says right here on the 21 beginning of Exhibit 2, 10-2-91 to 1 -- it look likes 22 13-92. 23 Q. Okay. 24 And did you go to all these sites? 25 A. Yes. 38 1 Q. I believe you said Les Vilchek did all the 2 identification. He also obviously went too. 3 A. Right. 4 Q. Did anybody else participate in the site 5 identification trips? 6 A. No. 7 Q. Approximately how many trips did it take? 8 A. Without having my folders, I don't recall. 9 Q. Okay. 10 And did you visit certain sites more than 11 once? 12 A. I don't think so. 13 Q. Okay. 14 I was just trying to understand why there 15 were two different data sets that you then merged. 16 A. I'm going to have to go back and look. I 17 remember that we collected one set and then we 18 collected another set, not repeating, two different 19 sets. We called one old and one new, and then we 20 combined it. That's the best of my knowledge, without 21 going back to my notes. 22 Q. All right. 23 Are those notes that you've produced to 24 us? 25 A. No, they're in -- it's basically in my -- 39 1 yeah, they're probably here. But it's all -- not like 2 in my folders. 3 Q. Okay. 4 So you had field notes then from this 5 aspect of the study? 6 A. Well, those were already part of that. 7 Q. We're coming up on those. 8 A. Right. 9 Q. Okay. 10 Let's move on to the next document which 11 is Bates No. 120288 through 120291. And this likewise 12 has point new. My question would be that in the 13 approximately fourth column there, a number of data 14 points have 5 by 5 or 5 X 5. What does that refer to? 15 A. I believe that was if it had 5 by 5 pixels 16 or more, instead of a 3 by 3 pixel. 17 Q. Okay. All right. 18 Moving on then to next stapled portion of 19 this, which bears Bates No. 1202892 through 1202898, 20 and what would this relate to? 21 A. These are all out of the software called 22 PFINDER, and it's our software that we use to 23 differentially correct our field GPS data. This is the 24 output. 25 Q. Okay. 40 1 This is output from the unit you had out 2 in the field? 3 A. I'm not sure without having my folders in 4 front of me. I mean it's either output from the unit 5 in the field or it's the output after it's been 6 differentially corrected. 7 Q. All right. Let me just explore that for a 8 moment. 9 You have a GPS unit and it takes you to a 10 spot; is that correct? 11 A. That's correct. 12 Q. All right. 13 What are you -- how do you get to a spot 14 with a GPS unit? 15 A. You can enter way points into the GPS 16 unit, basically navigation points. You can navigate to 17 the point. The military's been jamming GPS signals 18 since the Gulf incident, so about the worse accuracy is 19 about a hundred meters. But there's -- we've found 20 that you can take that data set back to your office, 21 you have a community base station set up collecting GPS 22 data out of a known location that's been surveyed to 23 less than one centimeter. You can differentially 24 correct the recovery unit data to get an accurate 25 location of where you really were. 41 1 Q. Okay. 2 The unit itself, the recovery unit as you 3 called it, records then time and place, it was -- 4 A. It records the time and the position. 5 Q. Okay. 6 Is that where you just press a button and 7 it does that for you, or how does it do it? 8 A. Pretty much press a button. 9 Q. So every time you got a spot that Les 10 would do a site identification you would press a 11 button, it would record the time and coordinates? 12 A. Right. We took a number of coordinates at 13 each place that we stopped, because that gives you 14 better accuracy the more you can average the data. And 15 basically we went to known benchmarks during our field 16 trips that we found, identified and checked the unit to 17 see how accurate we really were getting. And accuracy 18 ranged from three to seven meters. 19 Q. Okay. 20 That was during all your visits to the 129 21 sites? 22 A. Yes. 23 Q. Okay. 24 (Thereupon, a discussion was held off the 25 record.) 42 1 BY MR. KOBELINSKI: 2 Q. The next document is Bates No. 1202899 3 through 1202904. 4 Can you identify what that document is? 5 A. Again, this is output from the PFINDER 6 software for GPS, PFINDER software. 7 It looks like we can take, for instance, 8 the first page, Site No. 61, these are all the points 9 that were collected at that site. And then this is 10 like until -- before we actually average it and get 11 then a final number. 12 Q. Okay. 13 Are these -- looking at 61, you have 14 approximately 10 readings there. I didn't count it, is 15 that about right? 16 A. Yeah. 17 Q. 1, 2, 3, 4, 5. Yeah I think it's about 18 10. Is that all from the same holding spot or did you 19 actually move around to get those? 20 A. No, same spot. 21 Q. Okay. All right. 22 And then going to the next document 23 1202905 through 909, what would this be? 24 A. Again, this is output from the GPS PFINDER 25 software. 43 1 Q. Okay. 2 Just drawing your attention to the 3 leftmost column where it says text, and following 4 through, is that an identification of some sort? 5 A. In this case, not on that page, it 6 represents the site number. 7 Q. And the following pages? 8 A. Bug in the program. We were able to 9 overcome that bug by looking at the time in the second 10 column to determine where we were. 11 Q. All right. 12 In next document, 1202910 through 913, 13 what is that? 14 A. GPS PFINDER output. 15 Q. Okay. 16 Would that hold true likewise for the next 17 document, 1202914 through 2920? 18 A. That's correct. 19 Q. Okay. 20 And next documents 1202921 through 927? 21 A. Yes. 22 Q. Okay. 23 And then drawing your attention to the 24 next four documents bearing Bates numbers 1202928 25 through 936, what are these documents? 44 1 A. PFINDER GPS data output. 2 Q. Okay. 3 And looking at 1202937 there's handwriting 4 on there, it says this starts quote the new data set 5 quote. Now does that indicate that the new data set 6 essentially starts on December 3, '91 and went only 7 after that period? Is that how you'd read this? 8 A. Yeah, I'd say that's a fair statement. 9 Q. Does this help you recall as to why there 10 were two data sets? 11 A. No. 12 Q. On this sheet, this 1202937, there's 13 handwriting on here in a couple of places, it says 14 miss. What does that refer to? 15 A. I don't recall. 16 Q. Okay. 17 Whose handwriting is that; do you 18 recognize it? 19 A. It looks like mine. 20 Q. Drawing your attention to 1202939, the 21 document goes through 940, the leftmost column in 22 handwriting, what are these, the handwriting identified 23 as 96, 104, 54 as I'm going through? 24 A. I think this means -- dealing with the 25 accuracy of GPS being a hundred meters, that when we 45 1 actually went to a site that we thought was that 2 cluster, so the unit was off a hundred meters, it threw 3 us outside the cluster when we went back and checked 4 it. So we missed a cluster. So we couldn't use the 5 ground truth statement, because we weren't at that 6 location. That's what miss means, we missed. 7 Q. Okay. All right. Fair enough. 8 Well, just look at 1202939, just so I 9 understand your first eight readings, are those all the 10 same site or are those different sites? 11 A. I would say they're different sites. 12 Q. Each of these represents a different site? 13 A. Um-hum. 14 Q. All right. 15 And then quickly finishing up the 16 following two documents, 1202941 through 943, these are 17 likewise GPS documents; is that right? 18 A. Yes. 19 Q. Okay. 20 What would do you when you missed a site, 21 would you go back on a different day? 22 A. We would try to attempt to go back to it. 23 Q. Did you ultimately locate all 129 sites to 24 your satisfaction? 25 A. Initially there were more sites, there 46 1 were -- we just never could get to them. They -- some 2 of the clusters broke out to just 3 by 3 pixels, and if 3 they were jamming for a hundred meters we never found 4 that site. We couldn't include it. 5 Q. Of the 129 original sites that you set out 6 to do, how many did you ultimately get to? 7 A. No, there was more than 129. Initially 8 there was 150. 9 Q. Oh, I see. 10 And do I understand correctly then that 11 you were able to get to a hundred -- get to 129 of the 12 150? 13 A. Right. 14 Q. Okay. All right. 15 Then looking at Bates Nos. 1202944 through 16 1203016, the first page of which has -- states SFWMD 17 Environmental Sciences Digital Mapping Field Inspection 18 Sheet, what are these documents, sir? 19 A. These are the ground truth data, what we 20 saw there at the site depicting the vegetation. 21 Q. Okay. 22 And who kept these, who prepared these 23 documents? 24 A. Les Vilchek. 25 Q. And he prepared these out in the field? 47 1 A. No. 2 Q. Okay. 3 How would he record what he was seeing out 4 in the field? 5 A. On a piece of notebook paper or whatever, 6 then he came back in, he transcribed them to here. 7 Q. Okay. 8 Does he still retain his field book or his 9 field notes themselves? 10 A. I'm not sure. I sort of doubt it. 11 Those things, especially in your air boat, 12 they get all smudged up and get wet, so that's why we 13 did this. 14 Q. Now under a vegetation type, for instance 15 on the first page you have 1, 2, 3, 4, 5, 6, 7, 8, 9, 16 10, 11 categories, how are the 11 categories selected? 17 A. Those are some of the major things that we 18 thought were out there initially, so to make it easier 19 so we don't have write them down every time we went to 20 a site, we made a list. 21 Q. Okay. All right. 22 And I notice -- I draw your attention to 23 documents in the next rubber band set, which is 1203017 24 through 1273072. What are these documents? 25 A. The same. Ground truth information. 48 1 Q. All right. 2 And that is all -- this ground truthing 3 relates to the original visitation of the approximate 4 129 sites; is that correct? 5 A. I believe so. 6 Q. All right. 7 Are there any other documents then that 8 would relate to this portion or this task in the 9 project? 10 A. Just the digital data. 11 Q. Okay. 12 Once you received these field notes or the 13 field inspection sheets, what would do you with them? 14 A. Basically we went to each of the clusters 15 to see if they had clustered out uniquely, and we found 16 that wasn't the case, that a lot of them exhibited 17 heterogeneity within a single cluster within -- based 18 on our field reconnaissance. 19 Q. Okay. 20 Who did that work? 21 A. I did that work. 22 Q. What was the type of recovery unit you 23 used for the GPS? 24 A. A PathFinder Basic. 25 Q. All right. 49 1 You've done all the field work, you have 2 all these field notes, you come back, what's the next 3 step in the process? 4 A. Well, once we determined that everything 5 just didn't cluster out the way we had hoped, we used 6 that data set to do a supervised classification. 7 Q. All right. 8 How did you go about doing that? 9 A. It's basically the computer does -- they 10 do -- you feed it the ground truth information and run 11 a supervised classification and you look at the 12 results, see if they mean anything, see if you have 13 unique spectral signatures for the final data. And we 14 determined that, yeah, we came up with initially 19 15 unique signatures based on that kind of ground truth 16 information. And we used those, initially we saw some 17 problem areas and we attacked those and came up with 18 one additional class. 19 Q. What was the additional class? 20 A. Periphyton. 21 Q. All right. 22 Now with supervised classification, a 23 little more detail there. Did you select 19 classes 24 based upon your review of field notes and make a 25 determination there were actually 19 identifiable 50 1 classifications out there, or did the computer then 2 select 19? 3 A. No, it's based on supervised, based on 4 ground truth data. 5 Q. Okay. 6 So you took the data from your visits to 7 the 129 sites? 8 A. Um-hum. 9 Q. You yourself came up with 19 classes from 10 that? 11 A. Right. 12 Q. Okay. 13 Then you tell -- identify them to the 14 computer, the computer reruns the digital data to see 15 where it finds those classes? 16 A. Based on the spectral signature of those 17 data sites, basically the band information within those 18 areas. It's used in the supervised classification to 19 delineate based on these statistics. 20 Q. Okay. 21 Is this something you were doing or Les 22 was doing? 23 A. I was doing. 24 Q. All right. 25 Are there any documents related to that 51 1 particular activity? 2 A. Hard copy, no. Digitally, yes. 3 Q. What would have you digitally related to 4 this? 5 A. Well, we have all the seed locations for 6 the ground truth information. And basically all the 7 steps from there to the final supervised 8 classification, the output maps. 9 Q. Okay. 10 You didn't make hard copies of the maps 11 though, is that you're saying? 12 A. No. Well, I did make hard copies of -- 13 not hard copies, no, no, I didn't. Just digital. 14 Q. Okay. 15 What was the next step? 16 A. Well the two problem areas, as I said, was 17 one was sawgrass/cattail sparse class, we knew from 18 aerial photography that we had a lot of, what we were 19 seeing in the southern end was periphyton that was 20 coming up as sawgrass/cattail sparse, so we wanted to 21 see if we can break that out. So we actually took that 22 class out of the supervised classification and ran an 23 unsupervised classification on that and broke it out 24 into, I believe it was five new spectral classes. We 25 look at each individually, looked at each of those 52 1 class individually and determined that we could break 2 out the periphyton from the sawgrass/cattail sparse 3 class. And then we came up with one additional class, 4 periphyton in the southern region. 5 Q. Okay. 6 I believe you said you knew from aerial 7 photography that the sawgrass/cattail part showing up 8 in the southern end was actually periphyton. 9 A. Um-hum. 10 Q. That aerial photography you were reviewing 11 as part of this particular project? 12 A. Yes. 13 Q. Okay. 14 What aerial photography were you using? 15 A. We had an area flown approximately at the 16 same time by Southern Resource Mapping at 1:24,000 17 scale, color infrared. 18 Q. That was by who? 19 A. Southern Resource Mapping. 20 Q. Now you're talking about the area, you're 21 talking about all of WCA-2A? 22 A. That's correct. 23 Q. Do you recall approximately when they did 24 that? 25 A. I think it was -- I'd be guessing. 53 1 Q. Well -- 2 A. It was within a year of this, the actual 3 data that we acquired, this satellite imagery. 4 Q. Within a year of August 10, '91? 5 A. Right. 6 Q. Okay. 7 Now did you retain the infrared 8 photography from that? 9 A. Yes. 10 Q. Okay. 11 A. Yes. 12 Q. Who is doing the vegetative identification 13 using infrared photography? 14 A. Both Les Vilchek and myself. 15 Q. Did you produce any of those infrared 16 photos? 17 A. No. 18 Q. Okay. 19 Do you still retain those? 20 A. Um-hum, yes. 21 Q. With regard to the southern area which the 22 computer was identifying as sawgrass/cattail sparse, 23 and that you had determined from aerial photography was 24 periphyton, were there any of the 129 sites located 25 within that area? 54 1 A. I don't recall. The sites were pretty 2 well distributed through out the whole area, I would 3 guess yes. 4 (Thereupon, Mr. Downing entered the room.) 5 MR. KOBELINSKI: Okay. Let's take a five 6 minute break as long as Ed just came in. 7 (Thereupon, a brief recess was taken.) 8 BY MR. KOBELINSKI: 9 Q. Let's see the step No. 6 that we were 10 discussing, or at least I had written down, is 11 supervised classification, which was done after you had 12 visited 129 sites for the unsupervised. And were there 13 any documents generated for this particular step of the 14 project? 15 A. Just what's available digitally, to the 16 best of my knowledge. 17 Q. Is that -- did you have hard copies that 18 you produced to us? 19 A. I don't believe so. 20 Q. Okay. 21 So the documents that you produced to us, 22 there are none related to this step? 23 A. The supervised? 24 Q. Yes. 25 A. Just the, you know, the ground truth 55 1 information and locations and what we saw there. 2 Q. Yeah, that's fine. We've already gone 3 through that? 4 A. Right. 5 Q. Okay. I appreciate that. I'm trying to 6 make some sense of what we have so we can sort of 7 follow along with what you did out there. 8 Now, you ended up with 19 and then you 9 added a 20th class of periphyton; is that correct? 10 A. That's correct. 11 Q. What was the next step? 12 A. There was another problem area, tree 13 islands. 14 Q. Um-hum. 15 A. They were being classified to something 16 other than tree islands. And basically we went and 17 digitized the tree islands on the supervised 18 classification, ran another unsupervised classification 19 just on tree islands, ten spectral classes, and then 20 collapsed that down into four already existing classes, 21 and mosaicked them back into the output of the 22 supervised classification 23 Q. Now, is there any documentation related to 24 that step? 25 A. That's probably -- I did see something, 56 1 ground truthing of the tree islands, the visits that we 2 made to those, stated tree islands. 3 Q. Why don't we quickly identify that? 4 (Thereupon, a discussion was held off the 5 record.) 6 BY MR. KOBELINSKI: 7 Q. It might be the bottom thing in that 8 entire stack. Take a look at the -- I have it as the 9 very bottom. Is that -- yeah, look at that one. I 10 don't know if that's it, but... 11 A. Yes, I believe this is it. 12 MR. KOBELINSKI: Why don't you mark that 13 as 3. 14 (Thereupon, the document was marked 15 Rutchey Exb. No. 3 for Identification.) 16 BY MR. RUTCHEY: 17 Q. All right. 18 Mr. Rutchey, drawing your attention to 19 what's been marked as Exhibit 3, and which record is a 20 document, bears Bates Nos. 1203073 through 1203105, and 21 the first page of which appears to be a cover, a file 22 cover, bearing the name WCA-2A tree islands and bears a 23 date of 2-20-92. 24 By the way, would February of 1992 be 25 about the time that you were doing this 57 1 reclassification of tree islands? 2 A. Yeah, this is the ground truthing of these 3 tree islands. 4 Q. Now, did this result in separate ground 5 truthing? In other words, did you go back out in the 6 field? 7 A. Yes. 8 Q. The third time you've gone out in the 9 field if I've counted correctly? Well, the third task. 10 First one was for, you referred to it as rectification, 11 that was your first field visit; is that right? 12 A. Field visits. 13 Q. Field visits, plural. 14 The second one was visits to the 129 15 sites, and this would be third set of visits you took 16 to the field? 17 A. That's correct. 18 Q. All right. 19 And there was -- Les Vilchek did this? 20 A. Both of us. Again, I'm the GPS and he's 21 the -- 22 Q. All right. How many -- 23 A. -- vegetation. 24 Q. How many sites did you visit? 25 A. I could count them, how many sheets are 58 1 here. Probably that's how many sites. 2 Q. All right. 3 A. It looks like 31. 4 Q. Okay. 5 Let me draw your attention back to 6 something -- or before I do that, looking at what is 7 the Bates page of this document, 1203074, what would 8 this be? 9 A. That's the location of the tree islands' 10 approximately center points. 11 Q. Okay. 12 Did you follow the same GPS technique of 13 taking a number of readings and then correcting it for 14 any distortion caused by the GPS system? 15 A. No, the tree islands are all fairly large 16 that we did digitized. And once you're navigating to 17 them, to your navigation points, you can see the trees, 18 so it wasn't necessary. 19 Q. Then drawing your attention then to the 20 field inspection sheets, which commences at 123075, in 21 the upper right-hand corner it says photo number R1-1. 22 Does that indicate that those photos were taken during 23 these visits? 24 A. I would say yes. Well, that's a good 25 point. 59 1 Q. I know, that's what I just noticed myself. 2 Going back then to Exhibit 2, I believe 3 start of the field sheets, it's at 1202944 -- 4 A. Right. 5 Q. -- these likewise have photo numbers in 6 them. Does that refresh your recollection as to 7 whether or not photos were taken? 8 A. Obviously, yes, they were. 9 Q. All right. 10 Do you know whether or not those photos 11 are still retained? 12 A. I haven't looked at them if they are. I 13 haven't looked at them. I don't even recall them. But 14 if they are, I might have them. 15 Q. Okay. 16 Were they used for any purpose in 17 refreshing your recollection when making 18 identifications? 19 A. I don't think so. I think we used our 20 visual view of the area as we saw it in real time with 21 our eyes. 22 Q. Okay. 23 Did you actually help Les with these or, 24 again, was he -- these are all just his notes as to 25 what he identified at the tree islands? I'm referring 60 1 back to Composite Exhibit 3. 2 A. He took the notes, but we would sit there 3 and he would tell me what he thought he saw there. And 4 we would, you know, between the both of us, I would 5 say, we came up with it. But he was the primary 6 person. But he would say this is what I see. I would 7 say well, you know, maybe sawgrass was 60 percent, he'd 8 say 70 percent. But we were pretty close. But we 9 still kept it to one person's view. I just wanted to 10 make sure he wasn't totally out of line. It's good to 11 have a second opinion there when you -- he's doing 12 that. 13 Q. Now with regard to the tree islands, did 14 you attempt to identify one entire tree island or were 15 you likewise attempting to identify a 20 by 20 pixel or 16 area? 17 A. Basically we were looking at the entire 18 tree island. 19 Q. Okay. 20 So of the 31 sites, are these essentially 21 then 31 different tree islands? 22 A. Yes. 23 Q. Okay. 24 Any notation as to the approximate area 25 that was covered by the tree islands? 61 1 A. Repeat that again. 2 Q. Would you be able -- is there any notation 3 on these sheets which would tell me how large the tree 4 island was? 5 A. No. 6 Q. Okay. All right. 7 Based upon these field trips, what did you 8 then do, how did you use this information? 9 A. We used this ground truth information, as 10 I said before, we cut out the tree islands from the 11 supervised classifications, 31 of them, and did 12 unsupervised classifications on them and made ten 13 clusters. Then we determined from this ground truth 14 information what those 10 clusters represented. And 15 some of them were duplication, so we collapsed it down 16 to four, which were already four classes we had within 17 the original 19 classes of supervised classification, 18 and then collapsed it -- well, collapsed to those four, 19 and then mosaicked it back into the supervised 20 classification. 21 Q. All right. 22 Just so I understand what you were doing 23 before, let me see if I understand what you're doing 24 here. A tree island in this case could actually be 25 comprised of approximately how many in this case, a 62 1 pixel being a 20 by 20 meter square? 2 A. Hundreds, if not thousands. 3 Q. Okay. 4 When you went out there to a particular 5 tree island, were you attempting to identify all of the 6 various pixel types that were out there or were you 7 doing a general vegetation type for the entire tree 8 island? 9 A. Basically, no, we were trying to look at 10 from the point of -- I have to look here. 11 Q. You want to use your original, it has the 12 nice color photo? 13 A. Yeah. 14 Basically we were looking at tree islands 15 from the point of a sawgrass/brush mixture 1, which is 16 what we categorize it as, sawgrass/brush mixture 2, and 17 these are all delineated within a table by -- what we 18 mean by these categorizations, tree island and other 19 keys. It might have been just been sawgrass, in some 20 cases cattail. 21 Q. Okay. All right. 22 What was the next step? 23 A. Okay. 24 Well, then we started mapping our accuracy 25 assessment of the overall map product. 63 1 Q. Once you did the tree islands, did you 2 then have what you believed to be a final or a pretty 3 much a final vegetation map? 4 A. That's correct. 5 Q. Okay. 6 And is there -- is that the same one 7 that's attached to Exhibit 1? 8 A. That's correct. 9 Q. Okay. 10 And that would be Bates -- would that be 11 Bates No. 1220435? 12 A. That's correct. 13 Q. Okay. All right. 14 Go ahead, what was the next step then? 15 A. Map accuracy assessment. We generated 241 16 random points from the final supervised classification. 17 We used a stratified random sampling technique based on 18 class. And the number of points selected was based on 19 the required minimum of 204 for an 85 percent map 20 accuracy with an error of plus or minus five percent. 21 And this was based on the binomial formulas. 22 Q. Now 241, would that -- were you 23 essentially trying to get X number of samples for each 24 of the particular 20 classs? 25 A. Well, the stratified random sampling by 64 1 class implies that you're going to take samples within 2 each of the classes. 3 Q. Is that -- does it by necessity result in 4 a minimum number taken within each particular class? 5 A. No. 6 Q. Okay. 7 And is there data showing approximately 8 how many were taken for each class? 9 A. Yes. 10 Q. Okay. 11 Where would that be? 12 A. You might have it in hard copy. It's 13 definitely in digital form. 14 Q. Okay. All right. 15 Once you determines these 241 points, 16 actually I believe then the computer then generates 17 these 241 points; is that correct? 18 A. That's correct. 19 Q. Is there a map showing the 241 points? 20 A. Yes, a map was generated digitally. 21 Q. You get the points out of that digital 22 map? 23 A. Yes. 24 Q. Did you produce that one? 25 A. It might be here, I'm not sure. 65 1 Q. Okay. 2 A. I'm not sure if it's in my files. 3 Q. All right. 4 You had 241 points. What did you do at 5 that point? 6 A. Basically you visit all these points out 7 in the field. 8 Q. Okay. 9 A. Ground truth them and see if they are what 10 you said they were in the map. 11 Q. All right. 12 Were you able to visit all 241 points? 13 A. I believe so. 14 Q. Okay. 15 A. If I remember correctly -- 16 Q. I'm sorry? 17 A. In acquiring 241 points we were again 18 constrained when the computer said this is where it 19 will be, that it had to be within a minimum of a 3 by 3 20 pixel area. I mean if it fell on one pixel and it was 21 surrounded by other things, well then, we weren't 22 obviously going to find that area, so... 23 Q. With regard to -- is that an instruction 24 that you gave the computer to pick 241 sites, was to 25 make sure it was picking a 3 by 3 or a 9 pixel area? 66 1 A. (No response.) 2 Q. Do you understand my question? 3 A. Right. I understand. 4 I'm not sure how we actually went about 5 doing that. I can't remember if there was a way we 6 could do that on the computer or whether we just picked 7 the closest point that was -- met the minimum 3 by 3 8 requirement. 9 Q. Ultimately you ended up with 241 3 by 3 10 sites? 11 A. Or larger. 12 Q. Or larger. 13 A. Right. 14 Q. You visited these? 15 A. Right. 16 Q. Okay. 17 Do you have documents related to those 18 visits? 19 A. I believe so. 20 Q. Similar to what we've already seen? 21 A. I think so. 22 Q. Okay. 23 Why don't we flip this one over so we 24 don't get confused. That's the tree island one. And 25 let's see if we can -- you can just keep them there, 67 1 that's your set. 2 A. Okay. 3 Q. That too. You don't need to go through 4 that, that's the other. It will be probably be here or 5 in here. 6 A. I believe this is it. 7 Q. All right. 8 And you're -- could you read off the Bates 9 numbers? These are consecutive. Just take, if you 10 just look at the top page there. 11 A. 1202231. 12 Q. Through? The final page -- 13 A. Yeah. 14 Q. -- of that entire. 15 A. Well, I'm make making sure all this is. 16 Q. Okay. 17 Well, I'll take you through each and every 18 one, trust me. 19 A. 1202541. 20 Q. Okay. 2541. Okay good. 21 MR. KOBELINSKI: Mark this as Composite 4. 22 (Thereupon, the document was marked 23 Rutchey Exb. No. 4 for Identification.) 24 BY MR. KOBELINSKI: 25 Q. Showing you then, Mr. Rutchey what's been 68 1 marked as Composite Exhibit 4, which bears the Bates 2 number you just read off into the record, the first 3 page of which appears to be a file cover reading WCA-2A 4 Accuracy Assessment, 3-23 through 4-24-92, is that the 5 period of time that you did the site visits for the 6 accuracy assessment? 7 A. Yes. 8 Q. Okay. 9 Now I want to go through this, rather 10 quickly identify what we have inside here. The first 11 document in there which bears Bates No. 120232 through 12 36, is this a summary of the site visits to all 241 13 sites? 14 A. Yes. 15 Q. Okay. 16 And so if I understand, isn't that, being 17 similar to a document previously identified in regard 18 to the 129 site visits, this is a summary based upon 19 the field notes and the visitations for the entire 20 field study? 21 A. Yes. 22 Q. Okay. 23 And what would be 1202237 through 40? 24 A. Well, the first part is the class number 25 that was assigned to each of the 20 classes. 69 1 Q. Okay. 2 Now with regard to points, would that be 3 the 240 some-odd sites? 4 A. Well, it's 210 of them. 5 Q. Okay. 6 Were there only 210 sites then that were 7 visited? 8 A. No, there was 241, but it was collected, 9 again, two different times. There was a second set 10 that was added on, 31 sites. 11 Q. Okay. 12 So those cover 210 sites. I can see that, 13 going along the columns here on this first page, 14 1202237, you have the points, you have the GPS 15 coordinates; is that correct? 16 A. (Shakes head up and down.) 17 Q. What would the, I guess it would be the 18 fourth column, which starts at the top of 10, 1, 2, 4, 19 1, 1 and et cetera? Is that class identification? 20 A. Yeah, but from looking at this I can't 21 tell whether that's what we saw in the field or what 22 was actually in the map, the final map that we 23 produced. 24 Q. Okay. 25 What is the final column when it says 70 1 negative 1 everywhere? 2 A. It looks like a bug. 3 Q. A bug, all right. 4 When you went out to the field to make 5 these classifications of 241 sites, were you aware 6 already what the computer was identifying each site as? 7 A. Les wasn't. I wasn't either, no. 8 Q. Okay. 9 The next document is 1202241 through 45. 10 It appears similar to what we just looked at, however 11 there's a fair amount of handwriting here. And drawing 12 your attention to that final, to the top of that where 13 the first page says final-map-CAT -- 14 A. Um-hum. 15 Q. -- what are the numbers in that left-hand 16 first column, first one? It looks like possibly 19.41. 17 It's difficult to read. The next one is clearer, 18 18.34, 7.76 and down the line. Do you know what those 19 are? 20 A. I'd be guessing, but I think it's 21 percentage. 22 Q. Percentage of the entire area? 23 A. Percentage of each of these classes. 24 Q. All right. I'm afraid you lost me on 25 percentage. 71 1 Are you talking about what percentage of 2 WCA-2A is made up of those classes or what 3 percentage -- why don't you answer that. 4 A. These numbers in the first column -- 5 Q. Um-hum. 6 A. -- okay, I believe they represent the 7 percentage of that class within Area 2. But again I'm 8 not sure. This is something I wrote on this paper two 9 years ago. 10 Q. All right. 11 Going along you have then the next column 12 or the, just class numbers 1, 2 through 20, and the 13 following column is a column of handwritten numbers, 14 41, 39, 9 16. Do you recall what those numbers are? 15 A. No. 16 Q. All right. Let's move along. 17 Drawing your attention then to a large 18 piece of map, which bears Bates No. 1202246, do you 19 recall what this is? 20 A. I believe this is our path that we 21 followed to look at the map accuracy assessment points. 22 Q. So this essentially has all 241 points on 23 here? 24 A. I think it's got the first 210. 25 Q. Okay. 72 1 Did you -- were 31 points added on after 2 the initial 210? 3 A. Yes. 4 Q. Why was that? 5 A. One of the things we wanted to know with 6 confidence is the cattail, and the stratified random 7 sampling didn't come up with enough points on that 8 cattail area. So we wanted to get more points to 9 verify whether the map was accurate in respect to 10 cattail. So we did a stratified -- another stratified 11 random sampling, checking 31 points within the cattail 12 zone. So an additional 31 sites were visited. 13 Q. All right. 14 When you say within the cattail zone, 15 which of the 20 classes were used for that stratified 16 selection? 17 A. (No response.) 18 Q. If you go back one, you can see the 20 19 classes, if that helps you. 20 A. Without actually seeing the digital data, 21 it's hard to be definite, but I would say it was 22 cattail dense, moderate, sparse cattail/brush mixture, 23 and I believe those are the only ones. 24 Q. Okay. 25 Do you recall whether sawgrass/cattail 73 1 mixture was reviewed, or part of that 31? 2 A. Oh, excuse me, yes, I would say those two. 3 I'm not sure. 4 Q. Would there be some documents in here that 5 we could look at to confirm that one way or the other? 6 A. It's all digital as far as I know. 7 Q. Okay. 8 The next set within this composite exhibit 9 1202247 through 253, what are these? What are these 10 documents? 11 A. This is ground truth data and the first 12 page is GPS output, PFINDER output. 13 Q. Okay. 14 And this is with regard to just these 15 seven sites? 16 A. That's correct. 17 Q. Okay. 18 Did you have any problems with the GPS 19 system during the inspection at 241 sites? 20 A. Other than the one I previously told you 21 about, as far as the navigation aspect. 22 Q. Okay. 23 And is there a particular name that's 24 referred to as, I think there is, where the data is 25 that it's not telling you the accurate location, what 74 1 is that? 2 A. Well, you either have raw GPS data or you 3 have differentially corrected GPS data. The raw can be 4 off by as much as a hundred meters. Differentially 5 corrected, we found we could get it down to three to 6 seven meters. 7 Q. And did you have that type problem when 8 you were doing the site visitation at the 241 sites? 9 A. As far as the inaccuracy? 10 Q. Right. 11 A. Yes. 12 Q. Okay. 13 Now then, going on to the next document 14 which appears as Bates No. 1202254 through 2275, what 15 are these documents? 16 A. Again, it's GPS PFINDER output data along 17 with ground truth. 18 Q. Are these grouped into any particular 19 manner? For instance, are these grouped into classes? 20 A. It's probably grouped based on that day's 21 work that we went out, went out in the field. 22 Q. Oh, all right. Okay. 23 And if you would just then go through the 24 remainder of this exhibit and confirm that what we have 25 here then are similar GPS data sheets along with field 75 1 inspection reports, and that would be up through Bates 2 No. 1202500. 3 A. (Indicating.) 4 Q. Would -- through that Page 500, is that 5 the initial 210 sites? 6 A. Yes. 7 Q. Okay. 8 And drawing your attention to Bates No. 9 1202501 through 541, what would these be? 10 A. This has the additional -- let me see. It 11 looks like 32 sites. 12 Q. Okay. 13 A. That we visited. 14 Q. All right. 15 Now, looking at these documents here in 16 regard to the additional sites for the cattail accuracy 17 assessment -- 18 A. Um-hum. 19 Q. -- does this help you determine what 20 classes were used or included in this? 21 A. No. 22 Q. Okay. 23 Nothing in here would identify that? 24 A. You're asking -- well, could you repeat 25 the question? 76 1 Q. My question is, going back to -- on the 2 additional 31 or 32 sites for cattail accuracy, I'm 3 trying to see which of the 20 classifications were used 4 for that -- 5 A. All right. 6 Q. -- random selection of 31 or 32 sites. 7 A. Again, I think it's -- without looking at 8 the digital data, I believe it was cattail dense, not 9 moderate, sparse and cattail brush mixture. 10 Q. Okay. 11 A. And you added sawgrass/cattail mix, so I'm 12 not sure about that. 13 Q. I didn't mean to add it. I was just 14 asking whether or not it was part of it. To the best 15 of your recollection it was Classes 10, 11, 12 and 13? 16 A. Right. 17 Q. What about 15, which is brush/cattail 18 mixture? 19 A. I don't think so so. It started with 10. 20 Q. And would your digital file show which 21 classes were identified or used? 22 A. Yes. 23 Q. Was that 31 or 32 additional sites that 24 were added on? 25 A. It looks like 32. 77 1 Q. Would it make a total of -- the total 2 would be 242 points then? 3 A. No, it's 241. If we went back and 4 counted, I think it was a total of 241 altogether. 5 Q. All right. All right. 6 What was the next step then? 7 A. Okay. 8 So we did the map accuracy assessment. 9 Q. Um-hum. 10 A. And we came up with the results from that. 11 And we -- at that point we wanted to see if we can 12 better those results by collapsing the -- within 13 species density characteristics that we were trying to 14 break out using the 20 class map. For instance 15 sawgrass, we had a dense, moderate to sparse. Well, 16 maybe the satellite imagery was having a hard time 17 breaking out with a species with that fine line between 18 graduations of density. So we combined all the 19 sawgrass and all the cattail into one class and came up 20 with a 12 class map. 21 Q. Okay. 22 A. Final map. 23 Q. Would there be a particular document 24 related to that step? 25 A. Yes. It's part of this paper. It's all 78 1 explained. 2 Q. Other than -- well, I understand the 3 explanation of the paper. Are any specific documents 4 going through that work step that you've produced? 5 A. Not to my knowledge. Digitally there is. 6 Q. All right. 7 And any additional steps after that? 8 A. We then did a map accuracy assessment on 9 that final 12 class map using the same data set that we 10 used on the 20 class map and came up with the overall 11 map accuracy. 12 Q. Okay. 13 Now as I understand it, you had -- then 14 you had the computer rerun the map using 12 15 classifications; is that correct? 16 A. We collapsed the 20 class map to a 12 17 class map, yeah. 18 Q. The computer would generate a new figure 19 showing just the 12 classes? 20 A. That's correct. 21 Q. Now, again, if I understand your testimony 22 that you did not make any additional field visits, then 23 you just took the data that was from the 241 sites 24 visited and used that for accuracy of the final map 25 with the 12 classifications? 79 1 A. That's correct. 2 Q. All right. 3 Any additional steps? 4 A. That about sums it up. 5 (Thereupon, a discussion was held off the 6 record.) 7 BY MR. KOBELINSKI: 8 Q. Mr. Rutchey, I'm going to hand you a 9 number of documents, see if you could identify what the 10 documents relate to. 11 MR. FITZGERALD: Give him a hint, these 12 are his documents? 13 MR. KOBELINSKI: We'll use that 14 definition. 15 BY MR. KOBELINSKI: 16 Q. Yeah, these are all from documents that 17 you've been looking at today in response to a duces 18 tecum that you've produced to us today in response to 19 the duces tecum; first of which is a laboratory 20 notebook, 1202643 through 688. 21 Do you know what that lab book relates to? 22 A. Yeah. This is the actual at the site that 23 we visited, it has in the left-hand margin the site 24 visited and what actually the pixels that were within 25 the imagery, 3 by 3 matrix of every one of them. 80 1 Q. This relates then to the paper we were 2 just discussing? 3 A. Yes. 4 Q. Okay. 5 MR. KOBELINSKI: Why don't you go ahead 6 and mark that. 7 (Thereupon, the document was marked 8 Rutchey Exb. No. 5 for Identification.) 9 MR. KOBELINSKI: I will identify this 10 better for the record. What we've marked as 11 Exhibit 5 -- is that correct? -- is a 12 laboratory notebook. It bears Bates Nos. 13 1202643 through 688. 14 BY MR. KOBELINSKI 15 Q. Is that your notebook, sir? 16 A. Yes. 17 Q. All right. 18 Why don't we use just the first -- second 19 page of it which is 1202644 and it says Class 1. What 20 exactly does this reflect? 21 A. It almost jiggles my memory about old and 22 new, but I'll try to guess. 23 Um, basically this is the -- what was, 24 let's say, Site No. 4, for the ground truthing, what 25 the pixel data was, such as was it all -- in this case 81 1 it looks like on No. 4 that it was all one, which would 2 have been, it looks like sawgrass dense. So we had a 3 whole 3 by 3 dense homogeneous patch of dense sawgrass. 4 Q. Well, let me break this apart a bit, if I 5 can. On Page 1202644 in the left-hand margin outside 6 the grid there are two numbers written there, 4 and 5. 7 Do you see that? 8 A. Yeah. 9 Q. Is that site Site No. 4, is that what that 10 reflects? 11 A. Yes. 12 Q. All right. 13 Now, following across this grid of 14 approximately 30 or 40 squares across, this is a grid? 15 A. Yes. 16 Q. And within that, just following the row 17 next to 4, interspersed in there are, in six places, 18 are the number 1 space, space, 1, space, space, 1, et 19 cetera. What exactly does that mean? Is there a 20 reason you have 6 columns there? How would I -- how do 21 you interpret this? 22 A. Okay. 23 I separated them out. If you look -- I'm 24 going further on so you can understand better. 25 Q. Okay. 82 1 A. If that's -- 2 Q. Okay. 3 Just give a Bates page and I'll turn 4 there. 5 A. 1202679. 6 Q. Done. 7 A. Okay. 8 Let's go -- let's go like 131 there in 9 upper right-hand site. Hold on one moment. 10 (Thereupon, a discussion was held off the 11 record.) 12 BY MR. KOBELINSKI: 13 Q. Okay. 14 131 appears to be on the upper right-hand 15 corner. 16 A. Okay. 17 That Site 131, the computer is telling us 18 within that location of Site 131, of the accuracy of 19 the site location, that every pixel showed to be 20, 20 which this case was periphyton. 21 Q. Okay. 22 A. If you look at the column over there we 23 say yes, it's 20, what we determined it to be. We went 24 out in the field and they came up to be 6, so this one 25 was wrong. 83 1 Q. Okay. 2 So this actually classification No. 6? 3 A. That's correct. 4 Q. This is out in the field, okay. So 5 reading next to 131 I have a box with nine 20's in it. 6 A. Right. 7 Q. On those 9 pixels in the computer I would 8 find them all as Class No. 20 -- 9 A. Right. 10 Q. -- and that's why you have 20 written down 11 then in the third column. Over where 6 is is what 12 actually the field notes show? 13 A. That's correct. 14 Q. All right. 15 Now, just out curiosity, would that mean 16 to you that, according to your field observations, all 17 nine of those were Category 6 or is that the 18 predominant category within the nine? 19 A. What it means to me is that our computer 20 said that that 9 by 9 matrix was periphyton and our 21 field reconnaissance showed otherwise, in that it was 22 counted as wrong. 23 Q. Okay. 24 How would you go about determining whether 25 your field observations showed all 9 pixels to be 84 1 Category 6? 2 A. You go out in the field and you ground 3 truth it and you write, like on field sheets, the 4 notes. And if it's not periphyton it's something other 5 then. 6 Q. Perhaps I'm not explaining myself. 7 Is that final column, where you have 8 written 6, does that indicate that that -- that all 9 nine pixels would be Category 6, or would 6 be 10 predominant of these nine, for instance, five out of 11 the nine were 6, would 6 be written there or would 6 12 and 4 or whatever classification? 13 A. I believe it represents predominant 14 vegetation that was at that site. 15 Q. Okay. All right. 16 This is from the whole 141 site field 17 trips when you're doing the accuracy assessment? 18 A. Yes. 19 Q. Okay. 20 Is this something that was out in the 21 field? 22 A. No. 23 Q. Okay. 24 So this was developed after you took all 25 the field notes and did this back in the office? 85 1 A. Yeah. The only thing that pertained to 2 the field notes was, there are like four columns in 3 each one of these sets. The initial site number, the 4 pixel representation and in the computer what we 5 determined that the overriding majority was from that 6 pixel representation from that, up to that point that 7 was all computer-generated. The last column was the 8 only one that was derived in the field. 9 Q. I understand, okay. All right. This was 10 5. 11 MR. CESARANO: You want to put a rubber 12 band around Number 4, however many there were? 13 MR. KOBELINSKI: Oh, yeah, let's do that. 14 BY MR. KOBELINSKI: 15 Q. All right. 16 I show you a group of documents which bear 17 Bates No. 1202689 all the way through 1202772, and 18 actually that first 2689 appears to be a file folder 19 cover stating georectification points, areas 3N, 3S and 20 Holeyland. Could you just -- could we go through that 21 and tell me those sheets relate to? 22 A. This is a rectification that we did on 23 some satellite imagery of the area, what I call 3 24 North, everything north of Alligator Alley. Then 3 25 South, everything south, and Holeyland. 86 1 Q. Okay. 2 Now this has not been related to the 2A 3 study? 4 A. No. 5 Q. Okay. 6 When was this 3A study done? 7 A. I have it, it looks -- it appears this 8 initial data set was collected in May -- no, June, 9 1992. 10 Q. Okay. 11 Now, is this the rectification stage then 12 of the project, essentially using satellite imagery for 13 vegetative mapping of 3A? 14 A. Yes. 15 Q. All right. 16 When did you start that project? 17 A. Same dates, May to June, 1992. 18 Q. That using SPOT imagery? 19 A. This, yeah, for rectification, yes. 20 Q. Okay. 21 Are you still -- is an that ongoing 22 project right now? 23 A. Yes. 24 Q. Okay. 25 What stage are you at in that project? 87 1 A. Basically we have the satellite imagery 2 rectified and we have some aerial photography that was 3 acquired from National Park Service cooperative 4 agreement that we did with them in acquiring NASA 5 photography. 6 Q. What is the date of the aerial 7 photography? 8 A. November, December, 1992. 9 Q. And that's infrared? 10 A. That's correct. 11 Q. Are you following essentially the same, I 12 have them as eight steps, but essentially the same 13 steps that you used for 2A for this project? 14 A. No. 15 Q. How are they different? 16 A. Using -- I'm using straight 17 photointerpretation of aerial photography as opposed to 18 a digital process. 19 Q. Okay. 20 Did this start with a SPOT imagery digital 21 information? 22 A. Yes. 23 Q. Okay. 24 Did there come a time you abandoned using 25 that? 88 1 A. Yes. 2 Q. Are you still going to use it? 3 A. Yes. 4 Q. All right. 5 I misunderstood your response then. How 6 does this differ from the 2A study? 7 A. I'm going to be using more conventional 8 aerial photointerpretation methods as opposed to 9 digital. 10 Q. Okay. 11 With regard to the digital, did you 12 complete the rectification of the digital information? 13 A. Yes. 14 Q. Okay. 15 Did you do an unsupervised classification? 16 A. Preliminary, yes. 17 Q. With approximately how many classs? 18 A. I tried a number of different classes. 19 Q. Approximately how many? 20 A. 25 to 150. 21 Q. All right. 22 The data that you have there, does that 23 just deal with the rectification set that you have 24 there, the sheet that I put in front of you? 25 A. Yes. 89 1 Q. Okay. 2 How many rectification points did you use? 3 A. I don't recall. It's more than what was 4 used for Area 2A because it's a larger area. 5 Q. Okay. 6 Have you done any site visits to verify 7 the unsupervised the classifications? 8 A. Yes. 9 Q. Approximately how many? 10 A. I think maybe one or two field trips. 11 Q. Which have covered how many sites? 12 A. I don't recall. I'd be guessing. Maybe 13 50. 14 Q. Why don't we close that up? 15 And did you produce documents similar to 16 the field inspection sheets that we have seen with 17 regard to those, the 3A field inspection for the -- of 18 the unsupervised classes? 19 A. I don't believe any were generated. 20 Q. Okay. 21 Did you generate any field notes of what 22 you saw out there? 23 A. Yeah, they're probably around somewhere. 24 They might be in these piles or ... 25 Q. Why don't we find them. Why don't you 90 1 take a quick look? 2 A. I don't see it there. 3 Q. All right. 4 The other place it could possibly be is -- 5 well that was -- you did go through that. That's 6 everything. 7 Do you believe you still have those? 8 A. They might have been in my folders or Les 9 Vilcheck might have them. It probably is still at the 10 raw data stage. I don't even think it's been 11 transcribed to these summary sheets that you -- 12 Q. The raw data would be some sort of a field 13 notebook with notes on it? 14 A. Yeah, or just a pad similar to what you 15 have there. 16 Q. And Les Vilchek is assisting you with this 17 project? 18 A. Yes. 19 Q. Okay. 20 Were you taking photos at the field sites, 21 photos as you did in 2A? 22 A. I don't believe so. 23 Q. Would your field notes reflect that? 24 A. Yeah. I don't think we did though. 25 Q. Do you recall approximately how many sites 91 1 you visited? 2 I know I asked that, but I don't recall 3 your answer. It was two dates I believe you said? 4 A. It would be a guess, 50. 5 Q. And when did you do that? 6 A. Oh, probably not too shortly after we 7 acquired that -- that data set. 8 Q. So probably late '92 or early '93? 9 A. Probably '92. 10 Q. Okay. 11 After that field trip, did you then 12 perform a supervised classification? 13 A. No. 14 Q. All right. I'm getting a little too 15 disorganized, because I've jumped in the middle of it. 16 When did you start the 3A vegetative 17 mapping project? 18 A. Initially I think we made the first 19 efforts when we acquired the first SPOT satellite 20 imagery which was in May of '92. 21 Q. Okay. 22 And is anyone else working on this project 23 other than Les Vilcheck and yourself? 24 A. No. 25 Q. Okay. 92 1 After obtaining a SPOT imagery, I 2 understand you did a georectification of the map? 3 A That's correct. 4 Q. What was your next step? 5 A. We just basically analyzed the data, some 6 very preliminary analysis, in looking at it digitally 7 to see if we could get a feel for patterns in Area 3. 8 And we groundtruthed some of these pattern areas, some 9 very preliminary stuff. 10 Q. Is this different than the two day field 11 trip we were just discussing? 12 A. I think so. 13 Q. Okay. All right. 14 The field notes from that? 15 A. We didn't find them. I think they're 16 available somewhere. Les probably still has them 17 somewhere. 18 Q. You just looked through everything we had 19 here. Do you recall seeing them? 20 A. No. 21 Q. All right. 22 After that field trip, did that result in 23 any type of modification to your map? Or was it just, 24 as I understand it, just a beginning to understanding 25 the vegetative communities at this time that were out 93 1 there? 2 A. Which map? 3 Q. You have a digitized SPOT imagery map of 4 3A; is that correct? 5 A. Correct. 6 Q. You georectified it? 7 A. Okay. 8 Q. Then I understand you analyzed the data 9 and, as you put it, made some site visits to look at 10 vegetative communities? 11 A. Right. 12 Q. As a result of these site visits, did you 13 change the map at all or start changing 14 classifications? 15 A. No. 16 Q. It was just to familiarize yourself with 17 the area? 18 A. Yes. 19 Q. I gather from what you said, Area 2A 20 you've done a fair amount work in, is that right? 21 A. Yes. 22 Q. And 3A you've not? 23 A. That's correct. 24 Q. Okay. 25 After making this field trip with Les to 94 1 familiarize yourself with the communities, what was 2 your next step? 3 A. Basically we haven't done too much since 4 then. 5 Q. Okay. 6 I believe you did say you did an 7 unsupervised classification of several of them? 8 A. That was part of the preliminary -- 9 Q. Oh, all right. 10 A. -- just looking at the data and just 11 generally looking at it and trying to figure out land 12 patterns. 13 Q. Okay. 14 You also said you made a second field 15 trip, the two day field trip to points selected? 16 A. Yeah, one, two days. 17 Q. Okay. 18 Is it -- just so I understand it, that 19 makes two field trips you made? 20 A. No, it's -- I mean this is going back a 21 while, but either one or two days we went out in the 22 field after we acquired the data and just have a 23 preliminary looking at data, trying to come up with 24 some generalized land patterns. 25 Q. Okay. I'm sure you're explaining it 95 1 perfectly. I just want to make sure I understand. 2 In my notes I had thought you had told me 3 you actually did go to a particular site to do some 4 site identification, that was approximately a two day 5 trip where you have field notes, but you have not 6 written up the inspection field inspection sheets for. 7 A. We did some very preliminary unsupervised 8 classifications. We had patterns and we visited them 9 and just tried to look at the general land patterns in 10 the area. 11 Q. Okay. 12 A. That's as far as we got. 13 Q. I understand that. 14 Was this preliminary unsupervised site 15 inspection that you were doing one or two days, is that 16 the second field trip with regard to 3A? 17 A. The first one was for the actual 18 rectification. 19 Q. All right. What was the second one? 20 A. That's basically those one or two days was 21 the second. 22 Q. Just two trips then? 23 A. Two trips. 24 Q. I misunderstood you. Thank you. 25 And you finished that in late '92? 96 1 A. Approximately '92 sometime. 2 Q. Okay. 3 Have you done any additional work on the 4 vegetative mapping of 3A? 5 A. No. 6 Q. Okay. 7 Is there a reason it -- 8 A. Just working on a lot of different things 9 and other projects and it's taken me away from it at 10 this point. 11 Q. Is that an ongoing project, the mapping of 12 3A? 13 A. Yeah, I would say so. 14 Q. Are you going to attempt to get new SPOT 15 imagery or never mind? 16 A. No. 17 Q. Okay. 18 Do you intend to use the May '92 SPOT 19 imagery? 20 A. Yes. 21 Q. Okay. 22 Since approximately a year and a half has 23 passed since the collection of the May SPOT imagery, 24 how do you intend to ground truth it? 25 A. I don't. I plan to use that rectification 97 1 process to rectify a more current scene that's already 2 been acquired. 3 Q. What scene is that? 4 A. Basically it's late 1993. 5 Q. Is that SPOT imagery? 6 A. Yes. 7 Q. Do you recall what month of '93? 8 A. No, we -- no. 9 Q. All right. 10 Are you again then going to be using the 11 '93 SPOT imagery for the purpose of doing vegetative 12 mapping of 3A? 13 A. As part of the process, yes. 14 Q. Okay. 15 Will you also be using infrared as you did 16 with the aerial photography done with the National Park 17 Service? 18 A. That is a possibility, yes. 19 Q. Do you intend to use any infrared 20 photography? 21 A. Maybe. 22 Q. Do you already have it? 23 A. No. 24 Q. Okay. Are there plans to have it flown? 25 A. It's possible. 98 1 Q. Is it in the works? 2 A. No. 3 Q. Let me see what else I have here. Let me 4 see if we can identify it. 5 (Thereupon, a discussion was held off the 6 record.) 7 BY MR. KOBELINSKI: 8 Q. I'm showing you, sir, what has been marked 9 as Bates No. 1220375 through 1220400. Again this is a 10 document that you produced to us in response to your 11 notice of your deposition, the top of which appears to 12 be a file folder marked M. Koch. 13 Can you identify that for me, what that 14 relates to? 15 A. This is some work that Marguerite 16 initiated in a project that I was working on with her, 17 basically looking at transects in Area 2A. And she was 18 taking the lead on this. Basically we were looking at 19 the transition zone going from the impacted area to the 20 nonimpacted area of Water Conservation Area 2A. 21 Basically we were looking at hydrology, soils and 22 vegetation. 23 Q. Okay. 24 When was that project being conducted? 25 A. This was pretty much right before she left 99 1 the District, and I don't remember the exact data she 2 left, but this is what I had done up to that point when 3 she left. I haven't done much with it since. 4 Q. Okay. 5 Is that an ongoing project? 6 A. Not that I know of. 7 Q. Did you come to any conclusions from that 8 project? 9 A. No. 10 Q. Okay. 11 To your knowledge, is anyone still working 12 on that project? 13 A. Not this specific one, no. 14 Q. Okay. 15 Is anyone working on a similar project 16 that you're aware of? 17 A. Yes. 18 Q. Who is that? 19 A. I'll not sure of all the players. There's 20 a number of people in my division working on looking at 21 transects and gradient changes within the transects 22 within Water Conservation Area 2A. 23 Q. Do you know who is the head of that 24 project? 25 A. Currently I believe it's Fred Sklar. 100 1 Q. Fred, could you spell that name? 2 A. S K L A R. 3 Q. Okay. 4 And what do you understand the project is 5 doing? 6 A. Looking at -- well, collecting and 7 analyzing data along these transects within Water 8 Conservation Area 2A. 9 Q. Are these transects south of the 10 10 structures? 11 A. That's correct. 12 Q. And what type of data are they collecting? 13 A. All types of water chemical constituents, 14 soil data, algae, water depth, these areas are the 15 major components. 16 Q. Are they also doing vegetative 17 identification? 18 A. I believe at the points, the sites, yes. 19 Q. Do you know if they're using your 20 vegetative map that we've just been discussing, the 2A 21 vegetative map? 22 A. Yes. 23 Q. And do you know what the purpose is? 24 A. I think its final purpose is to determine 25 why the area is becoming impacted due to the inflow 101 1 through the S-10 structures. 2 Q. Well, is it attempting to analyze the 3 causes for vegetative change? 4 A. Causes for vegetative change is one 5 component. 6 Q. What are the other components? 7 A. Water quality, soil phosphorus or soil 8 chemical constituents, change that occurs with 9 vegetation, things like that. 10 Q. Is there anything else? 11 A. There's probably other things, but that's 12 the ones I know about. 13 Q. Who is working with Fred Sklar on that 14 that you're aware of? 15 A. Peter Rawlik. We just hired a new woman, 16 I'm not each sure of her name at this point. 17 Q. You know her first name? 18 A. Miao, I think that's how you say it. Jim 19 Grimshaw, Paul McCormick, Jim Laing. I think that's 20 the major people. There could be others that I'm not 21 sure what their role in it. 22 Q. Peter Rawlik, how do you spell that name? 23 A. R A W L I K. 24 Q. All right. Let's see what's left. 25 Let me show you again a number of 102 1 documents that were received. Now they were banded 2 together, I don't know whether they're related to each 3 other, Bates No. 1220096 through 1220189. First page 4 is all handwritten. I believe it says on the bottom 5 WCA-2 period DAT, N R O W, N C O L S. Could you 6 identify that? 7 A. This is the data from the vegetative map 8 that Les Vilchek and I produced that shows various 9 aggregations in the number and rows of columns that 10 resulted from those aggregations. 11 Q. Now is this the 2A study we were just 12 discussing? 13 A. No. 14 Q. All right. 15 What area is this study? 16 A. This was within Water Conservation Area 17 2A. 18 Q. Okay. 19 But this is a different project? 20 A. Yes. 21 Q. What project is this? 22 A. This is the paper I'm working on with 23 Jayantha Obeysekera, looking at scale issues as they 24 pertain to the Everglades. 25 Q. Could you just review what's in that and 103 1 see if that all relates to the same project? 2 A. No, it doesn't. It's not all pertaining 3 to this project. 4 Q. Okay. Hold on one moment. 5 Before I have you go through the documents 6 on this project with Jayantha Obeysekera, you're saying 7 it deals with scale issues with regards to the 8 Everglades. What exactly did that mean? 9 A. There's a number of these in existence or 10 being developed for the Everglades. And one of the 11 considerations of any model development is that you 12 consider the scale of what you're modeling or when 13 changes occur or what scale, and that's what this paper 14 is about. We're trying to figure out, at least for one 15 component or stated variable of a model, in this 16 particular instance it's vegetation, at what scale the 17 model should be looking at or addressing. 18 Q. All right. 19 And have you determined a proper scale to 20 look at for vegetation change? 21 A. It's very preliminary at this point. 22 We're in the data analysis. 23 Q. Okay. When did you start that project? 24 A. I'd say it was eight months, ten months 25 ago. 104 1 Q. Okay. 2 And how are you doing it, what's your 3 methodology? 4 A. Basically we have the original -- well, 5 basically we used the 12 class map output as opposed to 6 the 20 class map output. We aggregated it at a number 7 of different scales, aggregations going anywhere from 8 20 to a thousand and increasing by basically 40, 9 except -- with the exception of going from 20 to 40. 10 So each pixel is going to represent -- we have 20 11 meters, 80 meters, so on and so on, and we're looking 12 at those final map outputs using a program developed by 13 Monica Turner from Oakridge National Laboratories 14 called SPANS. And we're mainly interested in the 15 components, the fractal components of that program. 16 Fractals have been used to look at scale issues of all 17 types of physical phenomena, clouds, shorelines of 18 lakes, land cover. So we're -- this is resident in the 19 literature and we're using it to look at Everglades 20 vegetation. 21 Q. Okay. 22 Have you ruled out any of those 23 classifications or sizes from 20 to 1,000 as yet? 24 A. The results at this point are very 25 preliminary. 105 1 Q. What do the preliminary results show? 2 A. Somewhere around 120 meters. 3 Q. Okay. 4 Could you then identify by Bates numbers 5 which documents are related to that project starting 6 with initial page 1220096? 7 A. Everything up to 1220166. 8 Q. All right. 9 A. We've identified that. 10 Q. Let me show you two documents, or a 11 document, bears Bates No. 1202849 through 1202867, the 12 first page appears to be a file folder which indicates 13 WCA-3S for SPOT 5-11-92. What is that? 14 A. This is the sites that we visited in Water 15 Conservation Area 3, the satellite imagery we 16 previously spoke about, and those are Les's notes that 17 he had of all of his sites. 18 MR. KOBELINSKI: All right. 19 You can mark that as 6. 20 (Thereupon, the document was marked 21 Rutchey Exb. No. 6 for Identification.) 22 MR. KOBELINSKI: I'd like to mark this as 23 7. 24 (Thereupon, the document was marked 25 Rutchey Exb. No. 7 for Identification.) 106 1 MR. KOBELINSKI: For the record, I have 2 marked the document previously handed to Mr. 3 Rutchey as Exhibit No 6 that bears Bates No. 4 1202849 through 867 and has a first page which 5 appears to be a file folder labeled WCA 3S SPOT, 6 5-11-92. 7 BY MR. KOBELINSKI: 8 Q. I show you, Mr. Rutchey, what has been 9 marked as Exhibit No. 7, bears Bates No. 1202868 10 through 1202880 and appears to be a file folder on the 11 front which says WCA 3N for SPOT 5-11-92. I ask you if 12 you've ever seen that document before. 13 A. This is the same as the previous data set 14 but -- except for different days and south of Alligator 15 Alley. 16 Q. This again then relates to the 3A visit? 17 A. That's correct. 18 Q. Okay. Okay. 19 Next I'm showing you what's been marked as 20 Bates Nos. 12002773 through 1202848 and the front cover 21 which is Holeyland data for SPOT 5-11-92. Can you 22 explain what that is? 23 A. This is the same satellite imagery except 24 a different area. It's called the Holeyland area. And 25 this is a preliminary data analysis of that data and 107 1 some ground truth information along with some GPS 2 PFINDER output sets. 3 Q. That's a part of the 3A mapping then, 4 you're also mapping the Holeyland? 5 A. I would say Holeyland is a separate 6 project. 7 Q. Okay. 8 Is that Holeyland vegetative mapping still 9 an ongoing project? 10 A. I would say yes. 11 Q. Okay. 12 Do you have any additional data or 13 documents you've produced related to this Holeyland 14 mapping? 15 A. I believe there is some here, yes. 16 Q. If you could go through and identify 17 those. 18 A. This is all that's left of yours. 19 Q. Leave that here. 20 (Thereupon, a discussion was held off the 21 record.) 22 THE WITNESS: I believe all this is 23 similarly related, somewhat related. 24 BY MR. KOBELINSKI: 25 Q. These various documents are all Holeyland, 108 1 also part of that project? 2 A. I pulled this out of that. 3 Q. Okay. 4 MR. KOBELINSKI: And the witness has 5 identified documents bearing Bates No. 1220441 6 through 1220583, however he has taken out as 7 unrelated a document bearing Bates No. 1220491 8 through 1220494. 9 BY MR. KOBELINSKI: 10 Q. And these documents are, again, relate to 11 Holeyland mapping; is that correct? 12 A. Yes. 13 Q. Okay. 14 It appears to me we've finally identified 15 pretty much all the documents you've sent to us. We'll 16 just take a quick break for lunch and then we'll start 17 finding out what they mean. All right. 18 (Thereupon, a luncheon recess was taken 19 from 12:10 to 1:25 p.m..). 20 BY MR. KOBELINSKI: 21 Q. All right, Mr. Rutchey. I remind you that 22 you're still under oath. 23 MR. KOBELINSKI: One thing before we get 24 on, why don't we mark this 8? 25 (Thereupon, the document was marked 109 1 Rutchey Exb. No. 8 for Identification.) 2 BY MR. KOBELINSKI: 3 8. Mr. Rutchey, I'm showing you what's been 4 marked as Rutchey Exhibit No. 8, which is a paper 5 bearing Bates No. 1220001 through 1220032, which is 6 entitled Inland Wetland Change Detection in the 7 Everglades Water Conservation Area 2A Using a Time 8 Series of Normalized Remotely Sensed Data. And I 9 gather this is a paper that you have participated in? 10 A. Yes. 11 Q. Is this the final draft of it? 12 A. Yes. 13 Q. Is this -- will this be published in any 14 type of a -- 15 A. Yes, it's been accepted by the Journal of 16 Photogrammetric Engineering and Remote sensing. 17 Q. Do you know when it will be published? 18 A. They -- right now, I called them just the 19 other day. There's about an 18 month turn around for 20 papers that they have a backlog right now. 21 Q. This was sent out for peer review? 22 A. Yes. 23 Q. Okay. 24 And have you received peer review comments 25 back? 110 1 A. Jensen has all that. 2 Q. Okay. 3 You didn't receive any peer review 4 comments? 5 A. Nope. 6 Q. Was the document revised after it was 7 peer-reviewed? 8 A. I'm not sure. 9 Q. Okay. 10 Are the documents that you've produced to 11 today -- which, if any, of the documents -- when I say 12 today, in response to this notice of deposition. 13 Which, if any, of these documents that are remaining 14 relate to this paper? 15 A. That are remaining? Probably none. 16 Q. Okay. 17 And of the documents previously marked, 18 which, if any, relate to this paper? 19 A. The original 129 ground truth sites and 20 their locations and what we found there. 21 Q. Okay. 22 What about the accuracy analysis for the 23 241 sites? 24 A. I believe that was sent too, but I don't 25 think that was used in this paper. 111 1 (Mr. Downing entered the room.) 2 BY MR. KOBELINSKI: 3 Q. Okay. All right. 4 What was your participation in this paper, 5 what did it encompass? 6 A. Basically just provide the original data 7 set. 8 Q. Okay. 9 And the data set you provided to -- was 10 that Dr. Jensen? 11 A. Right. 12 Q. Okay. 13 Is there a list of data sets you can just 14 tick off for me? 15 A. Yeah, the 129 ground truth sites is one 16 and then all the original multispectral satellite 17 imagery data sets that we used in this analysis along 18 with the final 20 class and 12 class vegetation maps 19 that I produced, Les Vilcheck and I produced. 20 Q. All right. I can't write as fast as she 21 can. 22 The original digital data set, right? 23 From the August of '91 or '92? August '91, yeah, 24 August 10, '91 digital data set; is that right? 25 A. Right. 112 1 Q. 129 ground truth sites? 2 A. Right. 3 Q. And the final 20 class and 12 class 4 digital map data sets; right? 5 A. Correct. 6 Q. Was there anything else? 7 A. And all the original multispectral data 8 sets that were used in this paper. 9 Q. Now you're referring to, if I understand 10 correctly, data sets for April 4, 1987? 11 A. That's one. 12 Q. January 17, 1982? 13 A. Yeah. 14 Q. April 2, 1976 and and February 22, 1973? 15 A. That's correct. 16 Q. Now did you just send him the original 17 digital data set you had for those four dates? 18 A. That's correct. 19 Q. Okay. 20 You had not manipulated them to any 21 extent? 22 A. No. 23 Q. Other than providing these data sets to 24 Dr. Jensen, what other participation did you have in 25 this paper? 113 1 A. That's about it. 2 Q. Okay. 3 Did you draft any portions of it? 4 A. No. 5 Q. Okay. 6 Do you know what Marguerite Koch's 7 participation was in this paper? 8 A. She provided the soil or water phosphorus 9 data. 10 Q. Did she perform any analysis comparing 11 vegetation to the porewater data? 12 A. I'm not sure. 13 Q. What about Sunil Narumalani? Last name is 14 N A R U M A L A N I, his first name is S U N I L. 15 A. I'm not sure what his role was in this. 16 You'll have to talk to Dr. Jensen about that. 17 Q. Have you ever met Dr. Narumalani? 18 A. Yes. 19 Q. Okay. 20 What exactly is his specialty, if you 21 know? 22 A. I'm not sure. I just met him a conference 23 one time. I know what he looks like. He's an image 24 processing -- I think he's got a doctorate basically 25 in -- basically digital image processing. That might 114 1 not be a right term, but that's what his field of 2 expertise was. 3 Q. What was Dr. Jensen's role with regard to 4 this paper? 5 A. He was the primary author. 6 Q. Okay. 7 To your knowledge is he the one that 8 conducted most of the analysis? 9 A. Right. 10 Q. Okay. 11 Drawing your attention then, sir, back to 12 Rutchey Exhibit 1, the 2A vegetative analysis, and I 13 have a few questions on some of the steps you had taken 14 with regard to what I have written, Step 4, I'm talking 15 about after the computer had gone through and broken 16 out the information into the 30 classifications or 17 clusters, and at which point I believe you said 154 18 sample sites were selected by the computer; is that 19 correct? 20 A. No, we just chose 30 classes, within each 21 one of those clusters we attempted to find five ground 22 truth sites. 23 Q. Oh, okay. 24 So the computer didn't generate the five 25 sites, that was something that you mechanically did? 115 1 A. That's correct. 2 Q. Okay. Pardon me. 3 And as I understand the criteria, was that 4 finding a -- essentially a three by three pixel square, 5 in other words, nine pixels in the same classification; 6 is that correct? 7 A. That was the minimum, right, requirement. 8 Q. And you, of course, would take more than 9 that. 10 With regard to locating the the test sites 11 what -- what was the exact instrument that you used? 12 It might be in here somewhere. 13 A. The exact instrument? 14 Q. Yes. 15 A. It was called ERDAS. It's a software 16 image processing software package. 17 Q. But I'm talking about going out on the 18 site, what GPS equipment did you use to find the actual 19 sites, to find the sites with? 20 A. GPS basic unit. 21 Q. Is there one standard GPS basic unit or 22 are there different models of that? 23 A. There's different models. 24 Q. Do you know what model you had? 25 A. That's the name of it. 116 1 Q. Okay.. 2 I believe also you mentioned that there 3 was a base station. Where was the base station 4 located? 5 A. At the South Florida Water Management 6 District, Gun Club Road. 7 Q. Are you responsible for that base station? 8 A. Yes. 9 Q. And how many -- as I understand base 10 stations, they keep track of the various satellites; is 11 that correct? 12 A. Yes. 13 Q. Do you know what particular type of base 14 station this was? 15 A. It's a Trimble Pathfinder community base 16 station. 17 Q. Does that -- how many satellites did that 18 keep track of at any given point in time? 19 A. Well, it varied from then till now. Right 20 now it can track up to nine. 21 Q. Then what about back in '91? 22 A. We didn't have a full ephemeris window 23 back then, window of opportunity. They didn't have all 24 the satellites in place. 25 Q. You lost me on that term. 117 1 A. Ephemeris. 2 Q. All right. 3 What were you operating with in 1991? 4 A. I don't remember the exact number, but our 5 window was limited in that actual span of time that we 6 can acquire an accurate GPS data. You can actually ask 7 the software for when the window is open that you can 8 acquire the data based on the geometry of satellites in 9 space, the available satellites in space. 10 Q. Okay. 11 Was this then one of the governing factors 12 as to when you would go on the site visits or field 13 visits? 14 A. Within a day, yes. 15 Q. Okay. 16 Perhaps if you would walk me through, 17 again, the GPS portion of it. How would you plan out 18 the site visit from the GPS aspect? 19 A. Well, I had my points I wanted to visit. 20 I put that coordinate into the GPS unit. I'd navigate 21 as best I could to that point. 22 Q. All right. 23 You were saying you had to -- perhaps I 24 misunderstood. I thought you told me you first had to 25 contact someone to find out whether or not the base 118 1 unit could read or contact certain satellites. Take me 2 from the initial step if you would. 3 A. I would look at the data, window of 4 availability, and figure out the span of time that I 5 needed to be out there in order to collect, you know, 6 accurate GPS data. So I go out during that time and 7 visit a point, log it over a period of two to three 8 minutes, that way you have multiple points, it makes 9 sure your final solution is more accurate. Take it 10 back, differentially correct each one of those points, 11 average the solution from that, and come up with a 12 point that you were really at when you went out in the 13 field. 14 Q. All right. 15 With regard to the window of availability, 16 who do you contact to find out what it is or is this 17 just a publication that you view through -- 18 A. No, it's all in -- what you can do is any 19 almanac, that unit logs, whenever you're looking for 20 data, you can download that to the computer and it can 21 figure out from that almanac when the windows of 22 opportunity are open for collecting GPS data. 23 Q. All right. 24 Now this almanac is in the base unit or is 25 that in the unit you're taking out in the field? 119 1 A. It's in both. 2 Q. Okay. 3 A. It's in both. 4 Q. Is that something you load in right before 5 you go out in the field, this almanac? 6 A. No. The almanac is generated 7 automatically. You don't have to -- just take the unit 8 out, let it make contact to the satellites. It 9 automatically puts an almanac in there, you can 10 download that almanac into your PFINDER software. 11 Q. Okay. All right. 12 The first time you are going out there, 13 you have a window of opportunity, window of 14 availability. You're starting at, I don't know where 15 you would start, the 10 structures or on the -- 16 A. For which? 17 Q. For the first trip you took out there. 18 A. For rectification? 19 Q. No, the 129. 20 A. It was random where I start, Site 1. Not 21 really known. 22 Q. Okay. 23 What do you do then? Do you punch in 24 coordinates for the first place you want to go? 25 A. Right. 120 1 Q. Where do you get those coordinates? 2 A. That came from -- that's been asked and 3 answered. 4 Q. All right. 5 So where do you get those coordinates? 6 A. Asked and answered. 7 Q. But you have to -- I don't remember the 8 answer, sir, can't you just say? 9 A. It's part of this report. You've already 10 asked that question. 11 Q. All right. I don't have it written down, 12 sir, you have to respond to my question. You can't 13 just say asked and answered. 14 THE WITNESS: I have to keep answering -- 15 if he asks me the same question over and over do 16 I have to keep answering? 17 MR. CESARANO: Well, why don't you go 18 ahead and answer it once more. Maybe he'll 19 write it down this time. 20 THE WITNESS: Unsupervised, the 21 classification within each of 30 clusters we 22 tried to find five sites. That would have made 23 150 and we found 129. That's where the sites 24 came from. 25 BY MR. KOBELINSKI: 121 1 Q. Okay. 2 But where did you get coordinates 3 themselves? I still don't understand. 4 A. The coordinates are part of the digital 5 imagery, we rectified it. 6 Q. So it's part of the digital package you 7 received, the data? 8 A. Well, no. You use the -- the 9 rectification points to rectify the original imagery. 10 Then you have a real world map projection, then when 11 you point to an area, you know the location within the 12 software. 13 Q. Okay. 14 The computer tells you the -- 15 A. Right. 16 Q. Okay. 17 Did you -- did you assign any error as to 18 the rectification as to whether or not there was any 19 error in that? 20 A. Yes, it was a root mean square of .4. 21 Q. By mean, what as far as meters? 22 A. Eight meters. 23 Q. Okay. 24 So you're about to start your trip, you 25 punch your coordinates for the first site; is that 122 1 correct? 2 A. Yes, it could be the first site, yeah, 3 probably start at one. 4 Q. Whichever one starts with, I'm just trying 5 to follow through and understand the procedure. 6 A. Okay. 7 Q. I guess it's directional, it just takes 8 you there? 9 I've never used a GPS unit, I'm just a 10 lawyer, okay. 11 How do you get out there, you punch it in 12 and there's a little arrow? 13 A. If we -- depending on the method, yeah, 14 it's basically that simple. It's -- you put way points 15 in and you navigate to them, and it basically tells you 16 your bearing and where you need to go and bearing and 17 direction. And it has actually a little compass thing 18 that says well, you should turn this way, a little bit 19 this way, and when you get there, you know, within a 20 certain distance and it, you know, like we could get 21 down almost to where it says you're on the spot. 22 Q. Okay. All right. 23 Now you talked about taking several 24 readings, if I understand it correctly? 25 A. Right. 123 1 Q. Once you get to the spot, what do you do? 2 A. I take a number of readings over a period 3 of two to three minutes, and that varied depending on 4 whether we used the helicopter or airboat. 5 Q. Okay. 6 With the helicopter how many readings 7 would you take? 8 A. Five. It's hard for a helicopter to hover 9 for two to three minutes in one exact spot. 10 Q. And with an airboat? 11 A. Probably over a period of two minutes, 12 three minutes, one every 15 seconds, approximately 13 maybe ten altogether, if I remember correctly, 14 that's... 15 Q. Okay. 16 How do you physically do a reading? What 17 do you do? Is that something you just program into the 18 machine itself? 19 A. Right. The machine actually logs the 20 data. You can actually set the machine to collect data 21 at intervals based on where you're at, you can say the 22 interval, say collect data every fifteen minutes and it 23 will log your position every fifteen minutes and store 24 it. 25 Q. Just trace your path then using that data? 124 1 A. Right. 2 Q. Okay. 3 A. You could use it for that purpose also. 4 Q. All right. 5 What did you have it set then for this 6 particular -- your field trips? 7 A. I don't understand the question. 8 Q. I thought you said you could set it 9 automatically to read? 10 A. Oh, it was -- I'm not -- I don't remember 11 exactly, but in the field I think it was every 15 12 seconds and in the plane, I think it was every -- 13 helicopter -- every five seconds. 14 Q. Okay. 15 Would you still have the -- well, all 16 right. 17 Before I find out what you have, this is 18 presumably recording in some sort of a computer or some 19 data base -- 20 A. Um-hum. 21 Q. -- out in the field? 22 A. Yes. 23 Q. What do you with it when you get -- 24 A. We download it into the PFINDER GPS 25 software. 125 1 Q. That automatically takes in -- looks at 2 the input from the base station, determines where you 3 actually were, in case there was a type of 4 interference? 5 A. That's correct. 6 Q. Okay. 7 Do you still have those files for the 129 8 trips -- 9 A. Yes. 10 Q. -- 129 station trips? 11 I assume, from looking at those files, I 12 would be able to tell approximately how many readings 13 there were and how close together, et cetera? 14 A. Yes. 15 Q. Okay. 16 Would I be able to identify what 17 satellites you're looking at from those files or no? 18 A. Not from those hard copy files. I have 19 the original digital data and I think there's a way 20 that you can actually look at that and tell what 21 satellites it was using to determine position. 22 Q. Okay. All right. 23 You had actually identified some GPS data 24 for me earlier in the deposition, and essentially, if I 25 understand what you just said, I could then pretty much 126 1 look at everything you just explained, with the 2 exception of what satellites from this hard copy 3 readout; is that right? 4 A. Right. 5 Q. With what you identified earlier in the 6 deposition I can find out whether you're reading from 7 five seconds apart or 15 seconds apart or how many, all 8 that? 9 A. Yes, 10 Q. That's all in here? 11 A. Yes. 12 Q. When you get back say, how many stations 13 do you visit in one trip? 14 A. I would say 30 or 40 in a day was a good 15 trip, depending on whether you're using helicopter or 16 airboat. 17 Q. Okay. 18 And then the down load the 40 stations 19 with the various readings for them; is that right? 20 A. Right. 21 Q. Okay. 22 Is there -- you've mentioned a software 23 package that's done, automatically plugs in to give you 24 where, where you actually were. Is this sort of 25 automatic for each station? 127 1 A. No. 2 Q. How does it work? 3 A. You download the data and you combine that 4 data with the base station data that was collected at 5 the same exact time. And then the software, it's 6 differentially corrected the data, you want to make 7 sure you do each individual point even though they're 8 pretty much the same site, you want to average them. 9 After that's pretty simple. 10 Q. Okay. 11 That computer program, does it take into 12 account whether they're reading the same satellite and 13 all that stuff? 14 A. They have to read the same satellite or it 15 won't work. 16 Q. That part, the program itself? 17 A. Yeah. 18 Q. Okay. 19 After you get the readout it's corrected. 20 Do you then average those 10? 21 A. That's correct. 22 Q. Or if its, for instance an airboat 23 station? 24 A. Correct. 25 Q. All right. 128 1 The data that we have to -- we have the 2 corrected 10 prior to averaging or do we have raw data? 3 A. You have all three. You have the raw 4 data, you have the raw data that's been differentially 5 corrected, and you have an average of that 6 differential, the corrected raw data. 7 Q. Okay. 8 And based upon the your analysis, how 9 close do you believe you were to the spot you were 10 actually looking for? 11 A. Well, I know the accuracy of the GPS unit 12 was in the range of three to seven meters because of 13 our trips. We would go to a known survey site out in 14 the field that we were doing our field reconnaissance, 15 we differentially corrected that data set, so we knew 16 throughout the process we were in a range of three to 17 seven meters. 18 Q. Okay. 19 After you, you know, took the 125 field -- 20 went to 129 sites out in the field, at that point, as I 21 understand it, you went from 30 classes down to, I 22 believe, it was 19 is what you said; is that right, and 23 then added periphyton later on? 24 A. No. 25 Q. Okay. 129 1 A. This has been asked and answered again. 2 Q. Sir, you have to understand, you've done 3 this, you're out there, you spent over a year doing it. 4 We, on the other hand, are trying to read something, 5 understand what you did. We do not have the memory 6 that you do. If I asked this morning, I apologize if 7 you stated something I didn't pick up on immediately, 8 but it will happen where I ask a question where perhaps 9 you believe you've given me the information I was 10 seeking. All right. It's perhaps a frustrating 11 process, but it needs to be done. Okay? 12 A. Okay. 13 My answer to that is my first deposition I 14 got asked the same thing over and over again 20 15 different ways and the guy knew exactly what he was 16 doing. I think you're doing it too, but that's okay. 17 If you want my answer, I'll keep answering. 18 MR. CESARANO: If I think he's beating you 19 up I'll let you know, okay. I don't think we've 20 gotten there yet. 21 THE WITNESS: Okay. 22 BY MR. KOBELINSKI 23 Q. Using the phrase, I am not tempted to beat 24 you up, all right. You're not being tested in this 25 case, I'm just out trying to really figure out what it 130 1 does, okay? All right. I'm attempting to. 2 Then it shows that you visited 129 sites 3 is what I have. You then did a supervised 4 classification, at which point you got down to, I 5 believe it says 19, and ultimately you added an 6 additional one class; is that correct? 7 A. That's correct. 8 Q. All right. That's perhaps what I asked. 9 And again, I don't want to misread or try 10 to read into my notes, but after the 129 sites you 11 actually went from 30 down to 19 plus the periphyton? 12 A. After the 129 we used that ground truth 13 information to do supervised classification and -- 14 Q. All right. 15 A. -- came up with 19 classes. 16 Q. All right. 17 Now, in the -- your paper there's 18 discussion here with regard to preparing ellipses from 19 sample band combinations? 20 A. Okay. 21 Q. In Exhibit 1, as I understand it, you have 22 three bands for the satellite? 23 A. That's correct. 24 Q. Okay. 25 How do you go about comparing these 131 1 ellipses of sample bands, do you look at all three? 2 A. Yes, and combinations of all the bands, if 3 you find anything unique within any combination that 4 makes it separate. 5 Q. Okay. 6 And you have, if I recall correctly -- 7 Drawing your attention, just for a moment 8 if I could, back to what's marked as Exhibit 8, and if 9 you would turn to the back of that, Bates 1220026, 10 actually they skipped a page it's marked 4, but it's 11 between Page 1220026 and 27, and I know this is not 12 your piece, but is this essentially what you were doing 13 for the cattail paper, drawing this type of an ellipse? 14 A. The computer makes -- actually makes the 15 ellipse, but it is a fair analogy, yes. 16 Q. And is the computer able to do it for just 17 two bands at a time, does it do all three bands at 18 once? 19 A. It does two bands at a time. 20 Q. Okay. All right. 21 Do you have a file showing that type of 22 information, the ellipse and comparison of the bands? 23 A. Yes, it's all digital. 24 Q. All right. 25 So we don't have a hard copy of that? 132 1 A. No. 2 Q. All right. Get back to where I was. 3 Once the computer does that, does the 4 computer statistically determine which ones are close 5 enough to do vegetative identification or is that 6 something that the operator or the scientist doing it 7 does? How is that done? 8 A. Well, I think it's a combination of the 9 two, where the computer generates the ellipse, you 10 analyze the data, determine, to see if there's overlap 11 between the ellipses or whether, indeed, we have unique 12 spectral characteristics for selected classes of 13 vegetation. 14 Q. Okay. All right. 15 Who did the review of the ellipses, was 16 that you or Mr. Vilchek? 17 A. That's me. 18 Q. All right. All right. 19 Now with regard to the color infrared 20 photography that you obtained for October 10, '91, 21 okay. 22 A. No -- October 10? 23 Q. Of 1991. 24 A. Color infrared? 25 Q. Yeah. 133 1 A. Oh, maybe it was that day. I said it was 2 within a year, okay. It's fair. 3 Q. Okay. All right. 4 Did you go through and attempt to locate 5 the color infrared photos that had the 129 points, is 6 that how you went about doing this or is it a different 7 method? 8 A. I think we used that as an aid in the 9 process, looking at that photography. It was just an 10 extra piece of detail. We didn't rely on it too 11 heavily. We mainly used -- we drove this process 12 digitally basically, but that was an extra data set 13 that it was -- that it was referred to it, yes. 14 Q. Okay. 15 Was -- just so I understand how you used 16 it, so whether or not you were doing a homogeneous 17 community or were you actually able to do vegetative 18 identification with the infrared photography? 19 A. Basically I think when we used it it was 20 like, for instance, when we had the periphyton problems 21 we looked overall, we could see periphyton in the south 22 end, and I don't think we used it too much in the 129 23 ground truth sites. 24 Q. Okay. 25 Now, with regard to 20 classes then, and 134 1 I'm just going to use the -- where is the one we have 2 marked? 3 Drawing your attention in Exhibit 1 to Bates 4 Page 1220435, Page 17 of the document, you have 20 5 listed right there. The sawgrass dense, is there a 6 percentage coverage that was used for that? 7 A. Yes, it's a table that goes along with 8 each of these classes. 9 Q. Actually let me find -- and that table is 10 at Page 19, also Bates No. 1220437? 11 A. Yes. 12 Q. Okay. 13 Now with regard to that, it refers to 14 greater than or equal to 70 percent evenly distributed; 15 the balance in open water. Okay. 16 What are the types of vegetation you would 17 have out in 2A other than sawgrass and open water? 18 What mixes would you find, if any? 19 A. I think this list here pretty well 20 characterizes the types of vegetation you would see in 21 Area 2A. 22 Q. Okay. 23 That would be sawgrass in open water, 24 sawgrass and cattail interspersed to varying degrees, 25 sawgrass/cattail and brush, sawgrass/brush, 135 1 sawgrass/broadleaf and cattail. And broadleaf, what 2 type of plants were those? 3 A. Sagittaria species or Pontederia species. 4 Q. Is that like a water plant? 5 A. Yeah, I would say it's a -- it's a wetland 6 species, yes. All the -- all these are pretty much 7 wetland species. 8 Q. And again, it may sound silly, I know what 9 sawgrass looks like, I know what cattail looks like, I 10 know what they would look like. Are these, the 11 broadleaf, are these low in the water type plants or 12 are they, again, grass macrophyte-type plants? 13 A. They're -- they could be, I'd say, average 14 two to two and a half feet, maybe 3 feet. And we would 15 call them broadleaf because the leaves on them were 16 rather broad. 17 Q. Okay. 18 Do you have any low water type plants? 19 You know what I mean by that? 20 A. Are there any occurring in -- 21 Q. Bladderwort. Did you have bladderwort in 22 2A? 23 A. Bladderwort is a submerged species. 24 Q. Okay. 25 A. It occurs throughout the area, yes. 136 1 Q. All right. 2 Does that, the bladderwort, if it's there 3 with the sawgrass, do the two cohabitate in various 4 communities? 5 A. Yes. 6 Q. Does that affect the spectral signature? 7 A. I don't think so, because it's submerged. 8 Q. Okay. 9 So does the depth of the water affect the 10 spectral signature? 11 A. It could, yes. 12 Q. How could water depth affect the spectral 13 signature? 14 A. Based on whether you have ground exposed 15 and you have periphyton out there, it's to what level. 16 Sometimes periphyton is floating, sometimes it's at the 17 bottom. So, you know, that could really affect the 18 spectral characteristics of what you're seeing. That's 19 why you ground truth what you're actually seeing. 20 Q. Okay. 21 Would the bladderwort, if it's a submerged 22 plant, affect the spectral signature to the same extent 23 that water depth would affect the signature? 24 A. I don't think so. 25 Q. Okay. 137 1 Would you have sawgrass stands, be they 2 dense, moderate or sparse, going with periphyton? 3 A. Yes. 4 Q. Where would that fall in this -- the 20 5 classes? 6 A. We didn't break it down. We took a 7 dominant, if it was dominantly periphyton or all 8 periphyton. Typically, we broke it out and if it was 9 dense sawgrass, could possibly be periphyton in this 10 case or not, dense, sparse sawgrass -- 11 Q. And in cases where you had sparse sawgrass 12 and periphyton, what would it be listed as? 13 A. Now say that one more time. 14 Q. In a case where you had sparse 15 sawgrass/periphyton, which classification would it fall 16 into? 17 A. From our field we would -- we would 18 probably call that sparse sawgrass. 19 Q. Okay. All right. 20 Would that hold true also for cattail 21 sparse, cattail and periphyton? 22 A. Yes. 23 Q. With regard to sawgrass sparse, is that 24 equal or to 30 percent coverage, what is the low end of 25 30 percent? 138 1 A. I'm not sure. I think it was like five or 2 ten percent. 3 Q. Are there notes as to that low end, as to 4 what the low end was? 5 A. I'm sure they're somewhere. I -- I would 6 say less than 30 percent means from 1 to 30 percent. 7 Q. Okay. 8 Would that same definition hold true for 9 sparse cattail, 1 to 30 percent? 10 A. Yes. 11 Q. Okay. That's a broad question. 12 What difficulties did you find in mapping 13 the sparse sawgrass? 14 A. (No response.) 15 Q. You mentioned periphyton. Anything else? 16 A. I think the major problem I had in this 17 mapping out effort was the periphyton community, 18 because even though there might have been sawgrass 19 sparse or sparse cattail, the dominant signature still 20 came back as periphyton. That's why this map effort 21 mostly suffered in most of its inaccurate -- in its 22 overall accuracy is because of the periphyton 23 community. 24 Q. Was there any predominant place where you 25 had periphyton throughout WCA-2A? 139 1 A. In the southern region when we have a lot 2 of open slough areas down there, sparsely vegetated 3 areas. 4 Q. Okay. 5 Now, did the fact that you're using the 6 August SPOT imagery data set, compared to your field 7 trips which extended all the way through April of '92, 8 did the changes in water levels or vegetation as a 9 result of the dry season impact at all the study? 10 A. I don't think so. 11 Q. Okay. 12 Was there any way to test whether or not 13 it did? 14 A. No. 15 Q. Is there a difference in the spectral 16 imagery from August to, for instance, January or 17 February? 18 A. If you had satellite imagery, yes, 19 probably. 20 Q. Okay. 21 What would those differences be? 22 A. Basically vegetation goes through various 23 stages, different vegetation browning out or if there's 24 a drought some of it just dies out totally. So 25 hydroperiod and time of year can affect what you're 140 1 seeing in satellite imagery. 2 Q. Okay. 3 Does the time of year for the plant, as I 4 guess you put that, brownness, does that also impact 5 the reflective values and spectral imagery? 6 A. I think so. 7 Q. On the sites for the 241 points, my notes 8 are a bit confused. On that 241, when you're doing the 9 accuracy, was that based again upon a 3 pixel by 3 10 pixel or were those just randomly generated by the 11 computer without that, any of that type of requirement? 12 A. There was a stratified random sampling by 13 class. And yes, they had to meet a 3 by 3 meter, a 3 14 by 3 pixel minimum requirement. 15 Q. Okay. 16 On that, if I could draw your attention 17 back to Rutchey No. 4, that's the laboratory notebook, 18 and I believe you pointed out latter pages in this 19 document, essentially Bates No. 1202674 through the 20 remainder, 1202688, reflect the sites, the pixels based 21 upon the computer generation, and that -- then your 22 field data inspection; is that correct? 23 A. 4, Item 4 in the thing. 24 Q. The fourth item? 25 A. Is the field data. 141 1 Q. Okay. 2 Going through a, just to the first page, 3 1202674, Site 116, all 9 pixels are 4. The next one, 4 Site 196, it's a split of 5 and 4, 5 being 7, 4 being 5 18. And just randomly going through this, only 6 approximately 1 out of every 4 to 1 out of every 6 7 actually has all 9 pixels being the same. You have 8 having the same classification, that varies from page 9 to page. But does -- how would you deal with pixels 10 that did not have all 9 the same vegetation class? 11 A. I stated in the paper we used a minimum 12 of -- required minimum of 5 out of 9 meeting majority 13 status and called it, that pixel cluster that item, or 14 that classification. 15 Q. Okay. Perhaps I misunderstood that. 16 You're saying all nine did not require the 17 same classification, they just had to be a majority? 18 A. Majority. 19 Q. Okay. 20 Then, when you're doing your accuracy 21 analysis, would you be looking to see whether or not 22 the field test matched on all 9 pixels? 23 A. (No response.) 24 Q. In other words -- do you understand what 25 I'm saying? 142 1 A. Um-hum. 2 Q. As opposed to getting it to the point 3 which we believed to be in the middle pixel, would you, 4 as I understood it before, look at 20 by 20 when you 5 were doing your field tests for these 241, would you 6 look at all 9 surrounding, in other words, the -- all 9 7 pixels that you were analyzing? 8 A. We would look at what data we got back 9 from the GPS, correct the data. We would make a 10 similar 3 by 3 pixel representation as you see here, 11 pick the majority out of what it was and then look at 12 that majority value or classification and compared it 13 to what we got from the field. And if it was the same 14 we'd count it as correct, and if it wasn't, we counted 15 it as wrong. 16 Q. All right. 17 Just so I understand how this works then, 18 if you could go back to the second page of this 19 document, this one where we were looking at Site No. 4 20 originally right there. 21 A. Okay. 22 Q. And we had gone away from this because you 23 had thought we could look at another page earlier. You 24 have next to 4 in the 1, 2, 3, 4, 5, 6, 7, you have 7 25 columns, excuse me, rows, okay. And in the first, 143 1 fourth, and seventh you have noted in this case 1, 1 2 and 1 there. Are those the computer-generated 3 classifications for Site 4? 4 A. If I remember correctly -- I don't 5 remember. 6 Q. Okay. 7 To the right of that are then some 8 additional 1's. Again, they're in the first, fourth 9 and then there's one in the fifth and two in the 7th. 10 Are these again dealing with Site No. 4? 11 A. I believe so. 12 Q. Okay. 13 Does that refresh your recollection at all 14 as to how this was done? 15 A. Okay. 16 This is how it was done. 17 Q. Okay. 18 A. That's basically what this initial 4 19 data set was, we actually went and looked at 7 pixels 20 by 7 pixels instead 3 pixels by 3 pixels. What you see 21 here in this first part of this data set is that 22 representation. So let's go back to 4. Basically in 4 23 in the first column you see 1 at each one of the 24 corners. 25 Q. And 1 in the middle. 144 1 A. Right. So this basically, to me, 2 everything was 1. 3 Q. Now, is that computer generated? 4 A. That's computer generated. Now when, this 5 other one next to it, you see 1's in each corner, but 6 two 1's in the middle, you see 1, it's the whole -- 7 Q. Right. 8 A. The pixels in that area are something 9 other than 1, so what -- what this is, I went beyond 10 the original 3 by 3 in this particular data set. 11 Q. Okay. All right. 12 Just -- so you would then be looking at 13 the four corners, the middle points on the outside and 14 the center? 15 A. Right. But it was something other than -- 16 if the corner was something other than 1 I would put 1 17 here, I would put the next 1 in, so on and so on, if it 18 was other. 19 Q. Okay. 20 So for instance, on No. 4 I'm looking at 21 the right-hand side where this said Old 1. Okay. 22 A. Right. 23 Q. Looking at the upper left-hand, or where 24 it says 1 there, then four pixels in a box that are 25 blank, were those observed at all or or those would 145 1 automatically be taken as 1 unless marked otherwise or 2 just literally looked at 3, 6 points, 9 points. 3 A. No, I looked at all of them. I didn't 4 want to write 1's in every one of these little boxes, 5 so I made my own little method of how this -- how to do 6 it. And the one that you're pointing out -- 7 Q. Um-hum. 8 A. -- you see -- can see there's 1's in all 9 corners, but on the bottom one you see a 1 directly 10 below the middle pixel, that means everything behind 11 was something other than that. 12 Q. Right. 13 A. Weren't. 14 Q. Okay. Okay. 15 But, for instance, what about to the right 16 of where that pixel, that 1 would have been if it was 17 sawgrass? 18 A. To the right, if you look to the right and 19 there's a 1, then that means everything in between 20 between was a 1. 21 Q. Okay. 22 So everything blank other than the 1, for 23 instance, below those two double 1's are sawgrass, 24 dense sawgrass? 25 A. That's correct. 146 1 Q. Okay. 2 Is there any way to tell what the two 3 blank ones that we don't know what they are, what they 4 are that goes in those grids, what are the two missing 5 squares, what vegetation are they? 6 A. It's available digitally. 7 Q. Okay. 8 All of this data is available digitally? 9 A. Yes. 10 Q. Does the digital data contain more 11 information than that then? 12 A. Yes. 13 Q. Okay. 14 Just so I understand, the digital data set 15 then was not taken from those sheets, but rather this 16 is a summary of the digital data set? 17 A. This is created from the digital data, 18 right. 19 Q. Okay. All right. 20 When there's a discussion of map accuracy 21 of 81 percent in the paper, okay. And that discussion 22 was found at -- on Page 9 of Exhibit 1 which bears 23 Bates No. 1220427, 80.9 percent. 24 A. Okay. 25 Q. All right. 147 1 Is that an accuracy as to boundaries 2 reflected by the map or an accuracy as to vegetative 3 type within those boundaries? 4 A. That's an overall map accuracy of 5 everything within the boundaries. 6 Q. Okay. 7 Does the 80.9 percent apply to each class 8 of the 12 classes? 9 A. No, it applies to the overall map accuracy 10 of the whole vegetation project. 11 Q. How would you determine it as to the 12 various classes? 13 A. How would you determine the accuracy as to 14 the various classes? That was done for some classes, 15 if you look at 1220439, Table 3. 16 Q. Okay. 17 A. And you can see what -- the column, users 18 accuracy. We did that for some of them. 19 Q. Now, this shows all 241, all the -- all 20 the various samples there? 21 A. Yes. 22 Q. Would looking at this refresh your 23 recollection as to which classes were included in the 24 31 or 32 additional tests or sample sites? 25 A. No. 148 1 Q. All right. 2 Users accuracy tells you the accuracy of 3 whether or not the vegetative class that's actually 4 shown by the map is what's in the field, is that -- 5 A. (Shakes head up and down.) 6 Q. All right. 7 What does user accuracy mean? 8 A. I think you had hit a little bit. 9 Basically, if you -- if you point to an area on the map 10 you go out in the field to see if indeed that's what 11 you're seeing on the map is correct. 12 Q. All right. 13 A. Compared to to producer accuracy, the 14 producer accuracy, if you went out in the field and got 15 a GPS point and documented what you saw there, and you 16 went back to the map to see if that indeed was there. 17 Q. All right. 18 Why would that be different? 19 A. It's two different ways of looking at a 20 map. They're going to be different numbers. That's -- 21 I can't answer it any better than that. 22 Q. But is it still -- are you still 23 essentially just trying to figure out whether or not 24 the map reflects reality under both scenarios? 25 A. To a point, yeah. It's basically looking 149 1 at commission and omission errors. 2 Q. And the conditional KAPPA on the 3 right-hand side means what? 4 A. This is being used, now a KAPPA statistic 5 is being used to -- in image processing projects to 6 report the error. 7 Q. All right. 8 If I am reading your page, Bates No. 9 1220439 of Exhibit 1, if I'm reading this correctly, 10 your -- let me withdraw that. 11 When you say this is -- I'm looking at the 12 20 class map, 70.9 accuracy, is that average of 13 accuracy a producer accuracy? 14 A. No, I would say not. 15 Q. What does the 70.9 come into as compared 16 to user accuracy? 17 A. The 70.9 represents the overall map 18 accuracy as to the whole entire vegetation project. 19 User accuracy and producer accuracy has to be looked at 20 separately. 21 Q. All right. 22 How do you get then the overall map 23 accuracy? How do you calculate this? 24 A. Well, the KAPPA statistic takes into 25 account the user accuracy, producer accuracy, which is 150 1 really commission and omission errors and you have this 2 in KAPPA. 3 Q. All right. 4 It's -- in other words, it's a statistical 5 manipulation of the two to get what the overall 6 accuracy is? 7 A. What is your definition of overall 8 accuracy? 9 Q. All right. 10 That's on Page 1220439, overall accuracy 11 70.9 percent of a 20 -- 12 A. Basically, what that represents is an 13 overall map accuracy. How many out of that 241 points 14 that are visited in the field, what -- what percentage 15 of them were correct. 16 Q. Oh, okay. That's all right. That's fair. 17 Is there a means of determining that 18 accuracy on a class by class basis? 19 A. Yes, that's basically what user accuracy 20 is. 21 Q. Okay. 22 For user accuracy there are only six 23 classes that have a user accuracy number. Why is what? 24 A. You had to meet a minimum requirement of 25 numbers. I could find that for you. 151 1 Q. Okay. 2 (Thereupon, a discussion was held off the 3 record.) 4 THE WITNESS: Yes, yes. Page 7, second 5 paragraph are the results. In order to show any 6 significance or do it statistically right you 7 had to have a minimum of 19 field sites. 8 BY MR. KOBELINSKI: 9 Q. Okay. 10 But that's for user accuracy; is that 11 correct? 12 A. (No response.) 13 Q. Let me just make -- the reason I ask is, 14 for instance, on the producers accuracy, I see numbers 15 there for 15, 15, and 11. If you read that across from 16 on the 20 class map, 15 for Class 5, 15 is for Class 17 10, and 11 for Class 20. 18 A. Okay. 19 Q. Okay. 20 Is there a different minimum number for 21 user as opposed to producers accuracy? 22 A. Un-hum. I would say I'm not sure. I feel 23 the method that people who are experts in the field 24 such as Russel Congalton, Rosenfield, Lins-Fitzpatrick 25 (sic), Michael Story, people who have expertise in the 152 1 field, and I use their methods and -- 2 Q. Okay. 3 A. -- that's -- this is state of the art 4 here. 5 Q. Okay. All right. 6 Now, from this particular matrix, is there 7 a means -- I'm talking again on Page 21, Bates No. 8 1220439, perhaps the easiest example would be Map Class 9 1, Class 1, ground truth Class 1, and the number there 10 that says 41. It's on the exhibit. You following 11 where I'm at, upper left-hand corner of that? 12 A. Okay. 13 Q. Does that mean 41 sites, you went to 41 14 sites? 15 A. Okay. 16 Within Class 1 I visited 45 sites. 17 Q. I read it across then to 40 -- of the 45, 18 41 were Classification 1 based upon your field visit? 19 A. That's right. 20 Q. Two were Classification 2, and one was 21 Classification 4, one was a Classification 11? 22 A. Correct. 23 Q. Okay. All right. 24 If I recall correctly, you had stated that 25 you had tested an additional 31 sites dealing with the 153 1 cattail to better determine the accuracy of the model 2 with regard to the cattail? 3 A. That's correct. 4 Q. All right. 5 Given those additional 31 sites, if I read 6 this correctly, sawgrass/cattail dense and sawgrass 7 sparse, you don't actually have an accuracy figure, but 8 it was your recollection that those 31 sites didn't 9 include those two categories? 10 A. I think I said I wasn't sure. 11 Q. Okay. 12 Do you recall now or? 13 A. No. 14 Q. Do you believe that they did or just 15 really have no idea one way or the other? 16 A. I'd have to go back and look. 17 Q. Okay. 18 And with regard to the cattail, cattail 19 dense, cattail moderate, cattail sparse, the only one 20 that has sufficient is cattail dense? 21 A. In the 20 class map. 22 Q. Based upon that, were you able to 23 determine how accurate it was for cattail mapping 24 purposes? 25 A. I'd say, if you were looking just at dense 154 1 cattail, that cattail is -- on that we were right 68 2 percent of the time. 3 Q. Okay. 4 What about the other categories of 5 cattail? 6 A. For the 20 class map sawgrass/cattail 7 dense, 62 percent. 8 Q. All right. 9 And sawgrass/cattail sparse 58 percent? 10 A. Yes. 11 Q. Of the 17 samples of cattail, sparse, No. 12 12, only 7 came in correctly; is that right? 13 A. Yes. 14 Q. If I asked you to, given all the data 15 you've collected, would you be able to give me a 16 percentage of accuracy as to identification of cattail? 17 Not the different various categories, but just cattail 18 itself? Is there any way for you to determine that? 19 A. I would use the 12 class map to answer 20 that. 21 Q. Okay. 22 A. And No. 2, I would say overall for 23 sawgrass/cattail, I'd say that we were 70 percent 24 accurate. And for cattail by itself, we're 72 percent 25 accurate. And for cattail/brush we're a hundred 155 1 percent accurate. 2 Q. Okay. 3 That's where you're collapsing the three 4 cattail categories just into one category of cattail; 5 is that correct? 6 A. Yes. 7 Q. Okay. 8 (Thereupon, a discussion was held off the 9 record.) 10 BY MR. KOBELINSKI: 11 Q. All right. 12 Drawing your attention back to Exhibit 1, 13 Page 21, which is Bates No. 12200439, users accuracy is 14 essentially a -- just a simple percentage looking at, 15 you know, how many field -- how many sites did I check 16 that the computer told me was, for instance, 17 Classification 1, how many times was it correct. Is 18 that essentially correct, user accuracy is just a 19 percentage, right? 20 A. (Shakes head up and down.) 21 Q. Straight, simple. All right. 22 If I looked at map accuracy, overall 23 accuracy, 80.9 percent for the 12 class map, would that 24 be just doing that for every single one of the 25 classifications, again as a simple math on that, or is 156 1 it more complicated than that? 2 A. No, it's pretty simple. What you do is 3 look at the diagonal of the numbers that were correct. 4 Q. Oh, I never thought of that. Look at 5 that. 6 A. All right? 7 Q. Neat. 8 A. All right. 9 So I add those up up and you have 241, you 10 take that percentage of that and that's the overall. 11 Q. Kaboom. That's marvelous, that's great. 12 When we were discussing earlier accuracy 13 with regard to 20 class map, you had stated there was a 14 minimum number of 19 that was necessary, okay; is that 15 correct? 16 A. Right. 17 Q. All right. 18 Does that change if -- when you go down to 19 the 12 class map? 20 A. No. 21 Q. Okay. 22 The only reason -- it could just be that 23 you added this to a class, but Class No. 6 in the 12 24 class map you only had 12 sites and you had run it for 25 that particular class? 157 1 A. Well, you should have proofreaded (sic) my 2 paper. 3 Q. Well, that's just -- that's just pure math 4 anyway, just reading across. That technically can be 5 done for every column. If I understand you correctly, 6 for statistical significance you have to have 19 or 7 more samples. Is that essentially what' you've 8 determined? 9 A. Yes. 10 Q. Okay. 11 Now, with regard to the categories, I see 12 that you have on the immediately preceding page that 13 we've been looking at is where you collapsed 20 14 categories down to 12 categories. But just so I 15 understand the -- either the 20 or the 12, I'm looking 16 at Page 19 of this exhibit which bears Bates No. 17 1220437, and with regard to sawgrass/cattail dense, if 18 I understand the description you have there, which is a 19 mixture of Cladium jamaicense and Typha domingensis, 20 vegetative cover excludes aquatics greater than or 21 equal to 60 percent. In that category if, for 22 instance, the combined cattail/sawgrass was 90 percent, 23 it would fit within Category No. 4; isn't that correct? 24 A. If it was 90 percent? 25 Q. Of cattail/sawgrass, that would clearly 158 1 fit within that category? 2 A. Yes. 3 Q. All right. 4 What if it was 80 percent sawgrass and 10 5 percent cattail and 20 percent open water, that would 6 still be in Category 4? 7 A. Yes. 8 Q. What about the opposite, 10 percent 9 cattail, 80 percent sawgrass, 20 percent water? 10 A. Yes. 11 Q. What about the lower end of that, for 12 instance, what if it's one percent cattail, 89 percent 13 or 95 percent sawgrass and 4 percent water? 14 A. I believe it was 10 percent -- I'd have to 15 go back and look. 16 Q. Where would you look to see that? 17 A. Notes. I'm not -- Les probably has it, 18 that determination. 19 Q. Do you recall, since you have looked 20 through a fair amount, not in great detail, I 21 understand that, but you have looked through a fair 22 amount of documents that were produced, do you know 23 whether or not that would be reflected in what you sent 24 to us or produced to us? 25 A. I don't think so. 159 1 Q. But as you sit here you recall it being 2 approximately a 10 percent cutoff? 3 A. I think so. 4 Q. All right. 5 So, for instance, in either direction, if 6 it was 5 percent cattail and 95 percent sawgrass, that 7 would be marked as a pure sawgrass stand? 8 A. You might almost determine this from the 9 ground truth data sheets what the cutoff was. I think 10 we only -- it might even be down to 5 or 10 percent, 11 but I don't recall. 12 Q. Okay. All right. 13 Does the same analysis hold true for 14 sawgrass/cattail sparse? 15 A. (No response.) 16 Q. And by that I mean if, for instance, only 17 a 50 percent coverage and it's cattail and sawgrass, it 18 could either be 40 percent sawgrass and 10 percent 19 cattail or the opposite 10 percent sawgrass and 40 20 percent cattail? 21 A. Yes. 22 Q. All right. 23 Now, with regard to Category No. 6, that 24 one is, you know, perhaps this might be alone, but 25 that's very specific as to how many -- how that 160 1 sawgrass/cattail/brush is divided up. That's not just 2 any combination of them, if I understand correctly. 3 A. Right. 4 Q. All right. 5 It's greater than or equal to 70 percent 6 sawgrass and less than or equal to 30 percent cattail 7 brush, or cattail or brush? 8 A. Right. 9 Q. Okay. 10 What would happen if you had 60 percent 11 cattail and -- I don't care, let's just hypothetically, 12 so we understand, 60 percent cattail -- excuse me, 13 sawgrass. 30 percent or 20 percent cattail, and 20 14 percent brush. Where would that show up in this? 15 Well, before I ask that hypothetical, 16 would you ever find a community like 60 percent 17 sawgrass, 20 percent cattail and 20 percent brush? 18 A. I'm sure it's possible. 19 Q. Do you recall ever seeing anything like 20 that? 21 A. I've seen vegetation mixed in all 22 different amounts. 23 Q. All right. 24 Given that, where would -- if I came 25 across this out in the field, where would I put that? 161 1 A. I need a pen. 2 Q. I'm sorry. 3 A. What now? 60 sawgrass, 20 cattail, 20 4 brush you want this? 60, 20, 20. 5 Q. Sawgrass/cattail/brush. 6 A. Okay. 7 I don't see a place to put that. That's 8 probably a function of we're not finding that 9 particular combination in our ground truth sites. 10 Q. Okay. 11 In the larger, if you go to larger 12 categories, would it fall in? I mean you obviously 13 have the detailed description of larger -- the 12 class 14 map, under a 12 class map, how would I determine the 15 description of the classes? 16 A. Well, you -- like for sawgrass, you know 17 that it's basically dense, moderate, and sparse 18 vegetation. You just would take the present class map 19 and combining it all together and that would equal 20 sawgrass in the 12 class map. 21 Q. Okay. 22 So for instance, when -- the one I just 23 gave, 60 percent sawgrass, 20 percent cattail, 20 24 percent brush, would that just fall into No. 2? 25 A. Well, I can't put it in anywhere, because 162 1 we didn't have that percentage as an actual ground 2 truth site, those percentages, so we didn't make a 3 category for it. 4 Q. Okay. 5 How did you, for No. 6, again, as I said 6 6 is perhaps the most detailed of your descriptions. 7 MR. CESARANO: On here, on this 8 classification? 9 THE WITNESS: 19? 10 MR. KOBELINSKI: Yes. 11 MR. CESARANO: Okay. 12 BY MR. KOBELINSKI: 13 Q. How did you come up -- for Classification 14 No. 6 on the 20 class, how did you come up with these 15 percentages? 16 A. Basically we would have looked at 129 17 ground truth sites and we -- from that we best 18 determined what we could break out as far as being 19 classes. And basically we used that information to -- 20 gathered information to seed the original multispectral 21 imagery to come up with unique statistical data. At 22 that point we didn't know if this was indeed unique. 23 When we actually looked at it using the ellipse command 24 when we ran ellipses, when we do the bands, red versus 25 infrared or red versus green band, we tried to see if 163 1 that would make it unique, and that's -- basically that 2 process drove it to the 19 classes. 3 Q. All right. 4 Now, if -- could you look at, pull out for 5 a moment No. 8, yeah. There it is, right in front of 6 you. And I'd like you to go to Bates Page 1220027. 7 Is that an original one that you have with 8 you? 9 MR. CESARANO: That might be mine. 10 THE WITNESS: That's not the original. 11 Nobody has the original except for me. 12 BY MR. KOBELINSKI: 13 Q. Okay. 14 Let me just -- we have a copy. Have you 15 experienced -- I mean you've got copies of this before, 16 but notice how the colors aren't coming out exactly the 17 same. Is that just a function of the copying? 18 A. Yeah. 19 Q. As far as -- have you experienced that? 20 A. I think so. 21 Q. Okay. All right. It's difficult for us 22 to tell. 23 Looking at -- looking at the 1991 map on 24 this page, where is the brush here? Where did you see 25 brush? 164 1 A. Personally I don't ever look at my data 2 like this. 3 Q. Okay. 4 A. This is -- this for a final representation 5 of something to show because we can't give them a 6 computer, so they can say give me all brush out of 7 this. 8 Q. What, for instance, if you're looking at 9 the actual photo digital set, you just type in brush 10 and it comes on screen without any other colors? 11 A. Basically that's pretty much it, yeah. 12 Q. Okay. 13 To your recollection then, since we don't 14 have that capability right here, on the 1991 map, as I 15 understand this, the 1991 map is based upon your WCA-2A 16 paper; is that correct? 17 A. Right. 18 Q. Looking at the southern end of WCA-2A, is 19 that cattail or is it that brush do you recall? 20 A. On this map it's it's cattail. 21 Q. All right. 22 And if I understand your analysis of your 23 2A paper, that carries approximately an 80.9 or 80 24 percent accuracy of that being cattail all down there? 25 A. No. 165 1 Q. All right. Then I don't understand. 2 What accuracy would there be with regard 3 to cattail in that area? 4 A. Why don't we use the map that I generated 5 as opposed to the one that Jensen generated, because I 6 don't want to speak for his map. 7 Q. All right. Yours has 12 colors, it's 8 harder to see. All right. 9 Well, using yours, which would be on 10 page -- hold on, let me get to that. That's on Rutchey 11 Exhibit 1, and I believe you're directing us to your 12 Page 18, Bates Page 1220436? 13 A. That's correct. 14 Q. All right. 15 Now, are you able to tell from this -- 16 again the lower half of that, that's cattail? 17 A. That's what that map is depicting. 18 Q. Okay. 19 And under the overall accuracy, if I 20 understand it correctly, that means that 80.9 or 81 21 percent accuracy of that cattail, that lower half? 22 A. No. 23 Q. What is the accuracy of that cattail? 24 A. Okay. 25 Let's go back to this. I'm just going to 166 1 point something out here going from the 20 class map to 2 the 12 class map. We put a stipulation in here and in 3 our -- in the authors' view that there is on Page 9, 4 page nine, third paragraph down. 5 Q. Okay. All right. 6 But whether or not it's monotypic, there 7 is an 81 percent chance you have cattail in that area? 8 A. That's an 81 percent chance that if I go 9 for any pixel or location within this entire classified 10 image that it will be, correct. 11 Q. All right. Let me do it a different way. 12 Drawing your attention to a couple of 13 pages earlier than that, or is it perhaps just one page 14 earlier, your page 17 of Exhibit 1, Bates 1220435, this 15 actually has the cattail sparse and cattail moderate 16 indicated; is that correct? 17 A. That's correct. 18 Q. All right. 19 And if I understand correctly, what 20 percentage then chance is there this accurately 21 reflects the cattail that you found in the southern 22 half of 2A? 23 A. Well, if you look at user accuracy for the 24 12 class map, overall we have 72 percent so there's a 25 72 percent chance that if you go to an area that says 167 1 cattail that it's going to be correct in a 12 class 2 map. 3 Q. Okay. 12 class map. All right. 4 Is that 72 percent though influenced by 5 the overall accuracy of mapping the dense cattail? 6 A. I would say that that's possible. 7 Q. With regard to the transition zones where 8 you have sawgrass and cattail mixed -- and again, as I 9 understand it, this will not indicate whether we're 10 dealing with, you know, five percent sawgrass and 95 11 percent cattail or 95 percent sawgrass and 5 percent 12 cattail -- you have around a 60 percent chance of that 13 being accurate? 14 A. To which one now? 15 Q. I'm talking about the 20 class map. The 16 sawgrass and cattail mix. And we're talking dense or 17 sparse, either/or. 18 A. It appears to be about 62 for the dense 19 and 58 for the sparse. 20 Q. Okay. 21 Now the dense is located, let's see that's 22 No. 4. Is that, the dense located primarily, if I read 23 your map correctly, up below the 10 structures and then 24 a portion of it below the 7 structures? 25 A. Yes. 168 1 Q. Okay. 2 And now the No. 6 -- and again, I'm -- I 3 apologize, but I'm dealing only with colors as opposed 4 to on a computer I'd be doing something different. Do 5 I understand correctly with 6, with the 6 sawgrass/cattail/brush, that is primarily below the 7 S-10D and S-10C, and that then also again to the east 8 of the S-7? 9 A. (No response.) 10 Q. If I'm reading the colors correctly. 11 A. I would say it's below all three 12 structures in this region or here, the mid section 13 going from north to south, south of these structures 14 and then... 15 Q. And you're -- because there's some there, 16 is that what you're saying? 17 A. Now you said we're on sparse, right? 18 Q. I'm looking at No. 6, what I thought I had 19 mentioned was sawgrass/cattail/brush. 20 A. Okay. All right. Yes. 21 Q. Okay. 22 But -- so that's essentially, for the most 23 part, that's below S-10D and C and then to the right of 24 S-7? 25 A. Right. 169 1 Q. On those areas, if I read the description 2 correctly, are greater than or equal to 70 percent 3 sawgrass and the remainder is a mixture of cattail and 4 brush? 5 A. That's correct. 6 Q. And the gray which surrounds it goes then 7 further down, a mixture of sawgrass and cattail without 8 any means of determining the percentages. Did you 9 attempt to -- I mean, for instance, in going out and 10 doing your sampling, did you attempt to break apart or 11 get more specific in the sawgrass/cattail mixes? 12 A. As stated previously, I can't recollect if 13 the 31, if the additional 31, 32 additional classes 14 that we went out, whether that was -- 15 Q. I didn't explain myself well. In the 20 16 classes you have sawgrass/cattail mix dense and 17 sawgrass/cattail mix sparse, these are 4 and 5. 18 A. Okay. 19 Q. But the dense and sparse actually refers 20 to the overall vegetative cover as opposed to the 21 percentages between cattail and sawgrass. Do you 22 understand what I'm saying? 23 A. No. 24 Q. Okay. 25 Well, the description on sawgrass/cattail 170 1 dense says vegetative cover excluding aquatics, is 2 greater than or equal to 60 percent. 3 A. Okay. 4 Q. But it does not get into a breakdown 5 between how much is cattail, how much is sawgrass. 6 A. Okay. 7 Q. All right. 8 So, for instance, on sawgrass/cattail 9 dense, if I was mapping sawgrass it would probably be 10 fair to include that as sawgrass if I look at change in 11 sawgrass, because for all we know, 85 percent of it 12 could be sawgrass with 15 percent cattail, or likewise, 13 if I was looking at mapping cattail I could do it the 14 other way, because I don't know if it's 85 percent 15 cattail or 15 percent sawgrass. Where would you fit it 16 in if you were going to analyze sawgrass and cattail 17 change? 18 A. Fit what in? 19 Q. That category, sawgrass/cattail mix. 20 A. It could be in this -- okay, dense, it's 21 greater than 60 percent and it's a composite of 22 sawgrass and Typha domingensis. 23 Q. Dense is just referring to percentage 24 cover, not percentage cover of cattail or percentage of 25 sawgrass? 171 1 A. That's correct. 2 Q. Just vegetative cover? 3 A. Right. 4 Q. Did you attempt at all to see if you 5 could, spectrally with the imagery, identify 6 classifications within the mix, sawgrass/cattail for 7 instance, greater than 50 percent sawgrass, less than 8 50 percent cattail? 9 A. No. 10 Q. You didn't attempt to do it at all, or 11 just it couldn't be done? 12 A. We used, on the original 129 ground truth 13 data sites, the information from that to determine 14 these classes. And I -- we didn't try to break it down 15 out by density function because, as you can see from 16 the 12 and 20 class map, when you start breaking things 17 out, single species or mixed species by how dense they 18 are, you know, you end up having more error. 19 Q. But, for instance, we were just looking -- 20 that's what I tried to see, if we could draw any 21 conclusions in No. 6, the sawgrass/cattail/brush 22 mixture which if there's a large stand of -- it's in 23 the middle of sawgrass/cattail mixture, we know that's 24 over 70 percent sawgrass; right? 25 A. Yes. 172 1 Q. Okay. 2 Where would I find the initial 30 classes? 3 Is that somewhere around? The computer originally 4 generated it, I think it was. 5 A. Yes, it's in digital. 6 Q. Okay. 7 Did you -- when the computer generated 8 that 30 it didn't say Class 1 sawgrass dense, I mean it 9 just says here are 30 classes, is that -- 10 A. That's correct. 11 Q. All right. 12 Did you -- you went off to the field, you 13 look for these 30 sites, essentially try to pick 150, 14 you got down to 129. Did you literally end up with 30 15 specific classes you identified? 16 A. No. 17 Q. I don't think -- I'm maybe not explaining 18 myself. I guess the question is, did you at one point 19 actually have 30 defined classes which you then 20 narrowed to 19 plus the periphyton, or did you -- did 21 you just determine you could only identify 19 classes 22 then plus periphyton? 23 A. I did an unsupervised classification, 24 broke it down out into 30 clusters, used that ground 25 truth I used for analysis and applied it to the 173 1 supervised classification and came up with a final 2 classified map composed of 19 classes. 3 Q. Okay. 4 So there are 30 -- that's why I was, 5 perhaps when I was asking the question I kept saying 30 6 classes, you use clusters, now that's a distinction you 7 were drawing? 8 A. Yes. There weren't 30 classes, there were 9 30 clusters. Classes, clusters, the word can be used 10 interchangeably in the analysis. 11 Q. But 30 clusters weren't defined as, for 12 instance, those descriptions of what the classes are? 13 A. No. 14 Q. Okay. 15 Based upon your review of ellipses -- 16 remember we talked about that -- do you recall whether 17 or not you can actually break apart these mixtures of 18 sawgrass/cattail whether you can break it down into -- 19 into whether you have over 50 percent cattail, less 20 than 50 percent cattail sawgrass? 21 A. It's possible, but I just used the 129 22 original ground truth site information, that's what I 23 used. I didn't try to go in and break out density 24 functions within -- well, I take it back. I did try 25 that, but I found that's where a lot of error can occur 174 1 if you try to break out the density function of a 2 single class such as sawgrass dense, moderate, sparse. 3 Q. Okay. All right. 4 Looking at the map, the final map of the 5 12 classes which is on Page 18, again, I'm dealing with 6 colors, it's difficult to tell, tree island there 7 actually appears, I guess from both of our maps, there 8 are only a few communities up in northern 2A that are 9 still classified as tree islands? 10 A. Tree islands, right. 11 Q. And there's no way to -- well, I guess 12 there is. Where is Exhibit 1? This isn't a color one. 13 Well, the ellipsoid or teardrop shaped 14 areas that appear to be tree islands out in the middle 15 of 2A, those are no longer healthy tree islands? 16 A. I would say no. 17 Q. Are those primarily cattail or brush or 18 what are they? 19 A. I would say they're composed of tree 20 island, sawgrass brush mixture 1, where if we were 21 going to use the 12 class map we'll -- you'd say 22 sawgrass brush, possible tree island and those are the 23 two major ones. 24 Q. Okay. 25 Looking at Exhibit 8 for a moment, I 175 1 apologize for jumping back and forth, but your work was 2 the foundation for 8, so I need to at times go back and 3 forth to understand what was done. 4 On Page 20, which is Bates No. 1220020, 5 there is a calculation by hectares of the brush, 6 brush/cattail, cattail/sawgrass and sawgrass/cattail. 7 Is that something you also did in relation to your 8 mapping of of 2A? 9 A. Yes, basically it's Table 2, page 20. 10 Q. On Exhibit 1? 11 A. Exhibit 1. 12 Q. But that -- 13 A. The numbers in parentheses represent 14 hectares. 15 Q. Thank you. All right. 16 I need to switch gears for just a moment 17 with regard to the Exhibit 8. And I believe you had 18 stated you had provided Dr. Jensen with the five 19 digital data sets for the five maps, okay. 20 Did you ever do any analysis of those maps 21 to determine vegetative mapping from them? 22 A. Just the 1991, 8-10-91, my data set. 23 Q. Okay. 24 Did you ever review his work to determine 25 its accuracy or understand it? 176 1 A. No. 2 Q. Okay. 3 Have you ever worked with the LandSat MSS 4 imagery? 5 A. Very briefly. 6 Q. Okay. When was that? 7 A. Back initially, probably 1987, when I 8 first started looking at remotely sensed data sets I 9 just basically was looking at it, trying different, 10 various image processing techniques on it. 11 Q. Okay. 12 And am I correct you selected the SPOT 13 imagery over the LandSat MSS for a reason? 14 A. Yes. 15 Q. What was that reason? 16 A. Better resolution. 17 Q. With a 20 by 20 as compared to 79 meters 18 by a 79 meter picture? 19 A. That's correct. 20 Q. You had mentioned that during the period 21 of time, '81 through '85, you had done some vegetative 22 mapping with using helicopters. Did you ever -- I 23 believe you stated that it was contained primarily in a 24 report out here. Have you ever attempted to compare 25 your mapping from the helicopter to the maps in the -- 177 1 in your report which is Exhibit 8? 2 A. No. 3 Q. Okay. 4 (Thereupon, a discussion was held off the 5 record.) 6 BY MR. KOBELINSKI: 7 Q. Just a few questions from my notes with 8 regard to the data you sent to Dr. Jensen. 9 You stated you sent to him the data from 10 the 129 site visits or site investigations. Did you 11 also send him the data from the 241 field sites? 12 A. Yes. 13 Q. Okay. There was perhaps an inaccuracy in 14 my notes. 15 Now, this is sort of a broad question, but 16 without going into it heavily, in Exhibit 5, in the 17 laboratory notebook we were looking at -- and there's 18 really no need to pull it out, but how -- the 9 pixel 19 often had more than one vegetative class in the pixel. 20 However, when you went and produced a map similar to, 21 for instance, the one on Page 17 of Exhibit 1, Bates 22 No. 1200435, you don't see that much in the way of 23 variation. There is some, but how does the computer, 24 when it's doing colors, just take a predominant, like 25 within a, for instance, a 9 pixel, how does it do that, 178 1 create the map? 2 A. The final -- all that is going through an 3 algorithm. It's a -- it's a smoothing out of the 4 entire -- it takes out the salt and pepper effect so 5 that visually it looks pleasing, as you know, if you -- 6 Q. As opposed to just a scattering of colors, 7 little dots? 8 A. Right, right. And that's perfectly 9 acceptable, that's what everyone does. It's -- we 10 still have the original digital data. 11 Q. Okay. 12 I would assume then that when you 13 calculated the hectares or hectares or whatever the 14 correct pronunciation is of each category, that was 15 based upon the 20 by 20 pixels, not the smoothed or how 16 do you -- 17 A. It's based on the unsmooth data, right. 18 Q. Okay. All right. 19 With regard to -- and perhaps this is 20 going off the 2A paper, but with regard to Exhibit 8, 21 Dr. Jensen's collaboration with you, who selected the 22 four additional dates to look at? 23 A (No response.) 24 Q. You had the data, I believe you testified, 25 but who went back and selected those dates? 179 1 A. I believe he did. It wasn't me. 2 Q. Okay. 3 You didn't participate in that selection? 4 A. No. 5 Q. Okay. 6 As a follow-up on the -- on the GPS, when 7 I believe you went -- said you went to a number of 8 known benchmarks, is that what they're called, or known 9 stations with known positioning accuracy; is that 10 correct? 11 A. Right. 12 Q. When you did that would you hover or would 13 you land at those sites? 14 A. Those sites we actually went to physically 15 on the ground. 16 Q. Okay. 17 And in the helicopter would you always 18 hover or would you land? 19 A. I would say that we didn't do it every 20 single trip. 21 Q. You lost me. 22 A. We didn't actually go to a known control 23 every single trip out of all the trips we took. It was 24 intermittently throughout the process. 25 Q. When you were using a helicopter and 180 1 visiting 129 sites or, for instance, 241 sites, did 2 you, in the helicopter, would you ever land or would 3 you always just hover over the site? 4 A. Hover. 5 Q. Drawing your attention to Exhibit 1, Page 6 9 and if you see at the bottom there it says 7 interpretation of final maps, I want to draw your 8 attention immediately preceding that there is a 9 discussion there with the regard to the -- the 10 difficulties caused by the bright signature of floating 11 periphyton. And you conclude that there may be 12 infrequent times when periphyton is either absent or 13 submerged which would mask this problem. 14 Are any particular times you had in mind 15 that would be -- would allow for that problem to be 16 avoided or perhaps lessened? 17 A. Oh, okay. 18 Q. I didn't let you get to the page, did I? 19 A. Yeah. I would say in South Florida 20 periphyton tends to float in the summer months, and in 21 the winter, depending on hydrology of the area, could 22 be totally absent if there -- if the area gets pretty 23 dry, even then though it could, if it goes dry, it 24 forms almost like a calcareous, crusty surface that's 25 white in appearance. 181 1 Q. Would winter months then be a -- perhaps a 2 time when you would have less of the brightness from 3 the periphyton? 4 A. It's possible. If there's water on, 5 covering it, most of the area, then it would be at 6 the -- most likely at the bottom. Not too much of it 7 floats up in the winter months. But the drawback of 8 collecting satellite imagery in the middle of winter is 9 that vegetation isn't at its best as far as 10 differentiation. It will sometimes, if we have a 11 freeze, it tend to all brown out and look the same. 12 Whereas, in spring, and up almost through early fall, 13 you have a unique differentiation in spectral 14 characteristics of vegetation, it's at its most robust 15 growing stages. 16 Q. Are there particular times of the year 17 then that for different vegetative classes it would be 18 better to look at? 19 A. In my opinion, from spring to early fall 20 is the best. 21 Q. For all classes? 22 A. Yes. 23 Q. Other than periphyton? 24 A. Yeah. 25 Q. Okay. 182 1 A. Periphyton is not really a vegetation, 2 it's like an algae. 3 Q. But periphyton can mask during that period 4 is what you were saying? 5 A. Yes. 6 Q. Okay. 7 Spring meaning what? 8 A. I'd say, depending on the previous winter, 9 it's going to depend on freezes, it would be as early 10 as March and go as late as, again depending how cold 11 fronts move through, it gets as late as September 12 November. 13 Q. Okay. 14 And would that hold true with regard to 15 cattail and sawgrass then, that during the -- for 16 instance, you did August, would that be about the best 17 time, in your opinion, for distinguishing cattail and 18 sawgrass? 19 A. I would say in that range. If you look at 20 all the preceding data the hydrology and cold fronts. 21 Q. Okay. 22 A. That happens to be worse time of the year 23 to, also to acquire satellite data in South Florida. 24 Q. Because of the cloud cover? 25 A. That's right. 183 1 Q. Having done this, is there a particular 2 class of vegetation that you believe is the easiest to 3 map in the Everglades? 4 A. Well, I looked at it as a total project, 5 mapping the vegetation. I wasn't looking for any one 6 particular species to map. I wanted a clear picture of 7 what was there on the ground before I started doing 8 this work. And we did just look at specifying things 9 like cattail. This is like back when I first started 10 learning image processing, when we were doing it and we 11 would try to pick out one specific species. People do 12 that. But on this project I looked at everything as 13 equal and I just wanted to do a realistic 14 representation of what was on the ground. 15 Q. Okay. 16 Well, see if we are doing this clever 17 technique, looking at the diagonal, looking at the 12 18 category map, looking at Page 21 of Exhibit 1, Bates 19 No. 1220439. I have to add up these numbers again. 20 If you add up on this wonderful diagonal 21 all the numbers, you come up with 195. Which, of 22 course, then if you divide 241 you actually come up 23 with 80.91 percent, which is exactly what you have, 24 80.91 percent. Now, if I exclude Category 1, in other 25 words, your mapping of sawgrass from that, I take 195 184 1 correct identifications, subtract out 99 which leaves 2 me with 96 correct identifications, and then divide 3 by -- I assume I divide by 140; is that correct? 241 4 less 101 or do I -- is it 241 less 99? 5 A. You'll have to tell me, because I wouldn't 6 do this. 7 Q. Okay. 8 Well, I'm just trying to look at your 9 overall accuracy for all categories, for all categories 10 but sawgrass. How would you tell me -- 11 A. For sawgrass? 12 Q. No, for everything but sawgrass. I want 13 to know what the accuracy is. 14 A. I don't think I can tell you just looking 15 at this data that's provided. 16 Q. Well, why not? What else would you need 17 to know? 18 A. Because this data is looking at the whole 19 entire area, I mean not looking at one specific 20 species. 21 Q. Well, user accuracy, you've used simple 22 math to tell me it's 70 percent accurate at mapping 23 sawgrass/cattail and 72 percent at cattail, and that's 24 again just using simple math. I'm just trying to, if 25 you take out sawgrass, determine what would be the 185 1 overall accuracy for all other species. 2 A. I don't know how to determine that. 3 Q. Couldn't you just take out the sawgrass 4 category? 5 A. I'm not sure. 6 Q. Well, let me ask you this, if your 7 instruction was to map every category but Category 1, 8 would you come up with the same map, just with a lot of 9 blanks in there? 10 A. How would I map everything but Area 1? 11 How would I know how to mask it out in the imagery if I 12 didn't know what it was? 13 Q. Well, you can identify it, but I'm saying 14 once you identified it you can mask it out. Could you 15 go to the computer and ask it to give you a map of 16 Categories 2 through 12? 17 A. Yes, that is after the fact, after I've 18 classified it. 19 Q. Yes, I understand that, okay. 20 And once you have that map, could you 21 determine what the accuracy of those categories are? 22 A. I'm not -- I'm not sure. 23 Q. Okay. 24 A. This gets into some pretty heavy 25 statistics. I'd have to go back and read. It might -- 186 1 it might be simple statistics, but I'm not going to 2 guess. 3 Q. Well, I'm not asking you to guess, but I'm 4 just saying how would you go about determining accuracy 5 of your mapping of Category 2? 6 A. On the 12 class map? 7 Q. Um-hum. 8 A. My accuracy? 9 Q. Um-hum. 10 A. I would say it's 70 percent. 11 Q. But you did that by saying that out of 50 12 sample you were able to -- 35 were mapped correctly; is 13 that right? 14 A. Right. 15 Q. You just divided it out? 16 A. Right. 17 Q. Okay. 18 What about with regard to Category 5? 19 What's the accuracy? 20 A. 72. 21 Q. Okay. 22 You did that based upon out of 36 samples 23 26 were correct; is that correct? 24 A. That's correct. 25 Q. All right. 187 1 Now with regard to overall accuracy of all 2 12 categories, that's 80.9 percent; is that correct? 3 A. That's correct. 4 Q. And you did that by adding up all the 5 correct hits which were 195 and dividing by 241? 6 A. That's correct. 7 Q. All right. 8 Now if I want to know just Categories 2 9 through 12, wouldn't I follow the exact same thing 10 you've done following the rows,, et cetera, just add up 11 everything but Category 1 and divide by the number of 12 attempts? 13 A. I'm not sure. I'd have to go back and 14 read. 15 Q. Well, what you would read? 16 A. I want to know what's the legitimate thing 17 to do. You're telling me. You're not an expert, so I 18 don't know if your way of looking at is correct. And I 19 don't know in my head if it's correct, so I'm not going 20 to say that you're correct. 21 Q. Okay. All right. Fair enough. 22 If you reclassed 2 through 12 as one class 23 similar to your reclassifying the 20 classes into 12 24 classes, all right, so now you end up with a 2 class 25 map -- 188 1 A. Now say that one more time. 2 Q. You reduced your 20 classes into 12 3 classes; is that correct, by adjoining certain classes? 4 A. That's correct. 5 Q. What if we reclass a 12 class map into 2 6 classes, one being Category 1 and other one being 7 Category 2, and Category 2 being what is currently 8 Categories 2 through 12. Would you then be able to 9 determine the user accuracy for your new Category 2? 10 A. I wouldn't do that. 11 Q. Well, you did 12 from 20. 12 A. Because it made sense to take like species 13 or same species that have different densities within 14 the environment and clump it together. It doesn't make 15 sense to take different species of vegetation and clump 16 them together. That just doesn't make sense to do 17 that. Why would I do that? 18 Q. Well, why did you start with 20 classes 19 instead of 12 if there weren't differences between the 20 classes? 21 A. Because I worked with all the ground truth 22 information I had available to me and came up with the 23 initial 19 and added one additional, came up with 20 24 class map. 25 Q. Okay. 189 1 Then why reduce down to 12? If you saw 2 distinctions between 20 different classes why did you 3 just go down to 12? 4 A. Because I wanted to see if the error that 5 was associated, the margin of error that was associated 6 in the 20 class map was a function of trying to break 7 out the densities, characteristics of individual 8 species such as sawgrass, dense, moderate and sparse. 9 I wanted know from that the problem. That, in my mind 10 that made sense, because it's all one species and is 11 the satellite imagery able to tell that boundary of 12 density within that species and -- 13 Q. But sawgrass dense, moderate, and sparse 14 had your highest accuracy in the 20 class map? 15 A. That's correct. 16 Q. Well, then, how could that account for 17 your inaccuracy -- let me rephrase, maybe I 18 misunderstand what you were saying. 19 Why would you collapse down sawgrass if it 20 has the highest accuracy in 20 classes? 21 A. I didn't just do it for sawgrass. I did 22 cattail, sawgrass/cattail mixture, whatever the other 23 ones that are shown on Page 20 of Exhibit 2. 24 Q. Okay. 25 Well, look at the 20 class map which is 190 1 the Category 1, it had sawgrass dense, 91 percent 2 density; is that correct? 3 MR. CESARANO: The 12 or the 20? 4 BY MR. KOBELINSKI: 5 Q. The 20. 6 A. The 20. 7 Q. Yeah, the overall accuracy is better than 8 12 class. I'm just talking about overall accuracy of 9 the 12 class map. 10 A. I don't think you can look at it that way. 11 Q. Okay. Why not? 12 A. I'd have to read about that. You're -- 13 you're comparing a single species classification 14 accuracy to the overall accuracy of the collapsed map 15 of the same original work. You're trying to make a 16 comparison, it doesn't make sense to me. 17 Q. All right. 18 Would it have improved the overall 19 accuracy of the map if you had combined categories, 20 original Categories 4 and 5, which included sawgrass, 21 with sawgrass in the 12 category map? 22 A. I thought we broke it out based on things 23 looking similar. And sawgrass is unique and we 24 considered sawgrass/cattail to be unique. And when we 25 collapsed them we kept all the sawgrass together and 191 1 when we collapsed sawgrass/cattail we kept it 2 altogether. 3 Q. Well, I understand that, but you also 4 thought it was unique when you prepared the map using 5 20 categories, didn't you? 6 A. Yes, it was unique. 7 Q. But you had three different categories for 8 sawgrass, sawgrass/cattail dense, sparse and then 9 sawgrass/brush, all three of these being unique 10 categories. 11 A. That's correct. 12 Q. All right. 13 Then I'm at a little bit of a loss as to 14 why collapse them if they're unique. 15 A. To see -- I'll answer this again, this has 16 already been asked and answered, but I wanted to see if 17 the inaccuracies that the 20, original 20 class map was 18 trying to break out density functions within a single 19 species such as sawgrass dense, moderate and sparse. 20 And that was where most of my error was associated 21 with. 22 Q. Okay. 23 But you didn't just break out the single 24 species. I guess that's where I'm getting confused, 25 because you also combined other species into one class, 192 1 for instance sawgrass/cattail mixture is combined three 2 different ones which include brush. 3 A. But it's also all similar. So sawgrass 4 dense, moderate, and sparse goes to 1, sawgrass, 5 sawgrass/cattail mixture dense and sparse and 6 sawgrass/cattail/brush mixture go to sawgrass/cattail. 7 It makes sense. I don't understand what your problem 8 is at this point. 9 Q. Okay. 10 Well, what did you conclude then going 11 from 20 to 12 was the inaccuracy of the map due to 12 attempts to distinguish between dense and sparse 13 vegetation? 14 A. Overall accuracy was appreciably increased 15 by 10 percent. But, I have to go back and read this. 16 When you look at KAPPA statistics there's a test that 17 you can see if there's a significant difference between 18 the two maps. 19 MR. CESARANO: Page 7 or 6? 20 THE WITNESS: It's a pairwise test. I'm 21 going read it almost word to word. If you look 22 at Page 6, at the bottom, last two paragraphs, 23 and then top of the Page 7 that explains what 24 I'm -- if you want me to read it, I'll read it. 25 193 1 BY MR. KOBELINSKI: 2 Q. Okay. 3 Is your conclusion that there is a 4 difference, statistical difference between the two? 5 A. No. 6 Q. All right. 7 I guess it's no significant difference? 8 A. That's correct. 9 Q. All right. Okay. 10 I guess my question then is, why did you 11 include the 12 vegetation map? 12 A. I thought it was a matter of interest to 13 people who were interested in this kind of research to 14 see the method that I used to determine that this 15 overall process of looking at the two maps and 16 considering the density function within a species might 17 have been a cause for my error in my initial map. I 18 wanted to show the steps I went through to try to show 19 what I did and I think it was -- well, it got accepted 20 for publication, so I think they thought it was 21 interesting. 22 Q. Is it based upon though -- that there's no 23 statistical difference, does that mean then the 20 24 category map is as accurate as 12 category map? 25 A. I would say that's a fair statement. 194 1 Q. Okay. 2 Why didn't you use the 20 categories to 3 Exhibit 8, the -- Dr. Jensen's study with you? 4 A. You're going to have to ask Dr. Jensen. 5 Q. Let us move on to another area. 6 (Thereupon, Mr. Birch left the room.) 7 BY MR. KOBELINSKI: 8 Q. As I understand from this morning's 9 testimony, you've also been involved in vegetative 10 mapping of the Holeyland; is that correct? 11 A. Yes. 12 Q. When did you start doing that? 13 A. I think initially when we acquired the May 14 1992 SPOT satellite imagery. 15 Q. Had you done any other vegetative mapping 16 or analysis of the Holeyland prior to your obtaining 17 the SPOT imagery? 18 A. No. 19 Q. Let me look through my notes so I don't go 20 over it. 21 According to my notes I don't think we 22 really discussed the Holeyland, so I'm -- I'm trying 23 not to repeat myself, but after obtaining the May 1992 24 SPOT imagery, what did you do with regard to the 25 Holeyland? 195 1 A. I did some very preliminary data analysis 2 of the imagery. I rectified the imagery. I broke 3 something out of the imagery through that preliminary 4 process and then I just sort of stopped at that point. 5 Q. Okay. 6 Are you still attempting to map the 7 Holeyland? 8 A. I've heard recently that I might be put 9 back on that. 10 Q. Did you actually produce any type of 11 Holeyland vegetative maps? 12 A. Just -- just depicting cattail. 13 Q. Okay. 14 What are those maps from? 15 A. Actual field reconnaissance using GPS. 16 Q. Is this in relation to the May 92 SPOT 17 imagery? 18 A. No. 19 Q. Okay. 20 When did you do the mapping that you 21 produced of the Holeyland? 22 A. I don't have an exact date, but it's -- I 23 think our effort was in '92 or early '93. 24 Q. Would that be late '92, early '93? 25 A. I think so. I'm not positive. 196 1 Q. Okay. 2 You had identified this packet which is 3 Bates Nos. 1202773 through 2848 as part of the 4 Holeyland data. Is that related to your SPOT analysis 5 of the Holeyland? 6 A. Yes, this is -- this is the preliminary 7 work that we did. 8 Q. Okay. 9 Now that's different than your mapping 10 just using GPS? 11 A. That's right. 12 (Thereupon, a discussion was held off the 13 record.) 14 BY MR. KOBELINSKI: 15 Q. Did you also produce documents with regard 16 to Holeyland mapping outside of SPOT imagery? 17 A. Yes. 18 Q. Is that something that you identified this 19 morning? 20 A. I'm not sure. 21 Q. All right. 22 MR. KOBELINSKI: Mark that as 9. 23 (Thereupon, the document was marked 24 Rutchey Exb. No. 9 for Identification.) 25 197 1 BY MR. KOBELINSKI: 2 Q. All right. 3 Mr. Rutchey, I'm showing you what's been 4 marked as Rutchey Exhibit No. 9, which is a number of 5 Bates stamped documents bearing 1220441 through 6 1220583, and the first page of which has, appears to 7 again be a file folder stating Holeyland. 8 Why don't we have you put all this other 9 stuff we have in front of -- I guess that's yours. 10 (Thereupon, a discussion was held off the 11 record.) 12 BY MR. KOBELINSKI: 13 Q. And if you could go through this and tell 14 me -- well, just identify it for me, if you would, is 15 this -- are these documents related to your Holeyland 16 mapping just using GPS? 17 A. Yeah, I would say this is. 18 Q. All right. 19 I note that you've pulled out a number of 20 documents, those documents that you pulled out are not 21 part of that mapping effort? 22 A. (Shakes head side to side.) 23 Q. Is that right? 24 A. Yeah. 25 Q. Let me quickly read off the Bates numbers. 198 1 First item you've pulled out bears Bates 2 Nos. 1220491, through 494. And this is a December 6, 3 1993 memorandum from Garth Redfield. There is a single 4 page, Bates No. 1220465 and is a scale indicator of 5 WCA-2A vegetation. I assume this is part of that scale 6 analysis you're doing with Obeysekera? 7 A. That's correct. 8 Q. Next is Bates Page 1220526 and 1220527 9 which states Holeyland soils, 1990 and 1993. 10 Did you ever do a comparison of the 11 vegetation with the Holeyland soils? 12 A. No. 13 Q. Okay. 14 Do you know if anyone else has? 15 A. Yes. 16 Q. Who has done that? 17 A. It's -- it's being looked at, it has been 18 looked at and it's still being looked at by a number of 19 people. 20 Q. Okay. 21 Anyone within the District? 22 A. Yes. 23 Q. Who? 24 A. Sue Mewman, Tom Fontaine, me. 25 Q. Excuse me? 199 1 A. Ken Rutchey. 2 Q. Oh, I thought you said Mike -- 3 A. Marie Pietrucha. 4 Q. Can I ask you to spell the last name? 5 A. I'll guess it. I should have said no. 6 P I E T R U C H A. 7 Q. Okay. Anyone else? 8 A. There are other people, but I don't know 9 their names. 10 Q. Anyone outside of the District that you're 11 aware of doing that? 12 A. Yes. 13 Q. Who? 14 A. I don't know their names. 15 Q. Okay. 16 You mentioned that David Lane was looking 17 at transects below the S-10's. Do you know if he's 18 looking at the Holeyland? 19 A. No. 20 Q. Okay. 21 And you say -- are you still currently 22 doing this? 23 A. Yes. 24 Q. Okay. 25 And where does -- where does that project 200 1 stand? 2 A. Parts of the paper have been written. And 3 basically we're in the data analysis part of the paper 4 at this point. 5 Q. Are you working with someone on that 6 project? 7 A. Yes. 8 Q. That is? 9 A. The people I just mentioned. 10 Q. Okay. 11 Sue Newman, Tom Fontaine, Marie Pietrucha 12 and yourself? 13 A. And I guess there's one other person, 14 George Shih is being involved too. 15 Q. Do you have a draft of that paper already? 16 A. I think that you have a draft introduction 17 to the paper and that's all that's been -- I don't know 18 if I saw that here. It's not in this pile. It's not 19 in this pile. 20 Q. All right. We'll try to take a look for 21 it on the break. 22 What are divisional responsibilities 23 between -- the division of responsibilities between the 24 five of you with regard to that particular project? 25 A. What is the division? I think Tom 201 1 Fontaine has taken the lead. Sue Newman's doing a lot 2 of data analysis and looking at all aspects of the 3 project, all components and George Shih is also helping 4 in that effort. And there's also, my latest 5 understanding is that there's a person outside the 6 District that's taking a look at that data. 7 Q. Do you know who that is? 8 A. I don't know his name. 9 Q. Okay. 10 A. My part, I wrote the introduction to the 11 paper. And I've put a lot of the data sets together 12 there that are being used in the analysis. And I'll 13 probably be involved in looking at the results. The 14 discussion session and conclusion, I believe, probably 15 all of us will be looking at them. Marie's mainly 16 looking at GIS aspects of it, making maps. 17 Q. Okay. 18 What are the components to the project? 19 A. Water quality, soil phosphorus or soil 20 chemical constituent data, vegetation, muck fires, 21 water supply and that's hydrology. 22 Q. With regard to vegetation, are you looking 23 at all vegetative types or just some specific species? 24 A. At this point it's just been specifically 25 cattail. 202 1 Q. Okay. Okay. 2 This all started with the two page 3 document 122526 and 527 which you have excluded. This 4 has soil P as part of the data you're using for that 5 project? 6 A. Yes. 7 Q. Okay. All right. 8 And the next document you've taken out, or 9 two documents -- no, the document you've taken out of 10 that Holeyland pack is Bates No. 1223537 which is 11 Holeyland water quality monitoring network. All right. 12 That and that next one you've taken out is 13 Bates No. 122576 and then you have excluded 1220556 14 through 1220572, which are all in a file called 15 Holeyland vegetation map. What are these vegetation 16 maps? 17 A. I have them in the file, I got them from 18 someone, probably Dewey. I think this is an attempt by 19 the Department of Transportation to use, I believe it 20 was using MS data, LandSat data MS in December of 1982. 21 That's all I know about it. 22 Q. You've not used these for anything? 23 A. No. 24 Q. All right. 25 Then we're listing as Rutchey Exhibit No. 203 1 9, Bates No. 1224441 through 1220583 excluding those 2 Bates Nos. I just pulled out as documents that truly do 3 not belong in this file. Is that accurate, Mr. 4 Rutchey? 5 A. Your initial question was to pull out the 6 files that didn't pertain to the mapping of cattail. 7 Q. Okay. 8 A. And I pulled those out. 9 Q. Okay. All right. 10 These were there for a different purpose 11 then? 12 A. Yes. 13 Q. That being? 14 A. That they were part of the overall 15 Holeyland project. 16 Q. Okay. All right. 17 Well, for purposes -- I guess we'll just 18 include them then. I'll just put them at the bottom, 19 we can take care of the Bates Nos.. 20 With regard to the Holeyland vegetation 21 project, given your work with the WCA-2A SPOT image of 22 2A, did you attempt to just use the classifications you 23 used there to map out the Holeyland? 24 A. You'd have to look at every scene that you 25 get. It's a unique scene. You cannot apply the 204 1 statistical information from one satellite imagery to 2 another. That depends, but... 3 Q. Well, do you have the same type vegetative 4 communities? 5 A. I would say there's similarities, yes. I 6 consider it to be a disturbed Everglades environment. 7 Q. Would you consider 2A to be a disturbed 8 Everglades environment? 9 A. Would I? I consider 2A to have an 10 impacted zone and a nonimpacted zone. 11 Q. Okay. 12 In the impacted zone, would you consider 13 that disturbed, since that's the term you used for the 14 Holeyland? 15 A. Yes. 16 Q. Okay. 17 And do you find -- you find sawgrass in 18 the disturbed zone in 2A; is that correct? 19 A. Yes. 20 Q. Okay. 21 And do you find sawgrass in the Holeyland? 22 A. Yes. 23 Q. Cattail in the disturbed zone in 2A? 24 A. Yes. 25 Q. Cattail in the Holeyland? 205 1 A. Yes. 2 Q. Sawgrass/cattail mixed in the 2A? 3 A. Yes. 4 Q. Mixed in the Holeyland? 5 A. Yes. 6 Q. Are there any vegetative communities that 7 you find in the Holeyland that are not in 2A? 8 A. Oh, I'd have to go -- I wouldn't say 9 there's what I would consider to be tree islands in the 10 Holeyland and polignum/brush mixture. 11 Q. You would not find that in the Holeyland? 12 A. Well, you might find it, but I don't 13 recall seeing it. 14 Q. Okay. 15 Is there anything in the Holeyland that 16 you wouldn't find in 2A? 17 A. Well, not that I -- they have typical 18 Everglades vegetation. 19 Q. Okay. 20 Then, given all of your work with ground 21 truthing that you did in 2A, could you use just SPOT 22 imagery and statistical analysis to just create cattail 23 map for the Holeyland? 24 A. No. 25 Q. Why not? 206 1 A. Because every satellite image that is 2 acquired, that satellite imagery acquired from space is 3 on a different day and every day has unique qualities 4 about it. The atmosphere, the angle of the acquired 5 satellite imagery. There's just a number of things 6 that could come into play, you cannot apply it, it just 7 isn't done. 8 Q. Well, okay. Can't you correct for the 9 atmosphere, the angle and all that? 10 A. You can do that over time if the areas are 11 in the same location, but not -- not separate 12 geographically. We're talking about two different 13 areas from each other. 14 Q. Okay. 15 Why would that matter? 16 A. Well, I'm not -- this is all technique in 17 change detection. It's not my expertise, and I'm not 18 going to get into all the -- my opinions of what. 19 Q. Can you try and do it? 20 A. No. You can't. You shouldn't do it. You 21 can't do that. 22 Q. All right. 23 Then looking at Exhibit 9, how did you do 24 your mapping? 25 MR. CESARANO: That's 9. 207 1 THE WITNESS: Okay. 2 BY MR. KOBELINSKI: 3 Q. I'm sorry, Composite 9. 4 A. Basically we used the original May 1992 5 satellite image. All we did was a preliminary analysis 6 of that data. We did not make a final vegetation map 7 from that. Basically what we did, and we're -- the 8 only one date of this whole cattail mapping project was 9 1992, we went out in the field, it was Les Vilchek, 10 myself and Sue Newman. And we encircled areas with the 11 GPS unit within the Holeyland and got basically their 12 boundary and we each independently estimated percentage 13 cover that we saw in a boundary. And then we compared 14 our results. I don't think we have deviated from each 15 other more than 10 percent. So from that we took an 16 average and came up with a percentage cattail within 17 each of those zones. 18 Q. Okay. 19 I see that you are looking at one of the 20 first documents in Exhibit 9, and that bearing Bates 21 No. 1200442 through 446, which is a memo from yourself, 22 Les Vilchek, Everglades Systems Research Division, to 23 Maura Merkal dated October 21, 1992; is that correct? 24 A. That's correct. 25 Q. All right. 208 1 Now, it's -- I'm looking at Bates page 2 1220445 of this Holeyland cattail distribution in 1992, 3 and G has 0.75 percent cattails, that's a large area 4 there? 5 A. Um-hum. 6 Q. What is that? I mean how does it equate, 7 for instance, to -- I don't know, number of cattails or 8 percentage of cattail within a percent acre, but number 9 of cattail within an acre, just a couple of plants? 10 What -- what does that mean? 11 A. The last number there in the table tells 12 us. 13 Q. Okay. 14 I'm just trying to visualize what .75 of 1 15 percent cattail means. Am I looking at an acre, a 16 representative acre, with just a couple sporadic 17 plants, is it just a different type of growth pattern 18 out there which resulted in this? 19 A. You would -- I mean you want to know how 20 much an acre, what -- 21 Q. What would I see in area G? 22 A. I would take 43,560 square feet and 23 multiply it by, you know, the point -- I guess it would 24 be .0075, and that would be your answer of square feet 25 that you'd find in an acre. 209 1 Q. Would I find it though just interspersed 2 everywhere, individual plants? 3 A. Yeah. 4 Q. There wasn't, for instance, a growth -- 5 clumps of cattail just interspersed? 6 A. That's possible too, but it wasn't big 7 enough to happen such as those other polygons. I mean 8 we're not mapping something less than significant. 9 We're not going to go after the clump of cattail and 10 try to delineate it. In this area it was pretty sparse 11 so we just -- 12 Q. All right. 13 A. I'll estimate we -- I think we all came up 14 with like 1 percent or something. 15 Q. Less than one percent is essentially what 16 you called it? 17 A. I think we used the figure that Game and 18 Fish used in the previous mapping. 19 Q. Okay. All right. 20 A. Which map are we looking at? 21 Q. I was looking at this within Bates No. 22 1200445. 23 A. Okay. 24 Q. That the right map to look at? 25 A. What? 210 1 Q. Is this the map that Game and Fish did? 2 A. The last page. 3 Q. All right. 4 And that's 1220446. Do you know what 5 month the Game and Fish was? 6 A. Let me look in the memo here. I don't 7 recall. It's in here somewhere though. 8 Q. Okay. 9 A. It's not this particular memo, but -- oh, 10 it says April 1992, it is in the memo. 11 Q. All right. So this is April, confusing. 12 And there are some differences between 13 yours and Game and Fish's. Would you account for those 14 differences essentially based upon the six months 15 difference in mapping? 16 A. Yes. 17 Q. Okay. 18 With regard to K, your K, which is also 19 .75, that covers essentially all remaining portions of 20 the Holeyland; is that correct? 21 A. Yes. 22 Q. All right. 23 Now, getting back -- don't get me wrong, I 24 wasn't trying to beat a dead horse. 25 Is the vegetative pattern in response -- 211 1 talking about cattails growing around alligator holes; 2 is that what you're seeing out there which resulted in 3 .75 cover or was there a different type of pattern? 4 A. We -- we stated in the memo, stated in the 5 memo, it should be noted that Area K on our map 6 consisted of scattered cattail and cattail clumps too 7 small to map for our survey. We estimated that they 8 covered approximately .75 percent of the remaining area 9 such as was done for the Game and Fish April 1992 map. 10 Q. Okay. 11 So you have both clumps and just 12 individual plants? 13 A. That's correct. 14 Q. Okay. All right. 15 How long did this take to do? 16 A. One day. 17 Q. All right. 18 Did you -- have you ever compared this map 19 that you created, 1200446 that's the Bates page, to 20 then the SPOT imagery from May of '92? 21 A. No. 22 Q. Okay. 23 Did you record what the other vegetation 24 species were in those areas? 25 A. I -- I'm not sure. I think we just looked 212 1 at cattail. 2 Q. Okay. 3 Do you have any field notes from this 4 survey? 5 A. Yes. 6 Q. Okay. 7 Are those included in this packet here? 8 A. Yes. 9 Q. What Bates numbers would they be? 10 A. Okay. 11 Q. If you'd call out the Bates No. on the 12 bottom there. 13 A. 1220573. 14 Q. Thank you. All right. All right. 15 And this is a two page document which 16 includes 1220574, first column there says Poly number. 17 What does that stand for? 18 A. If you to back to the -- that memo, the 19 last map, those are all polygons. 20 Q. Okay. 21 So, for instance, 1 through 10 essentially 22 are A through K respectively? 23 A. That seems true, yes. 24 Q. Okay. And -- 25 A. Well, A through J respectively. I don't 213 1 believe K is on here or I was -- excuse me, I'm just 2 looking at the front page. 3 A. Okay. 4 Q. All right. All right. 5 The next column, I'm looking again at 6 Bates No. 1220573 is K, I assume that is for Kenneth 7 Rutchey; is that correct? 8 A. That's true. 9 Q. And S for Sue Newman, which is the 10 following column? 11 A. Yes. 12 Q. L is for Les Vilchek? 13 A. Correct. 14 Q. And then the average is actually your 15 averages of the various estimates and what is the final 16 column; what does that say? 17 A. Way points. 18 Q. Way points, what does that mean? 19 A. That was the GPS data. 20 Q. What does way points mean as far as GPS 21 data? I'm sorry. 22 A. That's okay. 23 The GPS unit, when you're checking in you 24 check the point, that's a way point. 25 Q. Oh, this is again trying to determine 214 1 where you took 11 way points which you then -- 2 A. In this case we flew around the outside 3 perimeter in a helicopter and collected points as we 4 were going along. 5 Q. Okay. 6 So, for instance following this along, 7 A -- A you went around what is actually small a little 8 area, did 11 as compared to how many way points for 9 instance were for G? 10 A. I don't have that information available 11 right here. It might be in those documents somewhere. 12 It would be, again, GPS Pathfinder data output. 13 Q. All right. 14 And do you take one approximately every 15 second? 16 A. Again, I'd have to look at it, but either 17 I had it set so it was collecting continuously every 18 second or maybe I set the interval for three seconds or 19 five seconds. I'd be guessing. 20 Q. Okay. 21 Did you have any problem with the 22 correcting? Remember we talked about it for 2A? 23 A. No. 24 Q. Okay. All right. 25 And did you also collect fire data, peat 215 1 fire data for the Holeyland? 2 A. That was supplied to us by Game and Fish. 3 Q. For what period of time? 4 A. I believe it was, let me look at 5 something. That's -- if you want me to look, but I 6 think it was 1980 to present. It's in here somewhere. 7 Q. Okay. 8 What was the purpose of collecting the 9 peat fire data? 10 A. That was one of the parameters of the data 11 that we wanted to look at to see why the area had 12 changed so quickly from basically no cattail to 13 presently 3,700 acres of cattail. 14 Q. Okay. 15 A. In a short relatively period of time. 16 Q. Have you come to any conclusions in that 17 regard? 18 A. No. 19 Q. Okay. 20 Have you look at the peat fires in 21 relation to vegetation of 2A? 22 A. I haven't, no. 23 Q. Okay. 24 With regard to this first initial memo, 25 which is -- bears Bates No 1200442, I'm drawing your 216 1 attention to the first paragraph. Was the attempt to 2 do vegetative mapping using SPOT satellite imagery 3 abandoned due to confusion within or among the 4 vegetation manyation types? 5 A. Yes. 6 Q. Okay. 7 Is the Holeyland vegetation unique that 8 you cannot use SPOT imagery to -- 9 A. I would say that that particular SPOT 10 imagery was -- that we acquired on that date we had 11 problems with. 12 Q. Okay. 13 What was wrong with that SPOT imagery? 14 A. I was having a hard time breaking out 15 various vegetation classes and being able to make a map 16 that I felt confident in the results. 17 Q. Was the quality of the imagery different 18 than, for instance, what you used in 2A? 19 A. It was different. I don't know how to put 20 a quality index on satellite imagery. It's different 21 for the time of year, different -- it's just a totally 22 different image. You have to treat each satellite 23 manage uniquely. 24 Q. Well, have you attempted to get a 25 different SPOT image of the Holeyland to do vegetative 217 1 mapping of it? 2 A. No. 3 Q. Are you going to? 4 A. No. 5 Q. Why not? 6 A. Basically, at this point I think we're 7 going to use aerial photography. 8 Q. All right. 9 (Thereupon, a discussion was held off the 10 record.) 11 BY MR. KOBELINSKI: 12 Q. Have you ever flown the aerial 13 photography? 14 A. We have the flight that was flown in 15 November, December '92, the NASA flight. 16 Q. And have you attempted to start doing the 17 vegetative mapping using those? 18 A. No. 19 Q. Do you need to ground truth the aerial 20 photography for your interpretation of it? 21 A. Yes. 22 Q. How do you intend to do that? 23 A. Well, you look at the aerial photography, 24 you delineate features that you can determine within 25 it, and then you have to go out in the field and ground 218 1 truth these features that you've delineated. 2 Q. Can you do that after a year's passed? 3 A. In my opinion you're pushing it. 4 Q. Okay. 5 Well, do you already have scheduled to 6 do -- start doing that ground truthing? 7 A. No. 8 Q. I gather you get pulled out to different 9 projects? 10 A. (Shakes head up and down.) 11 Q. Is that a correct summation? 12 A. Yes. 13 Q. All right. Fair enough. 14 With regard to 3A, have you determined 15 whether or not you will be doing SPOT imagery mapping 16 of 3A? 17 A. No. 18 Q. No, you've not made that determination? 19 A. I'm -- I won't be using SPOT imagery to 20 map Area 3A. 21 Q. Why not? 22 A. I will be using it as a a tool, but not as 23 the actual mapping part of the -- tool part of the 24 process. 25 Q. Okay. 219 1 Why not use SPOT imagery? 2 A. I'm going to use -- for this area I'm 3 going to use aerial photography. 4 Q. Why not use the SPOT imagery to map it as 5 you did with 2A? 6 A. I believe that you can be more accurate in 7 using aerial photography. 8 Q. Okay. 9 If I recall correctly, you stated you had 10 the aerial photography of 2A. Do you think that the 11 mapping using that aerial photography would have been 12 more accurate than the SPOT imagery? 13 A. Yes. 14 MR. KOBELINSKI: Might as well call it a 15 day if you have to leave at 5, Greg. Otherwise 16 it's a whole new topic area. 17 (Thereupon, the deposition was adjourned 18 at 4:55 p.m. until 9:05 a.m. on February 8, 19 1993.) 20 21 22 23 24 25