220
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 II
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 - 4:00 p.m.
221
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
17 America:
18 THOMAS A.W. FITZGERALD, ESQUIRE
Assistant United States Attorney
19 155 South Miami Avenue
Suite 600
20 Miami, Florida 33130-1693
21 ALSO PRESENT:
22 EDWARD DOWNING
MICHAEL SOUKUP
23 MICHAEL STORY
24
25
222
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
223
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
224
1 P R O C E E D I N G S
2
3 - - -
4 MR. KOBELINSKI: I would remind Mr.
5 Rutchey that you're still under oath.
6 Let me just make a comment here. As I
7 explained just a few moments ago, prior to going
8 on the record, I have not completed my direct
9 testimony of the witness. And, in fact, given
10 the fact that we still don't have the electronic
11 data and some other documents we identified
12 yesterday, including the photos, I would have
13 difficulty doing so. However, Ms. Raepple, from
14 the Cooperative, has spoken with me and,
15 essentially, if I do not pass the baton at this
16 point in time, we're pretty much guaranteed not
17 to be able to finish Mr. Rutchey today and have
18 to call him back.
19 If I do pass the baton there is a
20 possibility that either A, I might need
21 additional redirect or we perhaps would ask
22 those questions of a different witness. So I
23 will at this time halt my direct testimony or
24 questioning. Ms. Raepple will commence, but I
25 will reserve the right to redirect or to
225
1 question Mr. Rutchey further, particularly after
2 we receive his electronic data if that need
3 arises.
4 The other comment I need to make is that
5 Mr. Rutchey is involved, or at least Dr.
6 Jensen's paper is based in part on the 2A study
7 that Mr. Rutchey did. The Jensen deposition is
8 set, I believe, for what, two weeks from
9 tomorrow or something? Is that everyone's
10 recollection?
11 MS. RAEPPLE: Um-hum.
12 MR. KOBELINSKI: He's been noticed by both
13 sides and his documents have been due. Given
14 this fact if paper is finalized, we need those
15 documents or we probably will not able to be
16 able to start. I was told there's only two days
17 he's available. He's the U.S.'s witness --
18 MR. CESARANO: No, he's the District's
19 witness. He assured me that his documents were
20 with Federal Express yesterday, they should be
21 getting in today.
22 MR. KOBELINSKI: Okay. All right.
23 MR. CESARANO: We'll send them out
24 immediately --
25 MR. KOBELINSKI: -- to you and transmit
226
1 that.
2 MR. KOBELINSKI: The only problem
3 accommodating this witness is if those are the
4 only two days we need really need to get those
5 as soon as possible.
6 MR. CESARANO: I understand.
7 MR. KOBELINSKI: I will -- under those
8 conditions, I will pass the baton to Ms.
9 Raepple.
10 If you have an objection to that, Greg, I
11 can go on, but as I said, we're guaranteed to
12 have to call him back another time.
13 MR. CESARANO: I don't think that's an
14 unreasonable request. We'll give it a try and
15 see how it develops.
16 MR. KOBELINSKI: Okay.
17 Thereupon,
18 Ken Rutchey
19 being by the undersigned Notary Public previously
20 sworn, was examined and testified as follows:
21 CROSS (Ken Rutchey)
22 BY MS. RAEPPLE:
23 Q. Mr. Rutchey, I'm Carolyn Raepple. I'm
24 representing the Sugar Cane Grower's Cooperative of
25 Florida, Roth Farms and Wedgeworth Farms. I'm going to
227
1 ask you a number of questions today similar to what you
2 had yesterday with Mr. Kobelinski. If you don't
3 understand any of the questions I ask you, let me know,
4 I'll restate them. I'm not an expert in satellite
5 imagery interpretation. If I use a term incorrectly,
6 let me know, I'll try to restate the question in an
7 appropriate fashion. Do you understand?
8 A. Yes.
9 Q. Okay.
10 In the document which has been marked as
11 Exhibit 1 to this deposition, there are some vegetative
12 maps of WCA-2 A. Has the Water Management District
13 ever created a vegetative map for WCA-2 A prior to
14 those maps?
15 A. I did a preliminary map based on an April
16 1987 SPOT satellite image which was referenced a number
17 of times in other people's work.
18 Q. Was that map produced for this deposition?
19 A. Yes.
20 Q. Where is it?
21 A. It -- what I produced was a folder on
22 that, the data of that map and also a big hard copy,
23 color hard copy.
24 MS. RAEPPLE: Let's mark this as -- two
25 page map as Exhibit 10.
228
1 (Thereupon, the document was marked
2 Rutchey Exb. No. 10 for Identification.)
3 BY MS. RAEPPLE:
4 Q. Is this the preliminary map to which you
5 just referenced?
6 A. Yes.
7 Q. When was Exhibit 10 created?
8 A. I'd say late 1987, 1988.
9 Q. Did you ground truth this map?
10 A. I went out in the field and got
11 information for the classes obtained in the map, yes.
12 Q. Would you explain the procedure that you
13 utilized to ground truth this map?
14 A. Back then we didn't have GPS. So I used
15 photography and went out in the field and visited the
16 sites and tried my best to find them in the satellite
17 imagery and extracted that information from each of
18 those types of vegetation classes, and performed a
19 supervised classification with that data.
20 Q. How could you tell whether you were at the
21 location on the ground that you thought you were at
22 when you did that site visit?
23 A. Accurately I couldn't. It's probably why
24 this piece of work has never been published. It had
25 its faults and it was more of a learning process to me
229
1 in the creation of this map. I basically did the best
2 I could from looking at the photography going out in
3 the field, and trying to determine those locations in
4 the satellite imagery.
5 Q. Okay.
6 Then you used no mechanical assistance to
7 locate yourself on the ground when you visited the site
8 for this map?
9 A. Basically at that time GPS wasn't in
10 existence and Loran is pretty inaccurate in the
11 Everglades. I would have been more accurate using
12 aerial photography then to try to use the Loran system
13 at that time.
14 Q. What type of aerial photography did you
15 utilize when you were creating Exhibit 10?
16 A. Boy, this is going back in time now.
17 We're talking five, six years.
18 I had a data set, but don't ask me what
19 date it was, I don't remember. It was close to that
20 time of Area 2.
21 Q. Was it color infrared?
22 A. It was color infrared.
23 Q. Are you familiar with the SWIM Plan for
24 the Everglades?
25 A. I've heard about it, yes.
230
1 Q. Are you familiar with the vegetative maps
2 for WCA-2 A that appear in that document?
3 A. No.
4 Q. Did you have any involvement in creating
5 maps for utilization in the Everglades SWIM Plan?
6 A. They might have been utilized, but it
7 was -- I didn't have any direct input to it or know
8 about it, you know, they -- that happens sometimes.
9 Q. When I reference the Everglades SWIM Plan,
10 do you understand that I'm referring to the three
11 volume set?
12 A. No. I don't have anything to do with the
13 SWIM Plan.
14 Q. Do you know how many volumes there are in
15 the Everglades SWIM Plan?
16 A. Nope.
17 Q. Have you ever seen the Everglades SWIM
18 Plan?
19 A. I might have seen the cover, but I didn't
20 take the time to read it or anything.
21 Q. Do you know whether Exhibit 10 was
22 utilized by anyone else to create a map of WCA-2A for
23 inclusion in the Everglades SWIM Plan?
24 A. Not for certain, no.
25 Q. In your judgment, would it be appropriate
231
1 to utilize Exhibit 10 for the creation of a vegetative
2 map showing the vegetation in existence in WCA-2A in
3 1987?
4 A. Yes.
5 Q. Why would it be appropriate?
6 A. A number of people have looked at this
7 map, taken it in the helicopter and flown with it. A
8 number of us have long term knowledge of the area, been
9 out there literally hundreds of times and know the area
10 well. And this was a good representation of that area
11 at that time.
12 Q. Who have you discussed Exhibit 10 with, in
13 which they indicated that it is a good representation
14 of the vegetation in WCA-2A as it existed in the spring
15 of '87?
16 A. I would say Steve Davis, Nancy Urban, Dave
17 Swift. Those I believe are the three major -- Dewey
18 Worth.
19 Q. Okay.
20 And you yourself believe it's a good
21 representation; is that correct?
22 A. Yes.
23 Q. Have all of those individuals spent a fair
24 amount of time in WCA-2A?
25 A. Yes.
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232
1 Q. About how many times have you visited
2 WCA-2A either on the ground or in a helicopter?
3 A. I would say four to 600 days, many of
4 those for one stretch period from when I officially was
5 hired at the District in 1981 to 1985. We went out
6 almost every week and spent overnight trips there three
7 days a week.
8 Q. About how many days did you spend in
9 WCA-2A during the spring of '87?
10 A. I can't recall that. I don't know. I'd
11 have to look go back and look.
12 Q. What would you look at?
13 A. Hopefully they kept records of our -- of
14 our field trips. I'm sure the County somewhere
15 probably did that.
16 Q. Can you estimate how many days you spent
17 in WCA-2A prior to the spring of 1987?
18 A. I would say that's basically most of time
19 was prior to 1987 as opposed to after.
20 Q. Most of your four to 600 days?
21 A. Yes.
22 Q. Can you estimate how much of those four to
23 600 days were spent on the ground or in an air boat as
24 opposed to in a helicopter?
25 A. These are highly speculative numbers. I
233
1 mean without records I'm really -- four to 600
2 hopefully, in that range. What percentage, I'd be
3 guessing.
4 Q. When you went into the field to verify the
5 vegetation for the creation of Exhibit 10, do you
6 recall whether you went into the field in an air boat
7 or in a helicopter?
8 A. Most of the time it was in a air boat.
9 Q. Did you keep any field notes from those
10 visits?
11 A. No, other than the report that was
12 produced for Dewey Worth for all the transects that we
13 had established in this area.
14 Q. Which report is that?
15 A. I turned it over yesterday. It's in the
16 green folder. It's the response of the drawdown study
17 response of the vegetation -- I can't recall the exact
18 name of it.
19 Q. Are you referencing Technical Publication
20 88-2 of March 1988, titled Environmental Response of
21 WCA-2A to Reduction in Regulation Schedule and Marsh
22 Drawdown?
23 A. Yes.
24 Q. Where are your field notes reflected in
25 that report?
234
1 A. I don't think the field notes are actually
2 in the report. I think all the data that was used to
3 produce this is available in field notes. You'd have
4 talk to Dewey Worth about it, because he was the
5 primary author and he kept all that information.
6 Q. Did Dewey Worth accompany you on that
7 field trip to verify the vegetation in WCA-2A for the
8 creation of Exhibit 10?
9 A. Yes, on a few times, yes. I mean we
10 worked out there for four or five years together.
11 Q. Was he participating in the verification
12 of vegetation or was he simply along with you on the
13 trip?
14 A. I think he was just along on the trip.
15 And part -- I mean he knew about this map and that I
16 was working on it and he saw how things were moving
17 along as I was progressing and making the map. And
18 he'd have comments well, maybe this area doesn't, you
19 know, jive or look quite right and you need to work on
20 this and...
21 Q. When he made those kinds of statement, did
22 you make adjustments to Exhibit 10?
23 A. Again, this is going back a long time and
24 this is a very preliminary piece of work. I don't
25 recall, unless I go through my folder and start reading
235
1 through, how I actually produced this map other than
2 knowing I remember it was a supervised classification,
3 I used aerial photography and going out in the field to
4 ground truth. Other than that I don't remember any of
5 the details of the creation of this map.
6 Q. Did you ever speak with anyone familiar
7 with the vegetation in WCA-2A who felt Exhibit 10 was a
8 poor representation of the vegetation in WCA-2A in the
9 spring of '87?
10 A. No.
11 Q. In your judgment, is Exhibit 10 the best
12 reflection of vegetative conditions in WCA-2A in the
13 spring of '87 that exists today?
14 A. It's the best that's available, yes.
15 Q. You mentioned that you and Dewey Worth
16 worked on some transects in WCA-2A; is that correct?
17 A. That's correct.
18 Q. Where were those transects?
19 A. They were all over the area from north to
20 south, east to west.
21 Q. How were those transects developed?
22 A. You're going have to talk to Dewey Worth
23 about that.
24 Q. Where is Dewey Worth now?
25 A. Boise, Idaho.
236
1 Q. Can you be more specific?
2 A. More specific than Boise, Idaho?
3 Q. Yes. Do you know where he works?
4 A. Department of Environmental Quality.
5 Q. Do you know whether the transects were
6 ever surveyed?
7 A. I don't think they were. I would say that
8 there's -- they've been staked, you know, they're
9 still -- they're still there basically.
10 Q. When were the stakes put in place?
11 A. Back when we actually did our initial
12 biological survey.
13 Q. In which year was that?
14 A. What year?
15 Q. Yes.
16 A. It was during a period of years from '81
17 to, I'd say, approximately '85.
18 Q. And those stakes remain today up to 10, 12
19 years later?
20 A. Some of them.
21 Q. Do all the stakes remain?
22 A. No.
23 Q. What have those transects been used for by
24 the South Florida Water Management District?
25 A. I don't think they have been used since
237
1 that report.
2 Q. That report is a reference to the
3 technical publication we just referenced?
4 A. Yes.
5 Q. Were the stakes the method utilized to
6 locate the transects when you went into the field or
7 did you have some other mechanical means of locating
8 those transects?
9 A. They -- well, we wanted to know where the
10 beginning and ending part of a transect was each time
11 we went back exactly and that was only way to do that.
12 We know where all those areas are just from our
13 familiarity with Area 2, how to get there. It's just
14 that we wanted an exact beginning point, we ran our
15 transect.
16 Q. Would you then traverse along the
17 transects to the ending point?
18 A. Yes.
19 Q. How did you do that? Did you have
20 anything to assist you in staying on a straight course?
21 A. Yes.
22 Q. What?
23 A. Basically the transects were, I think the
24 longest one might have been a thousand feet, and just
25 tried to -- we biologists, you have a long tape
238
1 measure, you have a -- one pole to the other pole, you
2 got your straight line.
3 Q. Have you established the location of any
4 of those stakes in your GPS work?
5 A. No.
6 Q. Who else within the Water Management
7 District creates vegetative maps besides yourself?
8 A. Les Vilchek. I'd say Patti Sime.
9 Q. How do you spell her last name?
10 A. S I M E.
11 There might be others, but I'm not aware
12 of them.
13 Q. Is there any one department that has the
14 overall responsibilities for vegetative mapping within
15 the District?
16 A. I'd say no.
17 Q. There's no overall coordination of
18 vegetative mapping within the District?
19 A. I'd say no.
20 Q. Does Les Vilchek work in your department?
21 A. Yes.
22 Q. What about Patti Sime, where does she
23 work?
24 A. It's either up in Lower District Planning
25 or Upper District Planning.
239
1 Q. Has Patti Sime assisted you in the
2 creation of any vegetative maps?
3 A. No.
4 Q. Do you know who was responsible for the
5 creation of the vegetative maps that were included in
6 the Everglades SWIM Plan?
7 A. No.
8 Q. Based on your experience in WCA-2A since
9 1981, have the cattail which are located south of the
10 10 structures advanced as a solid monoculture or have
11 they spread by mixing in with the native vegetation and
12 sawgrass?
13 A. My personal observance is they definitely
14 have spread. And the way I have observed is initially
15 they go into slough areas which are lower, more water,
16 and they don't have vegetation. Once they get into the
17 slough areas then they encroach on the surrounding
18 sawgrass ridges and eventually out compete the sawgrass
19 and eventually form a monoculture of cattail.
20 Q. Does that pattern of cattail spread apply
21 to all locations within WCA-2A that are cattail today
22 or is that just south of the S-10's?
23 A. I can't -- I'm not sure, because I don't
24 know all locations within the -- within Area 2. I mean
25 this is the things that I've observed. I think that
240
1 they'll come in, you know, in other areas where there's
2 no sloughs, you know. I've seen that happen too when
3 they just come in thick, the sloughs aren't there,
4 they'll invade a sawgrass ridge. I mean just if we
5 have a monotypic stand of cattail, a wall moving along,
6 and there's a sawgrass ridge in the way and there's no
7 slough in between then they'll encroach on that
8 sawgrass ridge also. But most -- most of my
9 observations, if there's a slough available they'll
10 move into the slough area first and then encroach on
11 the surrounding sawgrass ridges.
12 Q. Where within WCA 2A have you seen the
13 cattail encroachment occur first in the slough and then
14 progress into a sawgrass ridge?
15 A. A number of places south of the S-10
16 structures and all the way on the southern end in along
17 L-35 all along.
18 Q. Any other areas?
19 A. Those are the two that I -- that I have
20 noticed it.
21 Q. Where have you seen cattails come into an
22 area where there was no slough?
23 A. I would say up in the north, very
24 northeast section and in the very west section adjacent
25 to the S-7 inflow structure.
241
1 Q. When did you first observe cattails on the
2 southern end of WCA-2A along L-35?
3 A. I think there's always been some cattail
4 there since I was there. I wouldn't say they were
5 always there, but as far as back as I can remember
6 there was always some.
7 Q. How far back is that?
8 A. 1981. When I say some, I -- that means --
9 I mean a little bunch here and there. That's how I
10 remember it.
11 Q. When did you first observe cattail in the
12 very northeast section of WCA-2A?
13 A. Since 1981.
14 Q. When did you first observe cattail in the
15 west section adjacent to the S-7 inflow structure?
16 A. I would say it was during that period, '81
17 to '85, that I started -- I mean there was some there.
18 Q. There was some there in '81 when you first
19 went into the area?
20 A. I can't tell you the exact date when I
21 observed. I mean this is -- all numbers I'm giving you
22 are real approximate. I'd say somewhere between '81
23 and '85 for that area.
24 Q. For the two areas that you've testified
25 cattail was in existence when you first saw them, and
242
1 that's the southern end along the L-35 and the very
2 northeast section, is it fair to say that you don't
3 know how cattail first came into the area?
4 A. I think, you know, cattail has always been
5 in the Everglades at one point in time. It's --
6 they're a native species. It's just they're
7 proliferating, that is the problem.
8 Q. Why is cattail proliferation a problem in
9 your judgment?
10 A. It's out of balance. It takes away from
11 the biodiversity of the fauna, the benthic community,
12 algae communities. It disrupts, basically, the whole
13 food chain, which extend, basically, to higher trophic
14 levels.
15 Q. In what way does the proliferation of
16 cattail disrupt the whole food chain?
17 A. Well, basically, when you form a dense
18 stand of monotypic cattail and there's nothing else, it
19 tends to shade everything out, light reaching the
20 water, then you don't have algae production. You don't
21 have algae production, you don't have benthics. You
22 don't have benthics, fish don't utilize it as much.
23 Fish don't utilize it as much, birds don't utilize it
24 as much. Birds don't utilize it as much, alligators
25 don't tend to hang out in those areas. They depend on
243
1 birds a lot for their food, you know.
2 Q. Have you ever seen fish in a monoculture
3 of cattail?
4 A. Yes.
5 Q. Have you ever seen birds in a monoculture
6 of cattail?
7 A. Yes.
8 Q. Have you ever seen wading birds in a
9 monoculture of cattail?
10 A. Yes.
11 Q. Have you ever seen wading birds feeding on
12 fish in a monoculture of cattail?
13 A. No.
14 Q. Have you ever seen alligators in a
15 monoculture of cattail?
16 A. Yes.
17 Q. Have you ever seen an alligator feeding on
18 birds in a monoculture of cattail?
19 A. No.
20 Q. You indicated previously that Exhibit 10
21 is a preliminary map. Was a final vegetative map of
22 the WCA-2A vegetation in the spring of '87 ever created
23 by someone else?
24 A. No.
25 Q. Did you ever calculate the acreages for
244
1 each of the vegetative classes shown on Exhibit 10?
2 A. Yes.
3 Q. Where are those acreages?
4 A. They were given in a folder.
5 MR. KOBELINSKI: Just for clarity, is it
6 one of the folders we marked yesterday, or is it
7 one that we have not as yet marked?
8 THE WITNESS: I don't know. I don't
9 recall if that -- it was in one of those, no.
10 BY MS. RAEPPLE:
11 Q. I'll pass that over for the time being,
12 and perhaps we can find it on a break.
13 Other than Exhibit 10, have any other
14 vegetative maps of the WCA-2A been created prior to
15 your 1991 map?
16 A. Not that I'm aware of.
17 Q. Are you aware of all of the remote sensing
18 imagery that the District has of the WCAs, the
19 Loxahatchee National Wildlife Refuge and Everglades
20 National Park?
21 A. Yes.
22 Q. Can you tell me what images the District
23 has of those areas?
24 A. There's probably hundreds, and I've
25 provided that in a -- in a document. I'm not going to
245
1 try to guess all the dates that we have of all those
2 areas.
3 Q. In the documents you produced there is a
4 list of all the remotely sensed data which the District
5 has?
6 A. It's basically a listing of the database I
7 put together describing all the satellite imagery that
8 the District has in its possession.
9 Q. Was that a hard copy list, or was it
10 digitized?
11 A. It's a hard copy listing. I'm pretty sure
12 you got that folder.
13 Q. Do you know Mark Maffei?
14 A. Yes.
15 Q. Who is he?
16 A. He's -- my description of him, he's a
17 scientist/bureaucrat for the National Park Service and
18 Water Conservation Area 1 specifically.
19 Q. Why do you call him a
20 scientist/bureaucrat?
21 A. He's -- because he's not a -- he looks at
22 everything scientifically, but he's involved in the a
23 lot of the bureaucratic processes that go on. I'm not
24 sure of all the details of what that means, but I know
25 that he's not strictly a field biologist.
246
1 Q. Have you ever spoken with him about remote
2 sensing?
3 A. Yes.
4 Q. Do you know whether he has ever done any
5 mapping of the Loxahatchee National Wildlife Refuge
6 using remote sensing?
7 A. No.
8 Q. No, he hasn't or no, you don't know?
9 A. No, I don't know.
10 Q. Has he ever asked you to assist him in
11 mapping WCA-1 using remote sensing?
12 A. No.
13 Q. Are you aware of any mapping effort for
14 WCA-1 that is ongoing?
15 A. Nope.
16 Q. Do you have any maps of the vegetation in
17 WCA-1?
18 A. Yes.
19 Q. Where are those maps?
20 A. They're all in digital form.
21 Q. Are those included in the digitized
22 records that we have yet to receive?
23 A. Yes.
24 Q. How many maps of WCA-1 do you have in
25 digitized form?
247
1 A. One.
2 Q. What year does it represent?
3 A. I believe it's 1987.
4 Q. How was that map created?
5 A. You'd have to ask John Richardson.
6 Q. Was it created by John Richardson?
7 A. Yes.
8 Q. Have you ever discussed with John
9 Richardson how he created that map?
10 A. Yes.
11 Q. What is your recollection of his
12 methodology based on that conversation?
13 A. I don't recall the details. What I do
14 recall is I looked at the finished product and my
15 observances of Area 1, it looked, from what I know of
16 the area, it looked good.
17 Q. When did you look at that map?
18 A. I look at it periodically since it's been
19 produced.
20 Q. When did you first look at it?
21 A. Oh, probably late 1989, 1990.
22 Q. How did you look at it, was it hard copy
23 at that time?
24 A. Yes.
25 Q. What happened to that hard copy, do you
248
1 know?
2 A. The original hard copy was a promotional
3 thing that SPOT was using to showcase their satellite
4 imagery. That's what I saw. I have that in a folder.
5 I don't think you got that as it was just promotional
6 stuff by SPOT Corporation.
7 Q. What else is in that folder?
8 A. Other people's work that they've done
9 around the country using SPOT satellite imagery.
10 Q. Any other maps of the Everglades area?
11 A. No.
12 Q. When you say that map looked good based on
13 what you knew of WCA-1, how well did you know WCA-1?
14 A. I don't know it as good as Area 2, but
15 I've flown over it a number of times in the helicopter.
16 I know what the interior structure is like and what the
17 outer levee structure is like, and from my personal
18 observations I thought it was a good reflection of the
19 area.
20 Q. When you will say good, can you put a
21 percent accuracy on that or a range of percent
22 accuracy?
23 A. I wouldn't feel comfortable doing that.
24 Q. How many maps of the Everglades area do
25 you have in digital form, do you know?
249
1 A. Can you repeat that question?
2 Q. How many maps of the Everglades area do
3 you have in digital form, do you know?
4 A. The way you asked the question, hundreds.
5 Q. What was it about the way that I asked the
6 question that made you answer --
7 A. You said just digital maps, that means
8 original satellite imagery.
9 Q. How many maps of vegetation in the
10 Everglades area do you have in digital form?
11 A. I'd say five or six.
12 Q. What areas are covered by those digital
13 maps?
14 A. Keep in mind some of these papers are just
15 preliminary, but 2, 1, Holeyland, Area 3, and ENR
16 project.
17 Q. And all of those vegetation maps will be
18 in digitized files that we have yet to obtain?
19 A. Yes.
20 Q. Were all of those vegetation maps created
21 using remotely sensed data?
22 A. No.
23 Q. Going back to the map that you indicated
24 John Richardson created of WCA-1, was that created
25 utilizing SPOT imagery, do you know?
250
1 A. Yes.
2 Q. These five or six vegetation maps that you
3 have in digital form, did you create all of them?
4 A. No.
5 Q. Do you know how many vegetation maps you
6 have of WCA-2?
7 A. Two
8 Q. Are those the two we've already discussed
9 in this deposition?
10 A. Yes.
11 Q. How many digital maps of WCA-1 do you
12 have?
13 A. One.
14 Q. Is that the John Richardson map?
15 A. Yes.
16 Q. How many digital maps of the Holeyland do
17 you have? And that's -- excuse me, that's digital
18 vegetation maps of the Holeyland.
19 A. There's probably half a dozen.
20 Q. Did you create all of those vegetation
21 maps?
22 A. No.
23 Q. Do you recall the dates of those maps?
24 A. I can give you a span of time, 1980 to
25 current.
251
1 Q. Who created the earliest of those
2 vegetation maps, do you know?
3 A. I believe -- I believe it was the
4 Department of Transportation.
5 Q. Who created the subsequent maps, do you
6 know?
7 A. Game and Fish and South Florida Water
8 Management District.
9 Q. How many have been created by the South
10 Florida Water Management District?
11 A. One and one preliminary.
12 Q. The one that is in final form, what is the
13 date of that map, do you know?
14 A. We talked about it yesterday. It's
15 cattail work.
16 Q. That was the cattail work where you and
17 Sue Newman and Les Vilchek flew in a helicopter, all
18 estimated the coverage of cattail in an area, then you
19 averaged those estimates --
20 A. Yes.
21 Q. -- is that correct? All right.
22 What about the preliminary map, who
23 created that?
24 A. I did.
25 Q. When was that created?
252
1 A. I would say it was 12 to 18 months ago.
2 Q. For what purpose was that created?
3 A. Basically I was just trying to look at
4 land patterns and do a preliminary look at the data,
5 see what I could pull out as far as vegetation, and I
6 sort of got pulled off to -- onto another project and
7 never finished.
8 Q. Was anyone assisting you in that mapping
9 effort?
10 A. Les Vilchek.
11 Q. When I get these digital maps, will the
12 digitized file indicate which of the maps are final and
13 which ones are preliminary?
14 A. No.
15 Q. I'd have to ask you which ones were
16 preliminary?
17 A. Yes.
18 Q. How far along were you in your vegetation
19 mapping effort 12 to 18 months ago for the Holeyland?
20 A. If I recall, I separated some things out,
21 but basically I wasn't looking to do a final product
22 with satellite imagery. I wanted to use that as an aid
23 for using aerial photography.
24 Q. What kind of aerial photography?
25 A. We went over this yesterday, but the
253
1 November, December NASA flight that was flown.
2 Q. I believe it was in regard to that prior
3 discussion in yesterday's deposition that you testified
4 that you believe using aerial photography would be more
5 accurate. Do you recall that testimony?
6 A. Yes.
7 Q. Why do you believe aerial photography
8 would be more accurate than satellite imagery?
9 A. Well, this latest effort, if you look at
10 just the overall map accuracy, you have 81 percent for
11 this area, which is excellent for this particular work.
12 Using photography you can probably get up around 95
13 percent. It's a much more detailed and a longer effort
14 in producing, but more accurate. But -- never mind.
15 Q. In this deposition whenever you are
16 referencing aerial photography, I'm assuming you mean
17 color infrared aerial photography. Is that a correct
18 assumption?
19 A. Yes.
20 Q. Will you tell me if we start talking about
21 aerial photography where you're not referencing color
22 infrared?
23 A. All I use is color infrared.
24 (Mr. Green left the room.)
25
254
1 BY MS. RAEPPLE:
2 Q. Okay.
3 How much vegetation mapping have you
4 personally done using color infrared photography?
5 A. I would say right now we have a good
6 effort going on in the ENR project.
7 Q. When will that be complete?
8 A. It's an ongoing project for, from what I
9 hear, from now till eternity. I'm not told a dead drop
10 date.
11 Q. Are you intending to produce a final map
12 from that ongoing project?
13 A. There'll be a map produced every three
14 months, approximately.
15 Q. Do you know the purpose of creating a map
16 every three months?
17 A. To show a trend analysis of the vegetation
18 communities of 1.
19 Q. How many of those maps have been generated
20 to date?
21 A. None.
22 Q. When do you project the first map being
23 complete?
24 A. Within the next four weeks, three to four
25 weeks.
255
1 Q. Who is assisting you in that mapping
2 effort?
3 A. Les Vilchek.
4 Q. Going back to the digital maps that you
5 have, you indicated that you have some vegetation maps
6 for WCA-3; is that correct?
7 A. Right.
8 Q. How many do you have?
9 A. Again, it's same as the Holeyland area,
10 it's preliminary, and same -- it was used for the same
11 purposes using the NASA aerial photography, just
12 basically trying to find land patterns.
13 Q. Is there just one map, vegetation map of
14 WCA-3?
15 A. There's really -- at this point there's no
16 map, it's preliminary data.
17 Q. How many vegetation maps in digital form
18 do you have for the ENR project?
19 A. None.
20 Q. What other types of digital maps do you
21 have other than vegetation maps?
22 A. Boy, I mean does that include graphs
23 and --
24 Q. Let me be more specific. Do you have any
25 digital maps of the Everglades area that show
256
1 topography?
2 A. Yes.
3 Q. Do you have any digital maps of the
4 Everglades area that show soils?
5 A. Yes.
6 Q. Do you have any digital maps of the
7 Everglades area that show water quality?
8 A. Not that I recall. I'll take that back,
9 yes.
10 Q. What kind of water quality, surface water
11 or interstitial?
12 A. What is your definition of those two
13 terms?
14 Q. Well, why don't you tell me what kind of
15 water quality digital maps you have for the Everglades
16 area?
17 A. Basically I have all of John Richardson's
18 data that he did, and some of the things he did was, I
19 believe, water quality when he went out and collected
20 samples.
21 Q. Do you have any digital maps of the
22 Everglades area that show water depth?
23 A. Yes.
24 Q. Are there any other digital maps of the
25 Everglades area similar to the types we've just
257
1 described that you have?
2 A. Not to my knowledge. That doesn't mean
3 there isn't out of all the time I've been out at the
4 District.
5 Q. What about a digital map of fire
6 locations, do you have any of those?
7 A. Yes.
8 Q. In the digitized files that you will be
9 producing, will all of these digital maps be included?
10 A. Yes.
11 Q. Are all of the digital maps that are for
12 not vegetation maps final maps or are there any -- are
13 there some preliminary maps in there as well?
14 A. I don't -- could you repeat that again?
15 Q. Okay.
16 When we talked about your digital
17 vegetation maps you indicated that some of them are
18 final, some of them are preliminary.
19 A. Correct.
20 Q. And that the digitized file will not
21 indicate which ones are final or preliminary, I'll have
22 to talk to you about which ones are. Do you remember
23 that testimony?
24 A. Right.
25 Q. Now I'm asking you about these other
258
1 digital maps, the topographic maps, the soils, the
2 water quality, the water depths, and fire locations,
3 are some of those preliminary maps, do you know?
4 A. I think most of those are final.
5 Q. Do you know whether any of them are
6 preliminary?
7 A. I think those are mostly final. To the
8 best of my knowledge they're all final.
9 (Thereupon, a discussion was held off the
10 record and Mr. Green returned.)
11 BY MS. RAEPPLE:
12 Q. Who created topographic digital maps that
13 you'll be producing?
14 A. I created one.
15 Q. Are there any other topographic digital
16 maps that you'll be producing?
17 A. Not to my knowledge.
18 Q. Okay.
19 Who created the soil digital maps that
20 you'll be producing?
21 A. John Richardson.
22 Q. Do you know how many soil digital maps
23 you'll be producing?
24 A. I think that's just one.
25 Q. Do you know the date of that map?
259
1 A. It -- I think it was in the period of
2 around 1987-88.
3 Q. You indicated that the water quality
4 digital maps are all John Richardson's; is that
5 correct?
6 A. (Shakes head up and down.)
7 Q. Do you know how many maps there are?
8 A. No, there's many files.
9 Q. Do you know what time span they cover?
10 A. I think it's all around '87, 87-88.
11 Q. Do you know what area of coverage the
12 water quality maps are for?
13 A. Area 1.
14 Q. All of them?
15 A. Yes.
16 Q. What about the soils map, what area is
17 covered by that map?
18 A. Area 1.
19 Q. What about the topographic map that you
20 created, what area is covered by that?
21 A. Holeyland.
22 Q. When did you create that map?
23 A. I'd say approximately three months ago.
24 Q. For what purpose?
25 A. It's one of the parameters to be looked as
260
1 for the reason why cattail has expanded so rapidly
2 within that area.
3 Q. What methodology did you utilize to create
4 that topographic map?
5 A. I was provided information from Game and
6 Fish of 196 points evenly -- pretty evenly distributed
7 through out the area. I took that data and created a
8 TIN and then created a contour from that within
9 ARC/INFO.
10 (Thereupon, a discussion was held off the
11 record.)
12 BY MS. RAEPPLE:
13 Q. How many water depth digital maps will you
14 producing?
15 A. Well, if -- the way that I work, if you
16 know the elevations and you have water, you can produce
17 water depth maps basically if you know the bottom
18 contour and you know how deep it is. So maybe many. I
19 have, you know --
20 Q. When you say many, would that require the
21 merging of two databases to create a water depth map?
22 A. The one I will be providing is one by --
23 Game and Fish gave us.
24 Q. What was the area of coverage for that
25 map?
261
1 A. The Holeyland.
2 Q. What is the date of that map?
3 A. I would say sometime in 1993.
4 Q. Do you know why that water depth map for
5 the Holeyland was created?
6 A. I think they were concerned that the --
7 that we didn't have a good handle on the water depths
8 within that area. That's just one more parameter to
9 look at in trying to figure out why cattail established
10 so rapidly within that area.
11 Q. Do you know why the Game and Freshwater
12 Fish Commission felt the District doesn't have a good
13 handle on water depths in the area?
14 A. No.
15 Q. How many fire location digital maps will
16 be produced?
17 A. One.
18 Q. What is the area of coverage for that map?
19 A. Holeyland.
20 Q. When was that produced?
21 A. Basically it shows muck fires from 1990 to
22 present, I believe.
23 Q. Who created that map?
24 A. I guess I did.
25 Q. Where did you obtain the data to create
262
1 that map?
2 A. Game and Fish.
3 Q. You testified that you created a
4 topographic map of the Holeyland using the 196 points
5 of data given to you by the Game and Freshwater Fish
6 Commission. Did you make any attempt to ground truth
7 that topographic map?
8 A. No.
9 Q. Do you know whether anyone has?
10 A. I -- I have, to a point, looking at an old
11 survey. It's not that old, but a survey that was done
12 in the Holeyland on ground survey, and I looked at
13 those numbers and -- to see if they were reasonable.
14 Q. What -- were you able to form a judgment
15 as to the accuracy of the topographic map that you
16 created?
17 A. Yeah, I think it's an excellent
18 representation of -- topographically of that area.
19 That's a lot of points to have work with in creating a
20 topographic map.
21 (Mr. Green left the room.)
22 BY MS. RAEPPLE:
23 Q. Could you estimate the percent accuracy of
24 that mapping effort?
25 A. No.
263
1 Q. How did you come into possession of all of
2 these digital maps that you've described?
3 A. All the digital maps that I've described?
4 Q. Yes. Or, in other words, are you the
5 District custodian for digital maps?
6 A. No.
7 Q. Who is the custodian for the digital maps?
8 A. Everyone at the District.
9 Q. So that there is no single entity that's
10 in control of all the digital maps at the District?
11 A. (No response.)
12 Q. Is there any index of all the digital maps
13 that exist at the District?
14 A. Not that I know of. That would be nice.
15 Q. Do you know whether any of the witnesses
16 testifying in this proceeding will be relying on any of
17 the digital maps that you have in your files?
18 A. Can you repeat that again?
19 Q. Do you know whether any of the witnesses
20 testifying in this proceeding will be relying on any of
21 the digitized maps from your files?
22 A. I'm not sure.
23 Q. Do you have any digital maps on soil
24 phosphorus in the Everglades area?
25 A. Yes.
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264
1 Q. How many of those do you have?
2 A. Well, two that I know of.
3 Q. Who created those maps?
4 A. John Richardson and --
5 Q. What -- oh, excuse me, were there other
6 authors?
7 A. No.
8 Q. John Richardson created both of those
9 digital maps?
10 A. No, John Richardson and John Jensen.
11 Q. What area of coverage is the John
12 Richardson soil phosphorus map?
13 A. Area 1.
14 Q. What area of coverage is the soil
15 phosphorus map created by John Jensen?
16 A. Area 2.
17 Q. Do you know the date of the John
18 Richardson Area 1 map?
19 A. I think it's '87, '88.
20 Q. Do you know the date of John Jensen Area 2
21 soil phosphorus map?
22 A. I believe it was '92 or '93 data.
23 Q. Where did John Jensen get that '92 or '93
24 soil phosphorus data, do you know?
25 A. Marguerite Koch.
265
1 Q. Do you know whether either of those maps
2 are preliminary in form or whether they're both final?
3 A. I think they're both final products.
4 Q. If the Water Management District was
5 coordinated with Mark Maffei on the creation of a WCA-1
6 map, who would be doing that coordination, do you know?
7 A. Can you say that again?
8 (Thereupon, Messrs. Fitzgerald and Soukup
9 joined the deposition.)
10 BY MS. RAEPPLE:
11 Q. If the District were coordinated with Mark
12 Maffei to create a WCA-1 map, who would be doing that
13 coordinating on behalf of the District, do you know?
14 A. I'm not sure.
15 Q. But you're not doing any such
16 coordination; is that correct?
17 A. No.
18 Q. I can't recall if I asked you this,
19 forgive me if I'm repeating myself.
20 Are you able to place any percentage of
21 accuracy on Exhibit 10?
22 A. No.
23 Q. Are you able to place a range of
24 percentage for accuracy of Exhibit 10?
25 A. No.
266
1 (Mr. Green returned.)
2 BY MS. RAEPPLE:
3 Q. When I get the digital maps that you've
4 described, will the date of the data used to create
5 those maps be included in the digitized file?
6 A. The only way it might be included is if
7 it's printed on the map.
8 Q. On the hard copy map?
9 A. Or what you're viewing digitally on the
10 screen.
11 (Mr. Downing left.)
12 BY MS. RAEPPLE:
13 Q. Do you know whether all of the digital
14 maps will have a date on them?
15 A. I think a lot of them won't.
16 Q. Will there be any way to determine the
17 date of the data used to create those maps for which no
18 date is shown?
19 A. Probably not.
20 Q. Would you know the date of the data used
21 to create those maps?
22 A. The ones I produced.
23 Q. Do you know the date of the data used to
24 create the one preliminary map for WCA 3?
25 A. May 1992.
267
1 Q. Do you know the date of the data used to
2 create the one preliminary map of the Holeyland that
3 you created?
4 A. May 1992.
5 Q. Do you know the date of the data used for
6 John Richardson to create the WCA-1 map?
7 A. April 1987.
8 Q. For the two WCA-2 maps that you created, I
9 believe we've already discussed this in deposition, the
10 date of that data, haven't we?
11 A. Yes.
12 Q. Okay.
13 And you said there will be no digital maps
14 on the ENR project; is that correct?
15 A. No. Yes, that's correct.
16 Q. How are the vegetation maps that are going
17 to be produced every three months for the ENR project
18 being created? What is the methodology you and Les
19 Vilchek are using?
20 A. They're being flown at two different
21 scales, one 6,000, one at 36,000. We're having
22 1:36,000 digitally scanned into the computer and
23 creating -- we're rectifying that imagery and using it
24 as -- and making a hard copy output and using it as a
25 base map on a zoom transfer scope -- zoom transfer
268
1 scope, it's a stereoscope. And we're actually looking
2 at the photography stereoscopically and drawing on a
3 Mylar overlay over the base map the boundaries of
4 signatures that we see. And we go out in the field and
5 we determine what those boundaries are on the ground.
6 Take that map, that base map once we have all the
7 ground truth information, and digitize it into ARC/INFO
8 to create a final map.
9 Q. How is the 1:6,000 aerial photography
10 used?
11 A. It's what we're actually using to
12 delineate what we're seeing in the area.
13 Q. So the stereoscopic analysis is done on
14 1:6,000?
15 A. Yes.
16 Q. Who is doing the stereoscopic analysis?
17 A. Les Vilchek and myself.
18 Q. What training do you have in stereoscopic
19 analysis?
20 A. I have no training, but it's not that --
21 it's not that difficult of a task. I believe just
22 about anybody could do it.
23 Q. Is the stereoscopic analysis for the
24 purpose of identifying vegetation species?
25 A. Or mixed communities.
269
1 Q. You said that during the stereoscopic
2 analysis you draw boundaries on the map or on Mylar
3 over the base map; is that correct?
4 A. Right.
5 Q. Are those the boundaries between two
6 signatures?
7 A. Yes.
8 Q. And then when you go in the field, do you
9 ascertain what is within those boundaries or do you
10 simply verify what you thought you saw in the
11 stereoscopic analysis?
12 A. You ascertain what you believe that
13 signature to be. You go out in the field and you
14 ground truth it.
15 Q. Talk me about me a little bit about the
16 ground truthing. Do you do it in a helicopter or in an
17 air boat?
18 A. So far it's been air boat.
19 Q. How do you locate -- when you are on the
20 ground do you use GPS?
21 A. Nope.
22 Q. How do you locate where you are on the
23 ground?
24 A. At a 1:6,000 scale I could see something
25 probably size of that folder there, so I could go
270
1 pretty much anywhere I want in that area looking at
2 that photography, know exactly where I'm at.
3 Q. You could see something about 10 inches by
4 14 inches?
5 A. Well, let's say -- let's say 18 by 18.
6 That's being conservative.
7 Q. What kind of things do you see in the
8 1:6,000 that are 18 by 18 inches or larger that help
9 you position yourself on the ground?
10 A. I'm not looking for things that are 18 by
11 18. I'm just looking for general patterns. I'm
12 telling you that you can go -- 1:6,000, it's a real
13 luxury to work with. I can go anywhere I want in the
14 photography and know where I'm at, it's very simple.
15 Q. With what level of precision can you
16 locate yourself on the ground using 1:6,000 aerials?
17 A. If you mean from the point of view when
18 I'm looking at that photo I go to the signature and I
19 go there and standing on, looking at the photo, I'm
20 looking around, I'd say a hundred percent.
21 Q. Can you locate yourself within some number
22 of meters using that methodology?
23 A. Well, after you go back and you transfer
24 it to the base map you know within a certain number of
25 meters where you were.
271
1 Q. Explain that to me.
2 A. Well, when you see a raw photo out in the
3 field, it's not any real world map projection, it's
4 just a raw photo. So I go out in the field, I go to a
5 location, the signature polygon region that I'm
6 uncertain, I go there, we determine what it is, we mark
7 it, we go back. Now put it to the base map, and the
8 base map has been rectified so I can transfer what I'm
9 seeing on the photo on that base map if it's rectified.
10 I now have a location of where that area is at.
11 This is all state of the art
12 photogrammetric -- I'm not inventing the wheel here.
13 It's been used since 1920, 1900's. I mean it's there's
14 volumes and volumes of books written on it, I'm not
15 doing anything out of the ordinary here.
16 Q. How small of a signature area are you able
17 to map using that methodology?