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THEREUPON,
TREVOR CAMPBELL
being by me first duly sworn to tell the whole truth,
as hereinafter certified, testified as follows:
DIRECT EXAMINATION
BY MS. NASH:
Q. Mr. Campbell, I'm Beverly Nash, counsel
for the United States in this litigation.
We're here taking these depositions to
find out about the Water Management District's
computers, how they function, what data is on them,
how that data is formatted.
You're here as a representative of the Water
Management District with knowledge of one or more
of the areas in which we're interested.
Have you been shown the list of
categories?
A. Yes, I have.
Q. And do you know which categories you're
responsive?
A. I may have to take a look at that again.
Okay. Categories 1, 2, 3, some of 4, some
of 5, some of 6, some of 7, none of 8, none of 9.
6
Q. What is your present title or position at
the Water Management District?
A. I'm a data base administrator.
Q. In what department or division?
A. Technical services department.
Q. Are you in one of the divisions in that
department?
A. No, I'm not.
Q. What are your job responsibilities?
A. Primarily to coordinate all data base
activities within the district, excluding the
financial and human resource systems.
Q. And how long have you been in that role?
A. Since January of 1989.
Q. Have you had other positions at the Water
Management District?
A. Yes.
Q. What positions?
A. Prior to this position, it was data base
manager in hydrology. Prior to that, it was senior
applications analyst. Prior to that, it was
applications analyst.
Q. And how long were you a data base manager
in hydrology?
A. Roughly a year and four months.
7
Q. And what were your job responsibilities as
a data base manager in hydrology?
A. Primarily to design the new hydraulic data
base. It also included responsibilities to develop
the RFPs for the preprocessing system.
Q. And how long were you a senior
applications analyst?
A. Roughly a year.
Q. In what division were you?
A. At that time, it was a computer
applications division, I think.
Q. What were your job responsibilities as a
senior applications analyst?
A. To develop software systems on request.
Q. And how long were you an applications
analyst?
A. Three months.
Q. And what were your job responsibilities as
an applications analyst?
A. Also to develop software systems on
request.
Q. What software systems did you develop
while you were an applications analyst?
A. For the reference center, I developed the
software systems which cataloged all their holdings
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and on which you could search, via, subject matter,
title, author, ISPA number, and I started the
development of the merit review system.
Q. And what's the merit review system?
A. It's a system used in personnel for our
merit review process. It basically takes your
scores from a green sheet and it scans it into the
computer, via, an optical scanner, and it verifies
that scores are in an acceptable range, and it
does some statistics on the scores, et cetera.
Q. Did you develop any other software systems
while you were an applications analyst?
A. No, I did not.
Q. What software systems did you develop
while you were a senior applications analyst?
A. I continued developmental of the merit
review system. I started to develop the contract
information system. I can't recall any other
systems.
Q. What is the contract information system?
A. The contract information system tracks
contract activities at the district -- a project
manager, contract administrator, when deliverables
are due, and how much -- for how much, among other
things, that I can't remember right now.
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Q. You have indicated that while you were
data base manager in hydrology, you designed the
new hydrology data base?
A. Not completely. We started the design and
the design was maybe 80 percent complete before I
left that job.
Q. Did this hydrology data base have a name?
A. Yes.
Q. What is its name.
A. DB Hydro.
Q. What was the source of the data to be used
in DB Hydro?
A. The source was from the preprocessing
system, from USGS, from another data base called
Rainfall. I'm not sure, but I think the DER may
have something there, too.
Q. What is your educational background?
A. I've got a bachelor's degree in management
science and systems. I've got an MBA in computer
systems management.
Q. And who are your supervisors in the
technical services department?
A. Currently?
Q. Yes.
A. John Lynch.
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Q. Do you have any employees that work for
you?
A. Yes.
Q. What are their job titles?
A. Senior data base analyst, that's it.
Q. Who is that person?
A. Ron Metzger.
Q. What are the computers that you utilize in
your job as data base administrator?
A. The PC, the VAX 8820, the VAX 6310, and
occasionally a work station.
Q. Which of the PCs do you utilize?
A. Which of the PCs do I utilize, the one in
my office.
Q. What model is it?
A. Model 70.
Q. It's an IBM?
A. Yes, it is.
Q. What work do you do on the IBM Model 70?
A. Primarily word processing. It is also
used as an intelligence terminal to connect to the
VAX machines that I access. I do some
presentations and stuff in it with Harvard
Graphics. I do Symphony work sheets.
Q. Are there other software packages that you
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use on the IBM PC?
A. We're still talking about my current job;
is that correct?
Q. That's correct.
A. That's it now.
Q. What work do you do on the VAX 8820?
A. The VAX 8820, I log onto the VAX 8820, and
most times I monitor CPU utilization as far as the
data base systems are concerned.
Q. Do you do any other work on the VAX 8820?
A. Yes.
Q. What is that?
A. I access tables and do bench marking work.
Q. What is the nature of the tables that you
access?
A. What is the nature of the tables that I
access?
MS. STOLLMAN: You can answer if you
understand.
A. Yeah, could you rephrase that one?
Q. (By Ms. Nash) What is the data in the
tables that you access?
A. Okay. The table is called WM underscore
salt underscore data, and it contains some permit
information with some sort of chemical information
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also associated with wells. And I do bench marking
tests on it to determine what the effective indices
are versus how ineffective the table without an
index is. I also access some of the tables in DB
Hydro, again, to do some other things.
Q. What is the data in the tables in DB Hydro
that you access?
A. It's primarily hydrologic information on
weir or gate.
Q. What kind of tests do you do on the tables
in DB Hydro?
A. Bench marking similar to what I do in the
WM_salt_data.
Q. Can you elaborate what you mean by "bench
marking"?
A. Again, I determine how effective the
indices are on the table, whether it increases
performance or not.
Q. Do you do any other work on the VAX 8820?
A. No.
Q. What work do you do on the VAX 6310?
A. As a data base administrator again, right?
Q. Yeah.
A. I really do not do any work on there.
Q. And you indicated that you also utilized a
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work station?
A. Occasionally I have.
Q. Which work station?
A. It's a DEC station 3100.
Q. And what's the type of work you do on the
DEC station?
A. Evaluating the CASE tool.
Q. Can you explain what that is?
A. CASE is an acronym for Computer Assisted
Software and Engineering. It's a method of
designing data bases and developing entity
relationships.
Q. As the coordinator of all the data base
activities in the Water Management District, do you
have an index or a listing of all the data bases in
the division?
A. In the division?
Q. I'm sorry. In the district?
A. Yes, I do.
Q. Does that index or listing have a name?
A. It's called an allocated list of data
bases.
Q. And does that encompass all of the data
bases on all of the computers in the Water
Management District?
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A. I'm sure it does not.
Q. Do you know what percentage of the data
base is in existence in the Water Management
District it does cover?
A. This would be a guess, but --
MS. STOLLMAN: I don't want you to
speculate. If you know, you can answer the
question.
MS. NASH: Well, to the best of his
knowledge.
A. I'd say somewhere between 85 and 90
percent.
Q. (By Ms. Nash) Do you know which divisions
or departments data bases would not be included in
that list?
A. No.
Q. Do you know who might know?
A. No.
Q. With the VAX 8820, what software do you
use on that machine?
A. Oracle.
Q. Any other?
A. No.
Q. And on the DEC work station, what software
do you use?
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A. Oracle's CASE tools.
Q. Any other software?
A. No.
Q. In your role as a data base manager in
hydrology, what computers did you use?
A. The VAX 8820, the VAX 6310, and an IBM PC.
Q. And what work did you do on the VAX 8820
as the data base manager?
A. As data base manager, created tables,
populated the tables with data, created indices on
the tables, that's it.
Q. What was the subject matter of the tables
that you created?
A. Hydrologic data.
Q. And what was the source of that data?
A. The source of the data would be the old DB
Hydro system.
Q. And what was done with the tables you
created?
A. I do not understand.
Q. What use was made of the tables that you
created?
A. That was in the design stage, and the data
base was not fully functional; therefore, no
practical use was made of the data.
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Q. While you were a data base manager in
hydrology, what work did you do on the VAX 6310?
A. Very similar to what I did on the 8820. I
created tables, created indices on the tables. May
I make a correction here?
Q. Certainly.
A. When I was a data base manager, it was not
a VAX 6310. It was a -- it was upgraded after that
to 6310, but it was an 8250.
Q. Was there a reason why you did some of the
creation of tables on the VAX 8820 and some of them
on the other machine?
A. Yes.
Q. And what was that reason?
A. Well, the 8820 came to the district after
the 8250. We were originally using the 8250 to do
our development work, but once the 8820 was there
and up and running, then, we transferred the
development work to the 8820.
Q. And while you were a data base manager,
what work did you do on the IBM PC?
A. I primarily used it to access the VAX
machines, did some word processing work, and then
wrote a couple of -- a few "C" programs.
Q. What software did you use on the IBM PC
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while you were data base manager?
A. Word Perfect, Lattice C, that was it.
Q. What was the subject matter of the "C"
programs that you wrote?
A. I can't recall it.
Q. Did you have any documentation or manuals
to assist you in your work while you were a data
base manager in hydrology?
A. Yes.
Q. What was the names of those -- of that
documentation of those manuals?
A. I cannot remember exactly what it was.
Q. What was the subject matter of the
documentation or manuals?
A. Systems -- the programmer's guide to the
preprocessing system, operators guide to the
preprocessing system, Schema, S-c-h-e-m-a, for the
existing data base hydro. There was some
documentation and some plot routines also.
Q. Was this Schema for the existing data base
hydro a document created within the Water
Management District?
A. Yes, it was.
Q. And who created that document, if you
know?
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A. No, I don't.
Q. And as data base administrator, are there
documentation or manuals that you utilize to assist
you?
A. I use the Oracle manuals, no
documentation.
Q. While you were data base manager in
hydrology, when you were working on DB Hydro, was
that data that was going into DB Hydro from the
Cyber?
A. The data in the existing DB Hydro was in
the Cyber.
Q. Do you know whether all of the hydrology
data from the Cyber has been transferred to the
VAX?
A. Today?
Q. Yes. Do you know?
A. It has not been.
Q. Do you know how much of it has been?
A. No.
Q. Do you know who would know?
A. Yes.
Q. Who is that?
A. Brian Turcotte.
Q. You indicated your present responsibility
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is to coordinate all data base activities?
A. That's correct.
Q. What does that entail?
A. It entails developing standards for data
base development, relational data base
development. It entails insuring that data bases
that are being developed in the district supports
the district's mission. You've got to minimize
system redundancy, develop an annotative list of
data bases, develop a data base migration plan,
that's what it is primarily.
Q. What does a data base migration plan do?
A. It's -- the Cyber is leaving the district,
and there are a number of data bases which are on
the Cyber, which should be migrated to a different
hardware platform. There are also a number of data
bases on PCs in a Data Flex package, which should
also be migrated to a different hardware, software
platform, as we'd like to consolidate data base
development in one environment.
Q. Do you know when the Cyber will be leaving
the district?
A. Not exactly, no.
Q. And this annotated list of data bases
you're developing, do you know how many data bases
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are in that list at the present time?
A. Roughly, it's 96 tabular data bases and
roughly 40 GIS or spatial data bases.
Q. Do you know who is developing GIS data
bases?
A. Some of the people.
Q. Which of the people do you know?
A. Bob Brown, Brent Moll, maybe Dave Black
Bill Haight, Dennis Meierer, that's it.
Q. Which of the computers are being utilized
to develop the GIS data base?
A. Work stations, SUN work stations.
Q. Any others?
A. I'm not sure.
Q. This annotated list of data bases you've
referenced, where is that located? Is it on one of
the computers?
A. It's on a floppy disk somewhere.
Q. Does that floppy disk have a name?
A. No, it does not.
Q. And where is that floppy disk physically
located?
A. I think Bert Price has it. I'm not sure.
Q. Who is Bert Price? What is his title?
A. She's a secretary for the department.
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Q. In the tests that have been done on data
base development, is any spatial data being used?
A. What tests are you making reference to?
Q. You referenced doing tests to access
tables in DB Hydro, for example, is any spatial
data utilized in those tests?
A. In a limited sense.
Q. What is the spatial data that is being
utilized?
A. Location.
Q. Where is that location information taken
from?
A. I don't know where it's taken from.
Q. In what format is that spatial data
provided to do the testing?
A. I do not understand that question.
Q. If spatial data is being utilized to do
testing, how is it -- in what format is it in
existence to do the testing?
A. I made reference to location, and that's
the only spatial quality of the data that was being
tested.
MS. NASH: All right. I have no
further questions.
MS. STOLLMAN: Do you want to take a
22
break before we continue?
THE WITNESS: No.
CROSS-EXAMINATION
QUESTION BY MR. RICHARDS:
Q. My name is Joe Richards. I represent the
cities of Belle Glade and Clewiston.
In reference to the annotated list of data
bases, would that list have any indication as to
the subject matter of the different data bases?
A. It has -- yes.
Q. To what detail would that indicate the
subject matter?
A. Two or three sentences on the
functionality.
Q. And you mentioned several individuals
developing GIS data bases, do you know whether any
of these data bases are operational?
A. No, they're not.
Q. As the data base manager, are you aware of
entities outside the district having access to any
of the computer systems?
A. As a data base manager, yes.
Q. What entities?
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A. Oracle Corporation.
Q. Any others that you're aware of?
A. No.
Q. Are you aware of whether any of the
computer systems of the district are capable of
providing outside access to entities?
A. Yes.
Q. Which systems?
A. The VAX 8820.
Q. Any others?
A. The Cyber. That's it.
Q. You are not aware of any other systems --
MS. STOLLMAN: What is your question.
Q. (By Mr. Richards) -- that are capable of
providing outside access?
A. Capable of providing access. The VAX 6310
is capable of it. I'm not aware of any others.
Q. For these three systems you named, are you
aware of whether they provide read only access?
A. No.
Q. Who would know?
A. Bill Hall.
Q. Are you aware of whether the district has
any formal guidelines or policies on quality
assurance and quality control for the data bases?
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THE WITNESS: Can I talk to you for a
second?
MS. STOLLMAN: Off the record.
(WHEREUPON, there was a discussion
held off the record.)
MR. RICHARDS: Could you read back
the last question?
(WHEREUPON, the requested testimony
was read back by the court reporter.)
A. No.
Q. (By Mr. Richards) No, you are not aware
of any?
A. Yes.
Q. Are you aware of any policies or
guidelines for maintaining data base integrity?
A. Yes.
Q. Are those policies in a written format?
A. You said "policies or guidelines." We have
guidelines, not policies.
Q. Are the guidelines in a written format?
A. In a sense.
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Q. Where are they written?
A. They're taken into consideration when the
data bases are being designed.
Q. Are those guidelines written down
somewhere in a manual?
A. It would be part of the documentation of
the data base.
Q. While at the district, are you aware of
any accidental loss of data?
A. No.
Q. Are you aware of the accidental loss of
any of the data for the DB Hydro data base?
A. No.
Q. While you were designing the new DB hydro
data base, was that system designed to provide
read only access?
A. The system is designed to provide read,
write access, but depending on the user, you may
only have a particular type of access to it.
Q. So it is possible to provide read only
access?
A. Yes, it is.
Q. Do you believe that allowing read only
access to the DB hydro data base would degrade the
system's performance?
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A. It depends.
Q. What would that depend on?
A. How many users are reading.
Q. Do you know how many users can utilize
that system at one time?
A. That's a function of the operating system.
Q. Do you know who would know that for the DB
Hydro data base?
A. Again, that's a function of the operating
system, and Bill Hall would know that.
Q. Are you aware of any computer work for the
Everglades Nutrient Removal Project?
A. No.
Q. The Holeyland Restoration Project?
A. No.
Q. The Water Management Area proposal in the
Everglades SWIM Plan?
A. No.
Q. Do you have any idea when the transfer
from the Cyber to the 8820 of the DB Hydro data
base will be completed?
A. Any idea?
Q. Do you know?
A. Roughly, yes.
Q. When?
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A. By April of next year.
Q. In reference to the transfer of the DB
Hydro to the VAX computer, are you familiar with
the Oracle data base programming language?
A. Yes.
Q. Do you know who designed the templates for
entry of data into the Oracle data base?
A. The templates of entry has not been
designed yet.
Q. Do you know whether, once the transfer is
completed, will the hydrology data be available to
others who request it in Oracle data base format?
A. I don't know who it's going to be
available to.
MR. RICHARDS: Thank you. I have no
further questions.
(The deposition was concluded at 9:33
o'clock a.m.)
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I, TREVOR CAMPBELL, do hereby certify
that I have read the foregoing transcript of my
deposition given on 28th day, August, 1990; that
together with the correction page attached hereto
noting changes in form or substance, if any, it is
true and correct.
_____________________________
TREVOR CAMPBELL
I do hereby certify that the
depostion of DAVID W. BLACK was submitted to the
witness for reading and signing; that after he had
stated to the undersigned Notary Public that he had
read and examined his depositon, he signed the
same in the presence of the undersigned authority
on the _____ day of ____________, 1990.
_____________________________
Notary Public
My Commission expires: _______
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