** 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 88-1886-CIV-HOEVELER UNITED STATES OF AMERICA, et al., ) ) Plaintiffs, ) ) VS. ) ) SOUTH FLORIDA WATER MANAGEMENT ) DISTRICT; JOHN R. WODRASKA, ) EXECUTIVE DIRECTOR, SOUTH FLORIDA ) WATER MANAGEMENT DISTRICT; ) FLORIDA DEPARTMENT OF ENVIRONMENTAL ) REGULATION; AND DALE TWACHTMANN, ) SECRETARY, FLORIDA DEPARTMENT OF ) ENVIRONMENTAL REGULATION, et. al., ) ) Defendants. ) / DEPOSITION OF SHARON TROST TAKEN ON BEHALF OF THE PLAINTIFF *** DATE: August 27, 1990 PROFESSIONAL REPORTING SERVICE Commerce Center 324 Datura Street, Suite 303 West Palm Beach, Florida 33401 (407) 659-4046 ** 2 INDEX August 27, 1990 DIRECT CROSS REDIRECT RECROSS SHARON TROST By Ms. Beverly Nash 5 By Mr. Joe Richards 29 ** 3 The deposition of Sharon Trost, in the above-entitled and numbered cause, was taken before me, KAREN BAUER FRY, C.S.R., Court Reporter and Notary Public for the State of Florida at Large, at Professional Reporting Service, Commerce Center, 324 Datura Street, in the City of West Palm Beach, Palm Beach County, in the State of Florida, beginning at the hour of 12:10 o'clock p.m., on August 27, 1990, pursuant to the Notice in said cause for the taking of said deposition, which is annexed to the Court file herein, on behalf of the Plaintiff in the above-entitled action pending in the above-named court. The appearances at said time and place were as follows: Beverly Sherman Nash, Esquire U.S. Department of Justice Environmental and Natural Resources Division P. O. Box 663 Washington, D.C. 20044-0663 Attorney for Plaintiff Joseph Richards, Esquire Peeples, Earl & Blank, P.A. Two South Biscayne Blvd. One Biscayne Tower, Suite 3636 Miami, Florida 33131 Attorney for Cities of Belle Glade and Clewiston ** 4 Katharine Stollman, Esquire Allison Burdette Skadden, Arps, Slate, Meagher, & Flom 1440 New York Avenue, N.W. Washington, D.C. 20005 Attorney for South Florida Water Management District Jackie Waters, Esquire So. Florida Water Management District Box 24680 3301 Gun Club Road West Palm Beach, FL 33416 ALSO PRESENT: Toni Lafuente Mike Rose David Buker ** 5 THEREUPON, SHARON TROST being by me first duly sworn to tell the whole truth, as hereinafter certified, testified as follows: DIRECT EXAMINATION BY MS. NASH: Q. Ms. Trost, I'm Beverly Nash, counsel for the United States in this litigation. We're here to find out what the Water Management District has in the way of computers, and what the information is on that computer, how it's stored, how it's formatted. You're here today as a representative of the Water Management District having knowledge concerning one or more of several areas that we are interested in finding out about. Have you been shown the list of categories? A. Yes. Q. And which category or categories are you here to respond to? A. I would need to see the list again. I know a little bit in general about No. 1, No. 2, ** 6 No. 6, and No. 7. Q. What is your present title or position? A. I'm the director of the water supply planning division. Q. And what is your job description? A. I'm responsible for the development of four regional water supply plants that cover the geographic area of the district. In these plants, we're going to project the future water demands for both agricultural, urban and environmental use; and we will also quantify the available supply through the use of computer models that simulate surface water and ground water availability. After we make a comparison of the supply and the demand, then, we would prepare a plan that would describe what to do in areas where we did not have adequate water. Q. How long have you been in the roll of the director of the water supply planning division? A. Since October 1st of 1989. Q. Have you been in any other positions at the Water Management District? A. Yes, I have. Q. What positions are those? ** 7 A. I was the director of the Hydrogeology Division from September of '85 till October of '89. Q. Any others? A. Yes. And prior to that, I held various levels of the hydrogeologist, professional hydrogeologist position from November of 1980 to September of '85. Q. And what were your job responsibilities as director of the Hydrogeology Division? A. I was responsible for developing and overseeing broad based ground water resource assessment studies, overseeing the district's well drilling geophysical logging operations, and aquifer testing operations, directing the preparation of ground water simulation models, and the writing of technical reports, preparation of map series that described water availability. Q. What's your educational background? A. I have a Bachelor of Science in geological science from Lehigh University in Bethlehem, Pennsylvania. I attended graduate school at the University of Arizona in Tucson, Arizona in the hydrology and water resource administration program. Q. Who are your supervisors at the Water ** 8 Management District? A. Jim Harvey and Dick Rogers. Q. What is Mr. Harvey's title? A. Deputy director of the planning department. Q. And Mr. Rogers? A. Director of the planning department. Q. Do you have employees who work for you in the water supply planning division? A. Yes, I do. Q. And how many? A. 17. No, I guess it would be 19 counting temporaries. Q. What is the nature of their positions? A. I have a number of different disciplines that report to me, including engineers, hydrogeologist, supervising professionals, programmer analyst, staff economist, staff water use planners, staff water use engineer, GIS CADD technician, administrative secretary, and temporary planning technicians. Q. What computers are utilized in the water supply planning division? A. We utilize personal computers, IMB personal computers, which vary between ATs, PS2, ** 9 Model 70's, compacts. We use a SUN work station, and a DEC work station, and we use the mainframe computer? Q. Is that the Cyber mainframe? A. Yes. Q. What work was done on the Cyber mainframe? A. On the Cyber mainframe, we extract data from the hydrologic data base, such as, rainfall information or other information that would be input into one of the ground water simulation models. Q. Any other uses of the Cyber? A. Not that I'm aware. It's just a storing house of data. Q. And what use is made of the DEC work station? A. The DEC work station is used to run the ground water simulation models. Q. Is there more than one ground water simulation model? A. No. The one that we're using now is called the Modflow Model. There are a lot of different models, but we're not using anything other than that one for our work purposes. Q. And how long have you used the Modflow ** 10 Model? MS. STOLLMAN: I object to that question. I don't think it's relevant to this deposition how long she's used a certain model. MS. NASH: It's extremely relevant if there are other models that were used during the relevant time frame, Katharine; and that's what I'm trying to find out. MS. STOLLMAN: Okay. Well, you've asked her if there are other models -- MS. NASH: Well, we can either spend the time and go through every single model and she can tell me when she used it or she can tell me simply how long this one has been in use and that may alleviate all the other questions on that, so you can have it either way you want. MS. STOLLMAN: You can answer it to the extent that you know of other models that were used. A. I don't know of any other models that were used by my staff, and I believe that we've used the Modflow since 1986; and I don't know when in 1986. Q. (By Ms. Nash) Okay. Is there other work that's done on the DEC work station? A. All the work that we're doing on the DEC ** 11 work station in my division is -- has to do with running the models. Sometimes you have files set up that have the input data for the models, sometimes the station is used to process the model to run the actual model. Q. What work is done on the SUN work station? A. The same as what's done on the DEC work station. Q. And what work is done on the IMB PC? A. The IBM PC's are used for word processing, routine correspondence, for developing the annual operating budget of my division, and for any other data manipulation that the staff would do before they would get ready to actually run a model. Q. What is the software that's used on the Cyber? A. The Cyber doesn't really use software. It's a mainframe computer that -- it's a text editor that's on the Cyber. Q. Does that text editor have a name? A. When I used it, it was called X Edit. I do not know what it's called now. Q. What is the software that's utilized on the DEC? A. I don't know the names of any specific ** 12 software on the DEC. There is one called -- there is one called LINDO? Q. What software is utilized on the SUN work station? A. Just the Modflow Model, which would also be used on the DEC. Q. And what software is utilized on the IBM PC? A. I don't know the names of all the software utilized on the IBM PCs, but some items would be: Symphony Spreadsheet, Harvard Graphics, Auto/CADD, Word Perfect; and then, there is some communication mechanisms to communicate with the other PCs in the mainframe computer. Q. Do you know what those communication mechanisms are? A. I don't know exactly what they're called, but I just know that they enable us to allow different machines to talk to each other. Q. Has your division done any water supply studies on the computer relating directly to the Everglades Agricultural Area? A. My division has not. Q. Do you know whether any such studies have been done relating to the Everglades Agricultural ** 13 Area or other divisions? MS. STOLLMAN: You can answer to the extent that you know. A. The Water Resources Division has performed some modelling work that I coordinated, but that's another division down the hall from my division. Q. (By Ms. Nash) Do you know whether your division has done any modelling work on the Water Conservation Areas? A. My division has not. Q. Do you know whether other divisions in the Water Management District have? A. Yes, the Water Resources Division. Q. Has your division done any water modelling on the Everglades National Park? A. No. Q. Do you know whether other divisions have? A. I don't know. Q. Has your division done any water modelling on the Holeyland tract? A. No. Q. Do you know whether other divisions have? A. I think the Water Resources Division may have. Q. Has your division done any water modelling ** 14 on the Rotenberger tract? A. No. Q. Do you know whether other divisions have? A. I think the Water Resources Division may have. Q. Has your division done any water modelling from the Everglades SWIM plan? A. My division has not, however, I coordinated an assignment for that with the Water Resources Division. Q. What was the source of the information that went into the water modelling for the SWIM plan? MS. STOLLMAN: Are you referring to "the source of the information," what computer system that came from? MS. NASH: No. A. I'm not sure I understand the question. Could you rephrase it? Q. (By Ms. Nash) Yes. The information that was utilized to do the water modelling for the Everglades SWIM plan, where did it come from? A. I don't know exactly where it came from. Q. Who would know? A. Someone in the Water Resources Division. ** 15 Q. What was your job in coordinating the modelling for the SWIM plan? MS. STOLLMAN: You can answer to the extent that it related to your work for the computers? A. I was not specifically working with the computers for that assignment. Q. (By Ms. Nash) Do you know who was? A. Ray Santee and Paul Trimble. Q. Do you know what data bases they utilized to do the water modelling? A. No, I don't. Q. Did you do any water use modelling before the Lake Okeechobee Technical Advisory Committee? MS. STOLLMAN: Again, this is limited to water modelling done on the computer system. A. No, I didn't do any modelling for the LOTAC Committee. Q. (By Ms. Nash) Do you know whether any water modelling was done for LOTAC? A. I don't know. I'm not sure. Q. Do you know who might know? A. Paul Whalen or Tony Federico. Q. Has your division done any water modelling for the proposed water management areas? ** 16 A. That was the assignment that I coordinated with the Water Resources Division. Q. But you don't know what data bases were used for that? A. No. Q. Did your division do any water modelling for the nutrient removal project? A. No. Q. Has your division done any water modelling for agricultural area Best Management Practices? A. No. Q. You testified that you're responsible for developing four water supply plants, what are the areas encompassed by those plants? A. The entire area of the district is encompassed by the plants. The district is broken into four geographic areas. Q. What are the four geographic areas? A. The upper east coast, the Kissimmee basin, the lower west coast and the lower east coast. Q. What is the present status of the plants for the lower west coast? MS. STOLLMAN: Again, this would be limited to plants which are on the computer. ** 17 Anything that you work on with respect to the computer system, not your other responsibilities. A. There is a model developed for the lower west coast that we're going to use to prepare the water supply plant for Lee County. The model is for Lee County. We still have a long way to go until that plant is ready. Q. (By Ms. Nash) What is the status on the plant for the lower east coast? MS. STOLLMAN: I would object to any questions about plants that are in development for which there is data involved in the system. MS. NASH: But she can answer the question. MS. STOLLMAN: Could you repeat the question, please? MS. NASH: Let's read back the question. (WHEREUPON, the requested testimony was read back by the court reporter.) MS. STOLLMAN: Could you clarify the question, please? MS. NASH: It's the same question I ** 18 asked about the lower west coast that she was capable of answering, so I'm sure she understands the question. A. At this point in time, we only have a framework laid out for the task that must be accomplished to write the plan. We have not initiated any of the modelling for the plant. Q. (By Ms. Nash) You mentioned that when you were director of the Hydrogeological Division -- A. Hydrogeology Division. Q. -- Hydrogeology Division, you prepared ground water simulation models? A. They were prepared under my direction, yes. Q. Can you describe those models? A. The first one to be completed under my direction was the Palm Beach County Three-dimensional Ground Water Assessment Model. The second one to be completed was the Hendry County Three-dimensional Water Assessment Model. The third one was the Lee County Ground Water Assessment Model. Possibly the Lee County was done a few months before the Hendry, but they're within a few months of each other. I'm not ** 19 sure of the order. Q. Was actual data utilized in the Palm Beach County Assessment Model? A. What do you mean by "actual data"? Q. Real data. Was real data utilized in the Palm Beach County? A. Yes. Q. What was the source of that data? A. Water level measurements, rainfall data, evapo transpiration data, aquifer perimeter data. Q. And from where was the water level measurement data obtained from? A. The U.S. Geological Survey and from our own network. Q. In what format was the data from USGS? MS. STOLLMAN: This is the computer format. A. Yeah, but I don't know. I don't know. Q. (By Ms. Nash) In what format was the data from your own network? A. I don't know. Q. Who would know the format of the data from USGS? A. I'm not sure. I think I know. MS. STOLLMAN: Well, I don't want you ** 20 to speculate if you don't know. A. Okay. I'm not sure. Q. (By Ms. Nash) Who would know the format of the Water Management District's data? A. What data? Q. You said it was data from -- you also utilized data from your own network? A. Maryjo Shine, S-h-i-n-e. Q. What was the source of the rainfall data that you utilized? A. The district's hydrologic data base. Q. And where is that data base located? A. On the mainframe computer. Q. And where is the evapo transpiration data from? A. It's also on the hydrologic data base, and through published reports. Q. The reports published by whom? A. I'm not sure, but probably a combination of the Water Management District and the U.S. Geological Survey. Q. I believe you also mentioned absorption data? A. No, I did not mention absorption data. Q. You mentioned aquifer perimeter data? ** 21 A. Yes. Q. Where was that data from? A. We collected that data in the field. Q. Your division collected that data? A. Yes. Q. In what manner was that data collected? MS. STOLLMAN: I object to that question. I don't think the manner for the collection of data is relevant. MS. NASH: You can answer the question. MS. STOLLMAN: You can answer to the extent that you know. A. First, the hydrogeologist figures out where they need information to develop the model, then, they decide where -- MS. STOLLMAN: Let me interrupt you for a minute. I think that your answer is going to go well beyond the scope of this deposition, and I instruct the witness not to answer. MS. NASH: We're entitled to know where the data came from. MS. STOLLMAN: And you know where it came from. They collected it at the district. You're not entitled to know how they set out to ** 22 collect it and the perimeters they used. MS. NASH: To the extent that it leads to the computerization of data, we are most certainly entitled to know that. MS. STOLLMAN: But her answer clearly was going beyond the computerization of data, and I don't think it's relevant to this deposition. MS. NASH: Let her finish the answer and we'll find out. MS. STOLLMAN: I'm not going to have you go on a fishing expedition. She began her answer. It was clearly well beyond anything having to do with the computers. MS. NASH: You don't know that, because they may have used computers out in the field. If you'd let her finish the answer, she can answer that question. MS. STOLLMAN: Well, if you'd like to ask her if they used computers out in the field, you may do so. MS. NASH: Let her finish her answer. MS. STOLLMAN: She may not answer the question that you asked. If you would like to ask her, if they used computers out in the field, you may do so. ** 23 Q. (By Ms. Nash) The question is: What is the source of the aquifer perimeter data that was utilized in the Palm Beach County Ground Water Assessment Data? MS. STOLLMAN: And to the extent that the sources are computer sources, she may answer the question. MS. NASH: We're also entitled to know where the data came from that got into the computer. MS. STOLLMAN: You've asked that question and it has been answered. MS. NASH: She has not answered the question. MS. STOLLMAN: The district collected it. That's an answer. MS. NASH: Fine. And they need to know where it collected it and when it collected the data, so that we know what data we're accepting from. MS. STOLLMAN: Well, if you'd like to ask questions along that line to know when the data is from that are in the files, those are different questions from the ones that you have asked. MS. NASH: That's correct. And I ** 24 will get to them after I find out where the data is from. THE WITNESS: I fail to see what any of this has to do with -- this is all ground water information of an aquifer. MS. STOLLMAN: You don't need to testify when there is no question pending. THE WITNESS: Sorry. Q. (By Ms. Nash) The question is: Where is the aquifer perimeter dated from? MS. STOLLMAN: I believe that's been asked and answered. MS. NASH: No, it has not. I will ask again. Q. (By Ms. Nash) Where is the aquifer perimeter data collected from? MS. STOLLMAN: That's been asked and answered. MS. NASH: It has not been answered. MS. STOLLMAN: Perhaps we could go back into the transcript, the last question before the one that is currently pending. (WHEREUPON, the requested testimony was read back by the court reporter as follows:) ** 25 Q. (By Ms. Nash) Where was that data from? A. We collected that data in the field. Q. Your division collected that data? A. Yes. (WHEREUPON, the deposition continued as follows:) Q. (By Ms. Nash) Where in the field was that the data collected? A. At several sites in Palm Beach County. I don't know the exact locales. Q. Is there a record of where those sites are? A. Yes. Q. Where is that record? A. In the technical publication which describes the study. Q. What is the name of the technical publication? A. Ground Water Resource Assessment of Eastern Palm Beach County, Florida. Q. What is the date that that was published? A. I don't know. I believe 1988. ** 26 Q. Has your division done any work on the regulation schedules? A. What regulation schedules? Q. Regulation schedules in the Water Conservation Areas? A. No. My division has not. Q. Has your division done any work in the Water Conservation Areas on drought impact? A. No, we have not. Q. You indicated one of your employees is a GIS CADD technician? A. Yes. Q. What is the nature of the work that this employee does in GIS? A. She doesn't yet do any work in GIS. She does work in CADD. Q. What's the nature of the work she does in CADD? A. She makes maps for our publications and for presentations. Q. For what projects has she made maps? A. For every project since she's worked in our division, and I wouldn't recall exactly which ones. Q. What's the name of this technician that's ** 27 doing your CADD work? A. Cynthia Whalen. Q. You indicated when you were with the Hydrogeology Division, you wrote technical reports on water availability. A. Uh-huh. Q. Do those reports have specific names? MS. STOLLMAN: Are these reports -- A. Which reports are you referring to? Q. (By Ms. Nash) I'm trying to find out what ones you wrote while you were -- A. Ones that I wrote or that my staff wrote? Q. That your staff wrote. MS. STOLLMAN: You may answer to the extent that these are reports that you wrote using the computer. A. The three major ones are the ones I have mentioned already. The Palm Beach County Perimeter Resource Assessment Report; the Lee County Three-dimensional Ground Water Flow Model Report; and the Hendry County Ground Water Resource Assessment Report. Q. (By Ms. Nash) When was the Lee County report done? A. The Lee County report was done in 1989. ** 28 Q. And the Hendry County report? A. In 1989, I think. Q. Is the work you do on the DEC backed up in any fashion? A. I don't know how they do that. Q. Who would know? A. The programer analyst. Q. And who was that? A. Pattie Everett. Q. Is the work done on the SUN work station backed up? A. I don't know. If it is, it would be the same answer as for the DEC. MS. NASH: I have no further questions. MS. STOLLMAN: Do you want to take a break before we continue? THE WITNESS: Yeah. I'd like to have a glass of water. (Short break.) ** 29 CROSS-EXAMINATION QUESTIONS BY MR. RICHARDS: Q. Ms. Trost, my name is Joe Richards. I represent the cities of Belle Glade and Clewiston. You mentioned you were aware of a modelling for the EAA by the Water Resources Division. Do you know what individual would be responsible for that project? A. As I mentioned before, it would probably be Mr. Trimble or Mr. Santee. Q. And that would be the same for the one you mentioned regarding the Water Conservation Areas? A. Yes, because it's all one model. Q. Any other areas that pertain to that model besides EAA and the water conservation area? A. I'm not sure of the full geographic extent of that model. Q. Are you aware of any water supply study or modelling for the City of Belle Glade? A. No, I'm not. Q. How about the City of Clewiston? A. No, I'm not. Q. This water supply study that may be being performed by Mr. Santee and Mr. Trimble, do you ** 30 know to what extent that is being performed, what it entails? A. I don't understand the question. Q. The water supply modelling for the EAA in the conservation areas, could you explain that? MS. STOLLMAN: She's testified that she doesn't work on it. You can answer to the extent that you know. MR. RICHARDS: Well, she said she coordinated it so -- A. The analysis was to determine the potential -- MS. STOLLMAN: Again, I think the answer to this question is going to go beyond the scope of this deposition. MR. RICHARDS: I'm sure that this work is being performed on a computer, if that's your concerned. MS. STOLLMAN: Whether it's being performed on a computer or not is not my sole concern. You have identified a water model. You have identified where it exists, and who works on it. This witness does not work on it, and she's not here to testify in detail about how the models ** 31 are set up. She's here to testify about water models -- MR. RICHARDS: I think it's perfectly reasonable that I -- MS. STOLLMAN: -- and where they are located on the system. MR. RICHARDS: -- inquire into the general nature of this model that she identified. MS. STOLLMAN: You have already done so. MR. RICHARDS: She just indicated the location. MS. STOLLMAN: And what type of water model it is. MR. RICHARDS: I don't think she got to identify the type. MS. STOLLMAN: What was your question? MR. RICHARDS: Could you read back the question? (WHEREUPON, the requested testimony was read back by the court reporter.) MS. STOLLMAN: I think your question ** 32 goes well beyond the scope of this deposition. To the extent that you need more information to identify where the models are located, you may ask questions. To the extent that you want to know how the models operate, that is inappropriate at this time. MS. NASH: It is not inappropriate, Katharine, because No. 7 clearly says: "The locations (where prepared and where maintained) of all water use modelling performed and the techniques used," and that is what Mr. Richards is trying to inquire into. MR. RICHARDS: I think you're unreasonably limiting the inquiry here. I mean, she identified a model, but we don't know what type of model it is other than water supply; and it's perfectly reasonable for us to inquire a little deeper into this area. MS. STOLLMAN: I think it's reasonable to inquire to the extent that you need to know where these models are located and what's -- MR. RICHARDS: Well, we need to know what type of model it is, what it entails, what the goals are, so I can know whether we need it or ** 33 not. That's the whole purpose of this deposition is to find what data you have and where it's located. MS. STOLLMAN: I understand that. MR. RICHARDS: So I need to be able to ask these questions to make those determinations. MS. STOLLMAN: Well, as an initial matter, this witness has testified that she did not specifically design the model. She helped coordinate it. I don't want her to speculate on things that she does not know. And No. 2, I think as a general matter, you may inquire as to what exists on this model, but not as a specific -- not to the level of detail that you have been inquiring. MR. RICHARDS: I'm just seeking general information. She identified a model, a water supply model, and that's all she said. I just want to ask a few more questions about the type of model and what's entailed. MS. STOLLMAN: But I don't believe that what is entailed in the model is an appropriate question. If you want to get information that will assist you in knowing what is ** 34 contained on the model as opposed to another model so that you can know which you would like to obtain, that is a general question which I would permit the witness to answer. I will not permit her to answer questions which go into the detail of every element of the model, how it was designed, and how it was set up. MR. RICHARDS: The techniques were specifically asked for in the subpoena. MS. STOLLMAN: The question reads: "The locations (where prepared and where maintained) of all water use modelling performed and the techniques used, for the Everglades SWIM plan, LOTAC I, LOTAC II, proposed WMAs, the ENR Project, EAA BMPS, the Water Conservation Areas and Everglades National Park." I think it's our interpretation that the techniques used are the computer techniques which were used to design the models and where those models are located on which computers. It's not the techniques used in terms of what the model is going to tell you and why they were set up in that way. MR. RICHARDS: So are you instructing her not to answer my question? ** 35 MS. STOLLMAN: She can answer your question to the extent it's limited to general information required to enable you to locate the models and to know how one model may differ from another so that you can determine if you are interested in obtaining that model. Q. (By Mr. Richards) Ms. Trost, do you know what models were used for this study you identified? MS. STOLLMAN: What study are you referring to? MR. RICHARDS: The EAA WCA water model that you've identified. A. I believe the South Florida Water Management Model was the model used. Q. (By Mr. Richards) Do you know who developed the model? A. No, I do not. Q. Do you know who would know? A. I think, Mr. Trimble or Mr. Santee would know. Q. You stated that your division hadn't performed any modelling for the EAA BMPs, do you know what division would be doing that work? A. No, I am unaware of any model of that ** 36 nature. Q. Are you aware of any model for the Everglades Nutrient Removal Project? A. No, I'm not. Q. Of the four regions you mentioned, which of those regions would include or encompass the EAA? A. The lower east coast region. Q. And that would be the same for the Water Conservation Areas and Everglades National Park? A. Yes. Q. The ground water simulation model for Hendry County, has that been published? A. No, it has not yet been published. Q. When do you expect it to be published? MS. STOLLMAN: I object to that question. I don't think the date of publication is relevant. You may answer the question. A. Probably within the next 90 days. Q. (By Mr. Richards) Do you know if the entire county is included in that report? A. Yes, it is. Q. And the Palm Beach County study that you mentioned, that was only for the eastern part of ** 37 the county? A. Yes, it was. Q. Do you know the approximate location of the western extent of that study? A. South of C-51 -- the western boundary is the outside of the conservation areas. North of the C-51, it extends up through the Calusa properties. Q. Ms. Nash asked you about the WCA regulation schedules and you said that you weren't aware -- that your division wasn't doing work on that. Do you know what division would be responsible for that work? A. Of what work? Q. Work with the regulation schedules for the Water Conservation Areas. MS. STOLLMAN: That's assuming a fact not in evidence. You haven't asked her whether there are any. A. I'm not aware that there are any. Q. (By Mr. Richards) Are you aware of any drought impact studies for the Water Conservation Areas? A. No. Q. Everglades National Park? ** 38 A. No. Q. EAA? A. No. Q. What about the urban areas of the east coast? A. What about them? Q. Are you aware of any drought impact studies and water supplies for the urban areas in the east coast? A. No. Q. Do you know what division would be responsible for drought impact work, if it was done? A. The Water Resources Division. MR. RICHARDS: I don't have any further questions. I want the record to reflect that I believe that Ms. Stallman has unreasonably limited the area of questioning with this witness as to work that she has coordinated and has prevented us from knowing what water modelling has been done for the specific areas, questions that will prevent us from properly identifying work that we would request, and may lead to the further need for deposition. ** 39 MS. STOLLMAN: I would just like to state that Mr. Richards is welcome to ask this witness which models are used for which projects, but I'm not permitting the witness to answer about specific elements of the models and how they were set up. MR. RICHARDS: I believe we have questioned other witnesses into the nature of their work, and their purposes, and goals; and that at this late juncture in this deposition, I believe you are unreasonably restricting inquiry. MS. STOLLMAN: Well, it's my view that the previous questions were designed to elicit information that was required to identify what different data bases and files were used for so that you could know which ones you were interested in obtaining. The questions here today with respect to these water models go well beyond that. Questions similar to the ones asked in the past, would be appropriate. MR. RICHARDS: I think the line of questioning has been similar throughout this deposition. That's all. I have no further questions for this ** 40 witness. (The deposition was concluded at 1:00 o'clock p.m.)