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