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KEMP, PH D, G. PAUL11/27/2007

Johns Pendleton Court Reporters 800 562-1285

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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF LOUISIANA

IN RE: KATRINA CANAL BREACHES CIVIL ACTION

CONSOLIDATED LITIGATION NO. 05-4182 K2

JUDGE DUVAL

PERTAINS TO: MAG. WILKINSON

Robinson, No. 06-2286

Deposition of G. PAUL KEMP, PH.D.,

given at the offices of Lambert & Nelson,

P.L.C., 701 Magazine Street, New Orleans,

Louisiana 70130, on November 27th, 2007.

REPORTED BY:

JOSEPH A. FAIRBANKS, JR., CCR, RPR

CERTIFIED COURT REPORTER #75005

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1 APPEARANCES:2 REPRESENTING THE PLAINTIFFS:3 O'DONNELL & ASSOCIATES, PC4 (BY: PIERCE O'DONNELL, ESQUIRE)

5 550 South Hope Street, Suite 10006 Los Angeles, California 900717 213-347-02908 - and -9 F. GERALD MAPLES, P.A.

10 (BY: TODD CAMPBELL, ESQUIRE)11 902 Julia Street12 New Orleans, Louisiana 7011313 504-569-873214 - and -15 BRUNO & BRUNO16 (BY: FLORIAN BUCHLER, ESQUIRE)17 855 Baronne Street

18 New Orleans, Louisiana 7011319 504-525-133520 - and -21 LAMBERT AND NELSON22 (BY: HUGH P. LAMBERT, ESQUIRE)23 701 Magazine Street24 New Orleans, Louisiana 7013025 504-581-1750

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1 - and -2 LAW OFFICE OF ELWOOD C. STEVENS, JR.3 (BY: ELWOOD C. STEVENS, JR., ESQUIRE)

4 1205 Victor II Boulevard5 Morgan City, Louisiana 703806 985-384-86117 - and -8 ANDRY LAW FIRM9 (BY: JONATHAN B. ANDRY, ESQUIRE)

10 610 Baronne Street11 New Orleans, Louisiana 7011312 504-586-889913 - and -14 LAW OFFICE OF DANIEL E. BECNEL, JR.15 (BY: DARRYL BECNEL, ESQUIRE)16 425 W. Airline Highway, Suite B

17 LaPlace, Louisiana 7006818 985-651-610119

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1 REPRESENTING THE UNITED STATES OF AMERICA:

2 UNITED STATES DEPARTMENT OF JUSTICE,

3 TORTS BRANCH, CIVIL DIVISION

4 (BY: ROBIN D. SMITH, ESQUIRE.

5 SENIOR TRIAL COUNSEL)

6 (BY: JACK WOODCOCK, ESQUIRE)

7 Torts Branch, Civil Division

8 P.O. Box 888

9 Benjamin Franklin Station

10 Washington, D.C. 20044

11 202-616-4289

12

13 ALSO PRESENT:

14 STEPHEN WILES, ESQ.

15 BEN MAYEAUX, ESQ.

16 KEA SHERMAN, ESQ.

17 PARKER HARRISON, ESQ.

18 SARAH MACK19

20 VIDEOGRAPHER:

21 GILLEY DELORIMIER (DEPO-VUE)

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1 E X A M I N A T I O N I N D E X23 EXAMINATION BY: PAGE

45 MR. SMITH ............................. 86 MR. O'DONNELL ............................ 2037 E X H I B I T I N D E X89 EXHIBIT NO. PAGE

10 Exhibit Kemp 1 ........................... 1011 Exhibit Kemp 2 ........................... 1212 Exhibit Kemp 3 ........................... 5113 Exhibit Kemp 4 ........................... 6214 Exhibit Kemp 5 ........................... 12715 Exhibit Kemp 6 ........................... 15716 Exhibit Kemp 7 ........................... 177

17 Exhibit Kemp 8 ........................... 20318

1920

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1 S T I P U L A T I O N2 IT IS STIPULATED AND AGREED by and3 among counsel for the parties hereto that the4 deposition of the aforementioned witness may be

5 taken for all purposes permitted within the6 Federal Rules of Civil Procedure, in accordance7 with law, pursuant to notice.8

910

1112

1314

1516

17 * * *

1819

2021

22 JOSEPH A. FAIRBANKS, JR., CCR, RPR,23 Certified Court Reporter in and for the State24 of Louisiana, officiated in administering the25 oath to the witness.

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1 MR. O'DONNELL:2 Pierce O'Donnell for the Robinson3 plaintiffs.

4 MR. BECNEL:5 Darryl Becnel for the plaintiffs.6 MR. STEVENS:7 Elwood Stevens for the Robinson8 plaintiffs.9 MR. LAMBERT:

10 Hugh Lambert for the Robinson11 plaintiffs.12 MR. ANDRY:13 Jonathan Andry for the Robinson14 plaintiffs.15 MR. BUCHLER:16 Florian Buchler for the Robinson

17 plaintiffs.18 MR. CAMPBELL:19 Todd Campbell with F. Gerald20 Maples here.21 MR. MAYEAUX:22 Ben Mayeaux, Orleans Levee23 District, also present.24 MR. WOODCOCK:25 Jack Woodcock, United States.

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1 MR. SMITH:2 Robin Smith, United States.3 MS. MACK:4 Sarah Mack, also present.

5 G. PAUL KEMP, PH.D.6 633 Magnolia Wood Avenue, Baton Rouge,7 Louisiana 70808, a witness named in the above8 stipulation, having been first duly sworn, was9 examined and testified on his oath as follows:

10 MS. HARRISON:11 Parker Harrison for Lafarge North12 America here to observe.13 EXAMINATION BY MR. SMITH:14 Q. Good morning, Dr. Kemp.15 A. Good morning.16 Q. My name is Robin Smith. We met just a17 few moments before the deposition began this

18 morning for the first time.19 A. That's right.20 MR. O'DONNELL:21 Did we swear the witness?22 THE COURT REPOTER:23 Yes. Usual stipulations, is that24 correct?25 MR. SMITH:

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1 No. This will be pursuant to the2 Federal Rules of Civil Procedure.3 EXAMINATION BY MR. SMITH:

4 Q. We met earlier this morning for the5 first time. I'm going to be asking you some6 questions today about the opinions that you've7 formed that are pertinent to this case.8 Do you understand that?9 A. Yes.

10 Q. Because we have a Court reporter here11 who's going to be transcribing this, I'd like12 you to try the remember to answer me orally13 with a yes or a no rather than a nod.14 A. Yes. I will.15 Q. Thank you.16 Is there any reason today why you're

17 unable to give testimony in this case, or are18 you under any disability or on any medications19 that might be affecting your ability to20 remember things or to understand my questions?21 A. Not so far.22 Q. Well, if anything comes up during this23 deposition, anything I say that you don't24 understand, will you agree to ask me to clarify25 the question?

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1 A. I promise to do so.2 Q. Thank you. I'm going to hand you what3 I'm marking as Kemp Exhibit Number 1 and ask if4 you have seen this Notice of the Deposition.

5 (Tendering.)6 (Exhibit Kemp 1 was marked for7 identification and is attached hereto.)8 A. Um -- I probably should have, but I9 can't say that I have.

10 EXAMINATION BY MR. SMITH:11 Q. Okay. I direct your attention to12 Exhibit A which is Page 3.13 Were you asked to bring any of these14 documents that are listed in Exhibit A to this15 deposition today?16 A. I was asked to bring the exhibits that17 I used in the report that I submitted that

18 concerns this deposition, yes.19 Q. Okay. Anything else? Were you asked20 to bring any updates to your report?21 A. No, I wasn't.22 Q. Okay. Do you have any updates to your23 report?24 A. Um -- do I have them with me? No.25 Q. No. Do you have any? Not whether you

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1 brought them with you.2 A. Well, we have continued --3 MR. O'DONNELL:

4 Have you prepared an update to5 this report?6 A. No, I haven't.7 EXAMINATION BY MR. SMITH:8 Q. Did you bring any invoices that you've9 prepared for payment for your services in this

10 litigation?11 A. I didn't bring -- I think there is one12 invoice since the last deposition, and I've13 neglected to bring that.14 MR. O'DONNELL:15 We'll furnish it to you.16 MR. SMITH:

17 Thank you.18 MR. O'DONNELL:19 Would you mark, sir, where I20 indicate we'll furnish something?21 EXAMINATION BY MR. SMITH:22 Q. And Number 1 asks for all the23 materials that you considered or relied on in24 connection with your report, which I take to be25 broader than simply the documents that you've

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1 cited in your report.2 Were there other things that you3 considered that you did not cite in your4 report?

5 A. I've been working on this for a long6 time, before Katrina, actually. So I've7 surveyed a vast amount of materials, and what I8 include in that report were things that I9 thought were relevant to the, um -- to that

10 report. I would say that I have an advantage11 in that I was the principal author of the Team12 Louisiana report, and so that is a pretty good13 summary of where things stood as of the end of14 last year.15 Q. Since you mentioned it, I'm just going16 to go ahead and mark this. I'm going to mark17 this as Kemp Exhibit Number 2 and ask if you

18 would look at it and tell me whether that is19 the Team Louisiana report that you just20 referenced.21 (Exhibit Kemp 2 was marked for22 identification and is attached hereto.)23 A. The front page looks right.24 EXAMINATION BY MR. SMITH:25 Q. Well, we're off to a good start.

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1 A. Okay, I'll note that it doesn't2 include the transmittal letters or the, um --3 Q. Actually, I think it may.

4 A. Oh, does it? Okay, those -- I'm5 sorry. Are you referring to these letters that6 are in --7 Q. No, I'm not referring to those. I8 know what you're referring to. If you don't9 see them there, that's fine. I thought they

10 were included but they may not have been11 included?12 A. Okay. I don't see them.13 Q. All right. But this would be the14 complete report, correct?15 A. It appears to be, without going16 through page by page.

17 Q. I won't hold you to the two hundred18 pages.19 A. It's a little more than that, I think.20 Q. You mentioned that you've been working21 on this for a long time, since prior to22 Katrina. What do you mean by "this?"23 A. Well, um -- I've been working on the24 issues of wetland loss in Louisiana and the --25 I'm one of the originators of the restoration

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1 program, federal/state program. I got involved2 in hurricane surge modeling as an adjunct or an3 outgrowth of my work in modeling hydrodynamics4 of coastal wetlands. So it was natural that we

5 would support the Hurricane Center and the6 state by adapting the Johannes Westerink 's7 model and my first involvement with that came8 in 2003.9 Q. So 2003 was your first involvement

10 with ADCIRC modeling?11 A. That's correct, yes. We had12 previously used other models.13 Q. What models had you used prior to14 that?15 A. Well, we had used a variety of16 engineering models, not specifically surge17 models, but TABS 2D was a Corps model.

18 Q. TABS?19 A. TABS.20 Q. T-A-B-S?21 A. Yes. And then we had developed --22 Q. And what kind of model is TABS 2D?23 A. It's similar to ADCIRC. It's a finite24 element model.25 Q. For modeling --

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1 A. For modeling --2 Q. -- hydrodynamic flow?3 A. -- hydrodynamic flows through channels

4 and over wetlands and coastal areas. It's5 coastal.6 Q. 2 dimensional?7 A. That's a 2 dimensional model, like8 ADCIRC -- like this form of ADCIRC that we've9 used.

10 Q. Through channels and over wetlands,11 you said?12 A. Over flooded lands.13 Q. Over flooded lands?14 A. Yeah.15 Q. Okay. And what were you looking --16 what data were you looking to acquire through

17 using the TABS 2D model?18 A. I guess the last report that I -- and19 there's a series of publications associated20 with it, but it was primarily for the design of21 a river diversion project into the Maurepas22 swamp for EPA, and we used TABS for the basic23 hydrodynamic engine and then we also attached24 to it an ecological model.25 Q. What kind of data, though -- I guess

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1 what I'm trying to get at is what kind of data2 are you able to obtain through use of this3 model that assists you in choosing a program4 for river diversion?

5 A. Well, the main thing is we can use it6 for -- in this case, we were looking at7 distribution of dissolved nitrogen coming out8 of the river, so we were able to model the9 mixing of water coming out of the river with

10 the water that was on the ambient area11 receiving. We were able to look at salt12 concentrations and the effect of the river13 input on salt concentrations in Lake Maurepas14 and the surrounding areas. We were able to15 look at the pathways of flow and the velocities16 and the water levels. And that's very similar17 to what we do with the ADCIRC model. So

18 basically velocities, direction and stage or19 height.20 Q. You mentioned that that's similar to21 some of the data that you can obtain through22 ADCIRC modeling.23 A. It's very similar.24 Q. But I take it it's -- is it designed25 specifically for use in certain environments,

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1 in other words, that are different from the2 ADCIRC environments; is that essentially the3 distinction between the two models?

4 A. No, no. It's really more -- ADCIRC5 has a lot of other features that make it better6 for surge simulation. For one thing, ADCIRC is7 not strictly a hydrodynamic model, it is a8 linked model that includes an atmospheric9 component. That's how we generate the storm

10 which then is the cause of the surge. So we11 have to generate the wind stresses on the ocean12 surface that is the primary way that water13 piles up in the surge.14 (Brief interruption.)15 EXAMINATION BY MR. SMITH:16 Q. Could you just read back? He may have

17 been finished, he may not have been finished.18 I'm not sure. Read the question and then read19 his answer and we'll see.20 (Whereupon the previous question was21 read back.)22 EXAMINATION BY MR. SMITH:23 Q. You were comparing and contrasting24 ADCIRC with the TABS 2D model, and you25 mentioned, I think -- one difference is the

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1 wind speed from those three pieces.2 Q. Is that at a radius, too, or is it3 just --4 A. I don't recall that there was -- they

5 usually just give a maximum wind speed.6 Q. Uh-huh. Okay.7 A. Now, we have a model, a Planetary8 Boundary Layer model, PBL model, that will then9 take that information and convert it into the

10 wind stresses necessary to run ADCIRC.11 Q. So the interpolating the points in12 between, how many points in between do you need13 to generate?14 A. I'm trying to remember, but I think15 the projections that the National Hurricane16 Center provides are, I believe, three hours17 apart, something like that. And we had to

18 generate half hour points in between. It may19 have -- maybe four hours and we had to generate20 another point in between. I'm not sure. This21 is going back -- I haven't done this in a22 while.23 Q. Sure. So you needed perhaps as few as24 one point in between, but it could have been a25 half dozen points, you're not sure at this

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1 point?2 A. Yeah. So that involves running a3 program, an interpolation program.

4 Q. And what -- is that interpolation5 program part of the ADCIRC model or is it an6 adjunct to it?7 A. It's a preprocessing, um --8 Q. What does that mean?9 A. I mean, you do that before you put the

10 information -- it goes into the input file, and11 it's something you run. It's one of those12 things that takes time. And it has to be done13 manually.14 Q. What do you mean has to be done15 manually?16 A. Well, basically, we have to get the

17 data from National Hurricane Center, we have to18 run our interpolation program, and then we have19 to check it. We usually plot it, because, you20 know, things can happen, and you don't want to21 have an errant point out there that will22 destroy the whole run.23 Now, the other thing is that we would24 sometimes run our own -- you know, we would --25 if the governor wanted a run that was a little

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1 further to the west, we would sometimes run2 that, also. So we would generate our own3 tracks.4 Q. When you say you sometimes generate

5 your own tracks, is this in the same time6 period that we're speaking about when Katrina7 was moving across the gulf?8 A. Absolutely, yes. We had the9 capability to run two runs simultaneously,

10 because we had a 1000 node processor, and we11 using only 250 nodes at a time.12 Q. So the idea being perhaps to generate13 a worst case scenario?14 A. We would generate an envelope --15 because when you get information from the16 National Hurricane Center, they'll provide a17 best guess track, but they'll also provide an

18 east and west error bound. And one of the19 things that we would do, sometimes, is run an20 intermediate storm that was closer to us so21 that we could have some advance notice of what22 might be expected if the storm took a turn in23 that direction. We were being continually24 pressed for that kind of information.25 Q. And when you were doing this, this was

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1 2005, what you're been describing most2 recently, but you indicated previously that you3 began using the ADCIRC model in 2003.

4 A. Yeah. I began -- I was the Director5 of the Natural Systems Modeling Group at the6 School of the Coast and Environment at LSU, and7 prior to my involvement the LSU Hurricane8 Center had contracted with Johannes Westerink9 at the University of Notre Dame to provide

10 these services, basically. And also to another11 modeler at LSU. So there was a history prior12 to my involvement. I had to acquaint my group13 with this model, and we basically took over the14 day-to-day running of the model from Johannes15 Westerink in the 2004 period. Now, we also --16 I'm sorry.

17 Q. No, go ahead.18 A. Yeah. 2003, we didn't have any storms19 coming our way, so it was a good year to be20 learning.21 Q. So that was my -- my next question22 was, this was essentially a function that23 you -- or a service that you provided during24 the hurricane season to track storms coming25 across the gulf?

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1 A. That's correct. Our -- well, track2 the storms? Well, we were on standby to3 provide surge forecasting, first in an4 experimental research mode, and then as the

5 public safety agencies, the Office of Emergency6 Management became aware of what we were doing,7 it moved pretty quickly into, um -- into more8 of a service, as you call it.9 Q. Again, would this have been during the

10 2004 hurricane season when it began to make11 this transition?12 A. That's right. And probably the13 biggest factor in that transition, which was14 not something that we were seeking or15 anticipating, was our involvement in the16 Hurricane Pam exercising in July of 2004. At17 that time, you know, it was kind of an

18 opportunity to show off to some degree, and so19 we took that opportunity.20 Q. The point of what you provided for the21 Hurricane Pam exercise was to provide22 information about where flooding would occur?23 A. That's right. Um -- where flooding24 would occur when.25 Q. Where and when flooding would occur.

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1 A. Yes. And this was essentially2 following a script. The National Hurricane3 Center, and I guess working with FEMA, had

4 created a fictional hurricane which we then ran5 in the same way that we would a real hurricane.6 It produced flooding sequence in the New7 Orleans area. That flooding sequence was used8 to drive at least part of the -- of their9 emergency simulation.

10 Q. And was this group that began doing11 this in a research mode in 2004 and then12 eventually began to offer its conclusions to13 other agencies composed of the same six people14 that eventually in 2005 were doing the15 six-hour -- attempting to generate this output16 in six-hour windows?

17 A. Well, we had some turnover of graduate18 students, because most of those six people were19 graduate students. My elite hydrodynamic20 modeler was Hassan Mashriqui. He's a hydraulic21 engineer.22 Q. I'm sorry. You described him as your23 lead --24 A. Hydraulic engineer. He was really25 running the models. He's also very capable

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1 with these parallel processing -- well, we2 became capable with that. And he was doing a3 lot of the interaction with Johannes Westerink.4 Q. He was a professor not a graduate

5 student; is that correct?6 A. He's a professor, that's correct.7 Assistant professor.8 Q. So you had yourself and Dr. Mashriqui,9 and then other graduate students?

10 A. Yes, we had graduate students, and I11 would have to refresh my memory about --12 Q. That's fine.13 A. Now, we also did have -- Dr. Van14 Heerden would be involved. We were working15 under contract to Dr. Van Heerden, basically,16 so during the time that the storms were coming17 in, Dr. Van Heerden was doing a lot of the

18 interaction with the emergency management19 people and, you know, conveying their requests20 to us and that kind of thing.21 Q. What does it mean to run the model?22 You said Mashriqui was running the models on --23 I take it on the supercomputer.24 A. That's right. Basically, you want to25 have one person involved in all the input and

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1 output, because if you get more than one person2 involved you're in trouble. So he was3 designated as the lead. And he works with that

4 model on a day-to-day basis. For me it was a5 part-time -- I had other responsibilities, too.6 Q. Which dealt with your principle work,7 I take it, of analyzing environmental, um --8 explain to me what your main work was at the9 time, if you will, please.

10 A. Okay. At that time, my primary11 research involvement was in trying to link12 ecological models for marsh survival and13 building with hydrodynamic models. Typically,14 these hydrodynamic models operate on time steps15 of a second or less. And then, you know, how16 do you mesh that with growing plants where

17 there's a seasonality involved? Or for dealing18 with swamps we may be centuries, you know. So19 there's big time scale differences, and that20 was the subject of my research interest. And21 then also linking -- well, that involved some22 chemistry work -- chemistry, also.23 Q. Again, was this principally using the24 TABS 2D model?25 A. The TABS 2D was one of several models

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1 we used. We actually created a finite2 difference model that was published in the let3 1990s called the CELSS model.4 Q. How is that spelled?

5 A. CELSS, not as it should be. And I'm6 trying to remember. Coastal Ecological7 Something Simulator. This was an effort to8 bridge the gap, as I said, between a true9 hydrodynamic model and an ecological model, so

10 it would work at these two different time11 scales. That model would simulate coastal12 change, land building, loss, over -- we would13 run that sometimes for close to a century in14 simulated time.15 Q. Was this a linked model?16 A. Um -- it was a coupled model. I would17 say coupled because we had -- the ecological

18 algorithms were being executed at the same time19 that the hydrodynamics was. Just different20 time scales.21 In the ADCIRC model, which is a linked22 model, we would run the atmospheric model and23 then run the hydrodynamics.24 Q. You've mentioned there may have been25 some other models that you used?

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1 A. Well, we -- I was involved with river2 modeling at that time, and so we would run a3 number of 1 dimensional models that -- I was

4 doing work for the Corps of Engineers, so we5 would use their models, the HEC-RAS and the6 HEC-6 for sediment transport. I think that7 stand for Hydraulic Engineering Center, out in8 California.9 (Brief recess.)

10 EXAMINATION BY MR. SMITH:11 Q. So then I think, correct me if I'm12 wrong, that covers pretty much your experience13 with hydrodynamic modeling, um -- with river --14 A. Well, I mean I've been working in that15 most of my career, so -- but the transition to16 working with engineering models occurred in the

17 2000 period. For my dissertation work I worked18 on wave models, sediment transport under waves.19 That's quite a different field. Um --20 Q. That's not an engineering model?21 A. No. Oceanographers typically will use22 their own models and then the engineers use23 their models. I -- the problem with working24 with the Corps of Engineers is that you25 essentially have to talk to them in their

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1 language, that means use their models, you2 know, whether you like them or not. And so3 that's when I -- when I was working with them,4 in the late 1990s, I became familiar with their

5 models. There is nothing particularly unusual6 about them. Oceanographers use models that7 rely on the same physics, but --8 Q. That's what I was going to ask you9 next. Are they different in kind or simply

10 different in name?11 A. Well, I guess it would be like going12 to a library and saying, are those all books13 there or -- you know. One thing that -- and14 this is not true of me, I'm more of a15 practitioner: Most hydrodynamics modelers are16 frustrated mathematicians and they can't stand17 to use somebody else 's model, they want to

18 build their own. And so they would argue19 they're all very different.20 You know, in fact, however, the21 physics is remarkably similar for all of them.22 It's more about how that physics is executed on23 a computer that is where the differences arise.24 And then particularly -- there are particular25 applications to which they're directed.

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1 Q. So when you say the physics are the2 same, would that mean that -- I think you said3 LePlace's shallow water equations are used on

4 both of these models?5 A. Navier-Stokes equations, LaPlace's --6 I mean, these are all, you know, two, three7 hundred year old Newtonian approaches.8 Q. The answer is yes, then?9 A. Yes.

10 MR. O'DONNELL:11 Isaac Newton?12 THE WITNESS:13 Yes.14 A. You know, we don't get into radiation15 and things like that.16 EXAMINATION BY MR. SMITH:

17 Q. So that brings us up to Hurricane18 Katrina. I'm interested in knowing what ensued19 after -- I've seen in your report that you were20 doing forecasting, which is what you've21 previously described.22 A. Yeah. What ensued was not something23 that I was prepared for. Our initial24 assumption was, you know, we do the forecasting25 and hopefully we do a good job of it, but one

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1 thing we want to do after the event is see how2 well we did. And it's the see how well we did3 that became -- you know, that took over my life4 for the next year or so. So part of what

5 happened is, in the lead up to Hurricane6 Katrina, we were doing forecasting the weekend7 before, and that became -- the results of those8 forecasts became pretty widely known.9 We were very concerned about this

10 storm. You know, we could -- we had become11 pretty comfortable with our model performance12 in the New Orleans area, and so when we started13 seeing the model forecasting overtopping of the14 flood protection works, then, um -- we thought15 it was important to get that information out.16 And some of it actually appeared on the front17 page of The Times-Picayune, the local newspaper

18 here, on the Sunday before the storm struck.19 So we have a conceit that we helped save lives.20 But, you know, it's very difficult to know21 that.22 Q. So when you say the weekend before the23 storm -- the storm struck on a Monday. You24 mean that immediate weekend --25 A. We were doing simulations from Friday

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1 through essentially the time the storm made2 landfall in Louisiana. So in my report I3 pretty much document what we did as soon as we

4 were able to get into New Orleans and --5 Q. I'd like you to explain to me what you6 did to -- well, first of all, let me back up,7 because you mentioned that you had become8 comfortable with the results that you were9 getting in the New Orleans area. Was that

10 based upon the simulations you ran in 2004?11 A. That was -- it was also based on Betsy12 simulations and some of the calibration work13 that Dr. Westerink had done. Also, looking14 at -- in 2004, we had a number of storms that15 hit in the near vicinity of New Orleans, in the16 Florida panhandle and Alabama area, and so we

17 were pretty pleased with the -- with our18 accuracy during those storms. And so we19 were -- that led us to develop a considerable20 confidence, at least for that Mississippi bite21 area, that we were pretty much on top of the22 primary threats, and particularly for a storm23 following that kind of track, which was not24 that far off of what we had seen before in Ivan25 when Ivan came ashore.

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1 Q. All right. You mentioned two2 different states, Florida storms, I think, and3 then you mentioned Mississippi bite area.4 A. Well, I talk about the area between

5 the Florida -- well, south of the Florida6 panhandle extending over across Alabama and7 Mississippi, and then terminating basically in8 the peninsula formed by the Mississippi River9 extending out into the gulf in a southeasterly

10 direction. That's an area that -- in which11 surge can accumulate. And so we were -- and12 it's also an area in which there's fairly13 limited amount of wetlands.14 The primary problem area that we had15 seen in our ADCIRC simulations was in16 addressing the damping effects associated with17 wetlands. We were able to flood them and dry

18 them, but they were essentially treated as no19 different from a shallow bay. And, you know,20 that's still an area of ongoing work, is, you21 know, we know from post-storm investigations22 that wetlands are very important in attenuating23 storm surge, but we don't get a lot of good24 chances to test the -- test that understanding.25 We did in September of 2005 with the, um --

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1 landfall of Rita, Hurricane Rita, which hit2 southwest Louisiana.3 I'm just saying we were confident on

4 the east side of the river, we were less5 confident on the west side.6 Q. When you say the river, you're talking7 about the Mississippi River?8 A. Mississippi River. I'm sorry.9 Q. Was this even prior to Rita, when you

10 say you had confidence in your modeling results11 on the east side of the Mississippi, and12 less --13 A. Yes. That was a function, really, of14 experience. Because in 2004 we had a number of15 storms that went to the east. And we also --16 we knew that there was a strong wetland effect

17 and we knew it wasn't in the model, and so the18 model works very well where there aren't19 wetlands. Or worked better, anyway.20 Q. When you say it wasn't in the model,21 you're referring the ADCIRC S08?22 A. S08 was the only version that we used.23 And the Hurricane Center had put a lot of money24 into developing that grid, working with25 Johannes Westerink.

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1 Q. Explain what you mean by putting a lot2 of money into developing that grid.3 A. Um -- some of this is, you know, what4 I was told, because most of this happened

5 before I got involved, but there was a lot6 of -- as Johannes -- if you ever talk to him,7 he will tell you the thing that matters most is8 geometry. And getting the -- the only places9 his model doesn't work is if you've got bad

10 bathymetry or bad topography.11 So the Hurricane Center worked with12 him and his graduate students to -- considering13 that lot of our coast was last surveyed by the14 U.S. Government in the 1930s, there was a lot15 of need for updating. And so in some cases we16 would actually, you know, set up a bathometer17 and run across a lake and provide Johannes with

18 that information.19 Q. And that would have been on the east20 side of the river.21 A. Well, that was -- that was all around22 the coast. It was -- getting the geometry23 right was -- and Johannes would say, you24 know -- I don't have any numbers in this25 lake -- you know, it's an inland lake of some

Page 39

1 kind -- and so we would send somebody out to2 get some bathymetry or I would find a recent3 survey somewhere that an oil company had run.

4 Q. I'm trying to understand, though, was5 this principally on one side of the river?6 A. Well, for Louisiana in general, the7 NOAA surveys are very dated. This is -- since8 the storm this being corrected. But as you9 know, we suffer a lot of land loss in this

10 area. Some people say the coast of Louisiana11 is more of a process than a place, and so12 what -- whenever Johannes saw results that13 didn't work well with gauge readings, for14 example, he would immediately blame the coast15 or the representation of the coast. And so we16 would try and prove that.

17 Q. And by getting more data, you provided18 more what I think modelers call nodes?19 A. No. The nodes are generated -- we20 have a surface -- okay, we have a surface, and21 then that is discretized or broken up into22 nodes that are concentrated in areas of, A,23 changing topography or bathymetry, you know,24 slopes, things like that, or, B, areas of25 intense interest. So we have a lot of nodes

Page 40

1 around the New Orleans area and around the2 flood protection system, and actually inside3 the city itself.4 Q. So it's a two step process, the first

5 part of the process is gathering the6 topological or bathymetric --7 A. Above the water, and below the water,8 yeah.9 Q. Yes, the surface data --

10 A. I call that the geometry.11 Q. The geometry --12 A. Yeah.13 Q. -- of the area. And you're trying to14 make that as accurate as possible.15 A. That's correct.16 Q. And then once you obtain that17 information, the modeler can generate nodes

18 using that data in a theoretically infinite19 number?20 A. That's correct. I think the month21 model that we used had around six hundred22 thousand nodes in it. I may be wrong.23 Q. Many nodes.24 A. Many nodes. And most of those,25 probably about 80 percent of them, would be

Page 41

1 within about, you know, two hundred miles of2 Louisiana. And that was because this was a3 model focused on Louisiana. Now, we still have

4 to -- the boundaries of this model go out to5 Bermuda in the middle Atlantic, they include6 the entire Caribbean Sea. The big problem with7 hurricanes is that they move across vast8 distances, and anyplace you put a boundary9 you're going to impose errors. So we want to

10 put the boundaries out as far as we can.11 Q. The notion being that if you move the12 boundary far enough away from the area of13 interest, the effect of the error that's14 introduced by that boundary will be minimized.15 A. I couldn't have said it better, yes.16 That's right. That's a problem with other

17 hurricane models.18 Q. And even non hurricane hydrodynamic19 models.20 A. True. True. Usually, the limitations21 are computational. You know, if you make the22 model too big and put too much in there, it23 becomes unmanageable computationally. We24 essentially had those limitations lifted off by25 the parallel structure of the model.

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1 Q. And access to the supercomputer.2 A. And the access to the supercomputer.3 Q. So on Tuesday morning, August the4 30th, 2005, the storm had passed and you were

5 intent on finding out how well you had done.6 A. Well, at that time I was still, you7 know, of course, dealing with my family. We8 had no power or, um -- it was essentially9 impossible to get out of the neighborhood

10 because of all the trees down and that sort of11 thing. So I was dealing with more immediate12 issues. But --13 Q. I didn't realize you lived in this14 area. I thought you lived up in Baton Rouge.15 A. Well, Baton Rouge was affected by --16 Q. You were out of power up there, too.17 A. Yeah. For about a week or so.

18 Q. Okay.19 A. In fact, when I was -- I left LSU and,20 they have -- you know, I was largely unaware of21 what was going on because we had been in, you22 know, a windowless building for a long time,23 and so I was sort of taken aback when I was24 having to drive around downed trees and that25 kind of thing just to get home. So there

Page 43

1 was -- I had a battery powered radio and I was2 listening to whatever news I could get. But3 most of the news was not very accurate. I had

4 sporadic telephone connections.5 So I really didn't have much6 involvement until that Friday when I was7 offered a seat on an overflight with the Civil8 Air Patrol through the Hurricane Center. And9 that was an amazing flight.

10 Q. Who was on that flight besides11 yourself?12 A. Um -- let's see. Dr. Mark Levitan,13 the Director of the LSU Hurricane Center, um --14 it was a four-seater plane. I think it was15 actually just Mark and I and the pilot, but16 there may have been another person. Because I

17 could actually shoot out of both sides of the18 plane. So I think it was just Mark and I.19 Q. And so you had a camera, a still20 camera?21 A. I had a still camera, and Mark had a22 still camera and a video camera, and we23 actually over flew the entire, um -- well, from24 about Grand Isle all the way to Mobile,25 Alabama.

Page 44

1 Q. So that was a long flight.2 A. It was a long flight, but it was a3 fairly fast plane. We weren't allowed to go4 down as low as I would have wanted to, because

5 of all the helicopters, but it did give me a,6 you know, pretty good over view of the -- now,7 I saw a lot of things that suggested to me very8 high surge. Mark Levitan, who's a wind expert,9 was pretty disappointed because he saw too many

10 buildings with roofs on and things like that,11 so. So he could see that the wind speeds were12 not that high, but that the surge was high.13 Most of the damage was associated with surge.14 Q. Were you surprised by the -- the state15 in which the hurricane protection systems16 surrounding New Orleans was in?17 A. Well, you know, honestly, it really

18 had not occurred to me that the system would19 fail as extensively as it did. And partly it's20 that I'm just not -- I'm not qualified to21 understand the engineering of that kind of22 system. Um -- you know, I understand23 oceanographic forces, and I assume that the24 engineers design a system that can deal with25 those. But, you know, all of our forecasting

Page 45

1 dealt with predicting overtopping, and as it2 turned out, of course, the system was not3 designed to withstand overtopping, so.

4 Q. Would the answer be yes, you were5 surprised?6 A. Oh, yes. Yes, I was surprised. I had7 no preparation for it.8 Q. I thought that's what you were saying,9 yes, but it was --

10 A. No. I had driven the system with a11 colleague that was an engineer. I had driven12 the system probably about, you know, two months13 before the storm hit, with the -- in the14 company of the people from the Orleans Levee15 Board, just to kind of take a look at this16 system. For one thing, we were trying to,

17 um -- use a GIS to map it, and -- Geographic18 Information System.19 Q. From the ground.20 A. Well, that's using lidar data --21 Q. Oh, I'm sorry. I thought you were22 talking about when you were driving around.23 A. Well, I was driving around to see what24 the laser was hitting, essentially, you know,25 and noticing where you would have earth levees

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1 interrupted by flood walls and sheet pile and2 things like that. So I had some familiarity3 with the system before the storm hit, but no4 understanding of reliability or vulnerability

5 because I had been pretty much focused on the6 oceanography.7 Q. I'm a little confused, and it's not8 your fault, it's just, where -- what is this9 lidar data that you're referencing?

10 A. Lidar is an airborne active sensor11 system. It shoots a laser down -- it kind of12 like works like an echo sounder in water, but13 it's -- it uses light instead of sound, and14 they fly over an area at night, they have, you15 know, very good navigation systems on the16 planes so they know its exact location relative17 to the geoid, and then they're basically

18 getting returns from the laser system that's19 pinging the ground at very high frequency, and20 so it gives a remarkably detailed21 representation, with the proper processing --22 post processing, of the ground surface23 elevations. So you're not restricted to the24 kind of point surveys that previously were25 available.

Page 47

1 Q. So had you relied on this lidar data2 in your prior modeling that you've done, say,3 in 2004?

4 A. I had the advantage of having a person5 in association of my group who was very6 familiar with that system and, yes, we had7 started to introduce that. It was a major8 technological advance, at least in dealing with9 the land part of our problems. You know, of

10 course it doesn't penetrated water, so. I11 think lidar stands for light ranging and12 detection -- light detection and ranging. I'm13 sorry.14 Q. Uh-huh. And so post-Katrina, when you15 were making your initial survey of the area,16 you were -- you had lidar data in hand?

17 A. That's right. We had -- you know,18 lidar data for most of the state is available19 over the Internet, from about the 1999, 200020 period. So we had all that. We used that21 initially in making estimates of the volume of22 flooding. People were asking us, how long is23 it going to take to pump out this water? So24 they wanted estimates of the volume, we25 provided that. Um -- initially, when I was --

Page 48

1 of course, my primary focus was on surge2 elevation and so I was looking outside of the3 flood protection system for high water marks4 since all the gauges went out, essentially. We

5 had less gauge data than after Hurricane Betsy.6 So we were restricted -- you know, for7 validation of the model, we were pretty much8 restricted to high water mark information.9 That information is ephemeral, it's

10 short-lived, you have to get it right away.11 And so I was anxious to get to New Orleans to12 start collecting this data which, you know,13 probably not many other people were interested14 in at the time.15 Q. You wanted data from outside the16 hurricane protection system because your17 modeling prior to the storm had focused on the

18 surge characteristics outside the hurricane19 protection system.20 A. That's right. That's right. Inside21 the protected system we would not expect to be22 very accurate because -- I mean, because we23 don't have -- in our model, the world is24 perfect, we don't have failures. So. So we25 could predict overtopping to some degree, but

Page 49

1 we couldn't predict failure.2 Q. And in your modeling, which again I'm3 talking about your pre-Katrina modeling, in the

4 three days, right, Friday through Monday?5 A. Yeah. Well, and then we did a6 hindcast, yeah.7 Q. But in the three days prior to8 Katrina, you previously testified that you9 were -- this is not your word: You noticed

10 that there was overtopping being predicted by11 your storm surge modeling.12 A. Yeah.13 Q. And you thought that residents of the14 area should be informed of that possibility.15 A. Yeah. I guess what -- and I wasn't16 the only one, or our group was certainly not

17 the only one, the National Hurricane Center --18 the Director of the National Hurricane Center19 was screaming as loud as he could to the public20 safety officials that people needed to get out21 of New Orleans.22 Q. Dr. Mayfield?23 A. Dr. Mayfield. My experience is that24 if you can show people, in a quite realistic25 way, that water is going to come over these

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1 levees, that's even better as a motivator. And2 so we were quite willing to disseminate this3 information through the press and so on. And4 as I said, hopefully we saved some lives.

5 Q. I know you've got a copy of what was6 published in the newspaper in some of your7 papers. I'm not sure if it's in your report.8 A. I believe there's a --9 Q. Graphic.

10 A. -- graphic.11 Q. That's not the one.12 A. Your colleague has it.13 Q. It's figure 2.14 MR. O'DONNELL:15 You're looking at his report?16 MR. SMITH:17 I am. Did we mark the report

18 yet?19 MR. O'DONNELL:20 No.21 MR. SMITH:22 Well, let's get that marked.23 THE WITNESS:24 Exhibit Number 3 is your next25 exhibit.

Page 51

1 (Exhibit Kemp 3 was marked for2 identification and is attached hereto.)3 EXAMINATION BY MR. SMITH:

4 Q. I've just handed you what's been5 marked Kemp Exhibit Number 3 and asked if that6 is the report that you prepared for the7 plaintiffs in this case.8 A. Um -- it is. I see it does not9 include a list of the bibliography, or the

10 references, which I can provide if you like.11 It also includes a copy of my CV.12 Q. Right. That's the form in which we13 received it. It has three parts.14 Is that the way that you produced it15 to the attorneys in this case? It has your16 declaration and then it has your CV, and it

17 also has --18 A. It has a copy of a paper in Science19 that I was an author on.20 Q. Right. Did you provide those three21 documents to the attorneys for --22 A. Yes. And I also provided a list of23 all the references that I cite in this, um -- I24 think maybe that was provided supplementally.25 That's a possibility. So.

Page 52

1 Q. All right. I think that may be -- so2 just directing your attention to Page 9, then,3 in that report, is this the graphic --4 A. Yeah, sorry.

5 MR. O'DONNELL:6 What page are you on?7 MR. SMITH:8 It's Page 9. You've got a black9 and white copy.

10 THE WITNESS:11 I know what it looks like.12 MR. O'DONNELL:13 Here. Use mine. Let me borrow14 yours.15 MR. SMITH:16 I do have color copies, and I'd17 like to have a color copy marked so

18 we'll -- I mean, I have them back in19 my office, unfortunately.20 For the record, I think we'd like21 to get a color copy.22 MR. O'DONNELL:23 You can substitute it.24 MR. O'DONNELL:25 Thank you. We'll substitute it

Page 53

1 later.2 EXAMINATION BY MR. SMITH:3 Q. Is this Figure 2 from your report --

4 I'll call it your 702c report --5 A. That's correct.6 Q. -- the graphic that was produced by7 the newspaper based upon information that you8 provided to them?9 A. Yes. Actually, Dr. Van Heerden

10 provided the information to them, but this is11 consistent with what we were seeing at the12 time. This is probably based on a Saturday13 simulation. And it's not all that clear, but14 you can see a shaded area which is indicating15 flooding inside of protected areas.16 Q. Is that shading in New Orleans East?

17 A. It is showing shading in New Orleans18 East, in the Lower Ninth Ward area, St. Bernard19 and the Central Business District of New20 Orleans.21 Q. So it's also showing flooding along22 the outfall canals, is that correct?23 A. Actually, this simulation does not24 show flooding associated with the outfall25 canals. It does show flooding coming from the

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1 western side of Jefferson Parish.2 Q. Out there in Kenner?3 A. Out in Kenner, that's right.4 Q. Okay. I must have a bad copy because

5 it looks like I see some shading right here.6 Is that not -- you're not sure?7 A. You know, I remember seeing -- well, I8 don't think so. I don't think so.9 Q. You don't think that that was

10 indicated in your modeling on Saturday.11 A. No. No. I don't have any12 recollection of that.13 Q. Does it also show overtopping along14 the eastern side of St. Bernard Parish adjacent15 to the MRGO?16 A. That's correct.17 MR. O'DONNELL:

18 Because of the darkening? The19 blue?20 THE WITNESS:21 The darker areas indicate areas22 of flooding. And that -- you know,23 this is partly the artistic work of24 the newspaper. This would not be25 necessarily how it would appear in our

Page 55

1 model output.2 MR. O'DONNELL:3 But it's an approximation?

4 THE WITNESS:5 It's an approximation, that's6 correct.7 EXAMINATION BY MR. SMITH:8 Q. Did you provide -- or if you know, did9 Dr. Van Heerden provide the newspaper with a

10 graphic?11 A. He -- I know the kind of graphics that12 we produce ought of the model, and I'm sure he13 provided a graphic like that. And I can point14 to one that would be similar.15 Q. Can you point to one in your report?16 A. Let me see.

17 Q. Or even in the Team Louisiana report18 if you prefer.19 A. I'm sure I can find any number of20 them. Well, if you look at Figure 12 in our21 report, you will see --22 MR. LAMBERT:23 Page?24 THE WITNESS:25 That is on Page 30.

Page 56

1 A. This does not show the entire New2 Orleans area, but it shows the eastern part of3 the city, the eastern side of the city. You4 can see an example of the kind of graphics that

5 the ADCIRC model will produce. The colors are6 an indication of the elevation of the water.7 This is -- this would be a snapshot water8 elevation at a particular time. The arrows9 here are showing the direction of water

10 movement, and then you can see the levees or11 flood protection works are shown in a red12 outline, and then the areas inside the -- or13 the dry areas are shown as a light -- you know,14 essentially a white color.15 So in this drawing, or in this -- this16 is an example of model output, you can see that17 there is some overtopping occurring along MRGO

18 Reach 1 at this stage in the simulation.19 Q. Oh. I see. The arrows into20 St. Bernard Parish?21 A. That's -- actually, I lot of that is22 Orleans Parish.23 Q. You're right. That is Orleans Parish.24 On both sides there I take it there's25 overtopping.

Page 57

1 A. That is correct. This is a prediction2 or a forecast of the model, yes.3 Q. This was -- Figure 12 was a graphic

4 produced by your ADCIRC modeling prior to5 Katrina.6 A. No.7 Q. No, this is hindcast?8 A. This is a hindcast.9 Q. Okay. But what you're saying is, this

10 is the sort of --11 A. This is what we received on Saturday12 that was alarming us.13 Q. Does ADCIRC, the software program14 itself, generate this graphic or do you have to15 take the data that comes out of the ADCIRC16 software and, you know, gin up a graphic to

17 represent the ADCIRC information?18 A. This is a product of the19 post-processing, and this particular graphic20 interface was developed by the folks at Notre21 Dame. It is essentially a standard format. If22 you look through the IPET report, you'll see23 probably hundreds of diagrams like that.24 Q. In other words, you can get your data25 two ways, you can get it in a table or you can

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1 wasn't going to be true.2 Q. One of the things you knew but nerve3 thought about.4 A. That's true. I guess I wasn't paid to

5 think about it that much.6 MR. O'DONNELL:7 And the "it" was, just to be8 clear?9 THE WITNESS:

10 The accuracy with which the crown11 of the flood protection works were12 represented in the ADCIRC model and13 any deviations of that from reality.14 EXAMINATION BY MR. SMITH:15 Q. Let me hand you what's been marked16 Kemp Exhibit Number 4 and ask if you can17 identify that.

18 (Exhibit Kemp 4 was marked for19 identification and is attached hereto.)20 A. Yes. This is a -- this is a short21 report that I wrote in July of this year22 discussing hydrograph information that I had23 provided to our colleagues in the Netherlands24 to -- as boundary conditions for their polder25 flooding model.

Page 63

1 EXAMINATION BY MR. SMITH:2 Q. Directing your attention to Page 5,3 the last -- let's just go to the second-to-last

4 paragraph and see if the number 340,0005 computational nodes perhaps refreshes your6 memory as to the number of nodes that were in7 ADCIRC Version S08.8 MR. LAMBERT:9 Is that Kemp 3, his report?

10 MR. O'DONNELL:11 No. It's Exhibit 4.12 A. Okay. That -- I believe that's -- I13 think that may be low. But I get confused14 between the number of elements and the number15 of nodes. Typically we'll have a lot more16 elements than nodes. I remember the model

17 actually calculates flux between nodes, a cross18 an element, and since every node is connected19 to multiple other nodes there are more elements20 than nodes. And I, um -- that could be21 correct.22 EXAMINATION BY MR. SMITH:23 Q. It's not important. And that's really24 not why I handed it to you.25 A. Yeah. And my memory is -- this may be

Page 64

1 one of the places where those problems that you2 specified at the beginning come into play.3 Q. I just was -- I just happened to see4 that number there and was wondering --

5 A. Yeah. Actually, I could point out6 other things in this report that I'm not -- I7 mean, there are places where it shows meters8 instead of feet, and so there's some editing9 here that I would --

10 Q. Would you go ahead and do that? This11 might be a good time to do that.12 A. As I recall, we put this together13 fairly quickly.14 Okay. For example, in Page 10, Table15 2, we give surge elevations for various areas16 in meters, and then -- which is confusing17 because most of the text is in feet. You know,

18 at the time -- we have it in both. For the19 science literature, we always use meters, and20 then for the engineers we convert it to --21 Q. It's not a mistake here, though,22 because you do have it -- in the caption, it23 does indicate this is meters.24 A. That's right. But I think at some25 point, and I can't say where exactly, there's

Page 65

1 something mislabeled. It escaped the, um --2 but most of this is actually excerpts from an3 earlier version of the Team Louisiana report.

4 So it's been corrected I believe in the Team5 Louisiana report.6 Q. Okay.7 A. I could provide that later if you8 want.9 Q. If you can, that would be great. I'd

10 appreciate it.11 A. Okay.12 Q. Let me direct your attention back to13 Page 5, the last paragraph, and ask if you14 would just read that last paragraph.15 A. "The Greater New Orleans Hurricane16 Protection System was represented in an

17 idealized way in that the levee and floodwall18 heights were presumed to be at the design19 levels relative to the NGVD 29 vertical datum20 historically used by the U.S. Army New Orleans21 District. The model used information from the22 New Orleans District however inaccurate with23 respect to deficiencies. It is now known that24 most levee and flood wall crowns were lower25 than the design level protection."

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1 Q. Is this what you were referring to2 previously when you said that the forecasts and3 the hindcast that you did around the time of4 Katrina used idealized representations of the

5 hurricane protection system?6 A. That's correct. This also brings up7 datum issues, which I don't know if you want8 the get into right now.9 Q. This is a good time to get into them

10 if you're ready to get into them.11 A. Okay. From the standpoint of our12 modeling of surge and of the original13 oceanographic work that led to the design of14 the New Orleans Hurricane Protection System,15 the only datum that matters is mean sea level.16 The engineers then take that and translate that17 into a terrestrial datum that the surveyors use

18 to figure out how high to build the flood19 protection works and so on. And so we have to20 be careful going through this whole process21 that we're comparing proper datums. The datums22 changed over time. In some cases, benchmarks23 were not adjusted. But as an oceanographer, I24 can say that the only thing that's important,25 that the surge knows about, is mean sea level.

Page 67

1 And so, you know, that's perspective that tends2 to be lost. So if they say that the top of a3 flood protection work is supposed to be at

4 17-1/2 a half feet NGVD, I then have to5 translate that -- well, what does that mean in6 today's sea level? And of course what we know7 is that that's, you know, quite a bit lower in8 terms of today's sea level.9 So the IPET report goes into a long

10 discussion of that, they have a whole volume11 devoted to it. We have a chapter in our report12 also, um -- you know.13 Q. It's simply important for purposes of14 your study to make sure year comparing apples15 to apples and not apples to oranges.16 A. It is. And, so usually you'll see

17 when I talk about surge elevation I'll usually18 put some kind of datum designation behind it,19 and if I don't I hope somebody will slap me20 with it.21 Q. You mention in a number of places in22 the various reports you've prepared that your23 study of the Hurricane Katrina event --24 post-Katrina study of the event was a forensics25 investigation.

Page 68

1 A. (Nods affirmatively.)2 Q. And let me just direct your attention3 back to Exhibit Number 2 which is the Team4 Louisiana report. And I can give you a bound

5 copy if you'd prefer to have one.6 A. If you find something you want me to7 look at it, or --8 Q. Just for your convenience --9 A. I have a bound copy of it.

10 Q. If you want to use your own, you're11 welcome to, sir.12 A. I don't have any tabs or anything on13 it.14 Q. You can use that or I can give you15 one, whatever you prefer.16 A. I'm back.17 Q. Okay. If you turn to Page -- I guess

18 it's Page i, it's the first page of the19 executive summary, would you read the third20 paragraph in that page which begins "from an21 engineering perspective?"22 A. Okay. "From an engineering23 perspective, forensic science is the study of24 materials, products, structures or components25 that do not operate as intended. In the

Page 69

1 context of the flooding of New Orleans, the2 purpose is to understand first what performance3 was expected from the GNOHPS, and second to

4 identify causes of failure as part of an effort5 to improve future performance."6 Q. And if you turn the Page 4 of the7 report, I think almost the exactly the same8 statement appears at the bottom of the page9 under scope of work. Could you read that,

10 um --11 A. Okay. "From an engineering12 perspective, forensic science is the study of13 materials, products, structures or components14 that do not operate as intended. In the15 context of the flooding of New Orleans, the16 purpose is to understand first what performance

17 was expected to from the GNOHPS, and second, to18 identify causes of failure as part of an effort19 the improve future performance. Team Louisiana20 was --" where do you want me to --21 Q. Go ahead.22 A. "Team Louisiana was asked more23 specifically to develop a time history of surge24 and wave elevations for levee and floodwall25 reaches that failed, to compare this

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1 information to design and actual levee crown2 and floodwall crest elevations and to assemble3 and examine all relevant design memoranda,4 construction plans and as built surveys."

5 Q. You can stop there, that's fine.6 These two statements are actually, as7 I noticed as you're reading them, as verbatim,8 at least as far as they go. Is this a fair9 description of the nature and scope of the

10 study that you performed as part of Team11 Louisiana?12 A. I would say so. That essentially came13 out of the scope that, um -- that the state14 presented us with. Those probably aren't15 exactly the same words, but they're similar.16 Q. And so you were performing a forensic17 study?

18 A. Yes. And, you know, this is my first19 experience doing that. And so, you know, I20 wasn't involved in setting up the scope of work21 or, um -- but yes. We were called a forensics22 team, we had special accreditation to go on to23 failure sites and that kind of thing.24 Q. And within this definition, if you can25 help me to understand it, is an assumption that

Page 71

1 as investigators you will be comparing intended2 performance with actual performance. Is that3 correct?

4 A. That's correct.5 Q. And specifically, it was the New6 Orleans Hurricane Protection System that was7 the subject of the investigation.8 A. Of this particular investigation, that9 was the mandate, um -- and that obviously

10 differs pretty substantially from the endeavor11 we're engaged in here.12 Q. A similar statement, if you will turn13 the Page 4, appears. If you could read the --14 looks like it's the first full paragraph on15 Page 4 which begins "LSU was commissioned."16 A. Okay. "LSU was commissioned in

17 October, 2005, by the Louisiana Department of18 Transportation and Development to assemble a19 team of Louisiana-based academic and private20 sector experts to, quote, collect forensic data21 related to failure of the levee systems around22 Greater New Orleans, unquote, that occurred23 during passage of Hurricane Katrina on the24 morning of 29 August 2005. This group, later25 known as Team Louisiana, was to focus on the

Page 72

1 hurricane protection system designed and2 constructed over a 40-year period by the U.S.3 Army Corps of Engineers for the east bank of4 New Orleans, New Orleans East and St. Bernard

5 Parish. The LSU Hurricane Center continued to6 provide assistance to Team Louisiana through a7 critical grant from the McKnight Foundation to8 cover additional team expenses."9 Q. And again, this is just reiteration of

10 the points that have already been made about11 the nature of your assignment and the scope of12 your work.13 A. For this particular contract, yes.14 Q. And the results of that contract are15 contained within this report which has been16 marked Kemp Exhibit Number 2, is that correct?17 A. Um -- that's correct.

18 Q. The composition of Team Louisiana is19 described on Page 5, including Dr. Van Heerden20 who you've previously mentioned as the lead21 investigator, and then it says he recruited22 three other LSU scientists, including an23 oceanographer -- who I assume is yourself.24 A. That's correct.25 Q. -- a hydraulic engineer -- I assume

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1 that's Dr. Mashriqui -- and a geotechnical2 engineer -- whose name escapes me.3 A. His name is Roddy Sharma, S-H-A-R-M-A.

4 All these people have signed the report.5 Q. Okay. I believe you've previously6 mentioned that you began as soon as possible7 after Hurricane Katrina to gather ephemeral8 data. Is that correct?9 A. That's correct.

10 Q. And you've previously identified the11 ephemeral data that you were attempting to12 collect as high water marks. Is that correct?13 A. That's correct.14 Q. And they were high water marks15 specifically that were outside the hurricane16 protection system.

17 A. That was our initial focus. We did --18 our team did collect some inside the system,19 but the focus was primarily outside.20 Q. And is that process described on Page21 3 of the Team Louisiana report, the second full22 paragraph? And I'm not going to ask you to23 read it because it's a long paragraph.24 MR. O'DONNELL:25 What page are you on, Robin?

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1 MR. SMITH:2 3.3 A. That describes generally what we did.4 EXAMINATION BY MR. SMITH:

5 Q. Okay.6 A. Uh-huh. That was prior to -- for the7 most part, prior to the formation of the8 forensics team.9 Q. So what's described in Paragraph 2 on

10 Page 3 was something that you did even before11 Team Louisiana was commissioned.12 A. Exactly.13 Q. But you participated in that effort,14 is that correct?15 A. Yes, I did.16 Q. How did you go about collecting those17 high water marks?

18 MR. O'DONNELL:19 Precariously.20 A. Um -- well, it was -- we had21 special -- prior to the storm, in fact when I22 joined the Hurricane Center effort, they23 provided credentials to team members so that we24 had State Police permission to go into25 emergency areas. In the case of our initial

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1 trips into the New Orleans area -- this was2 Wednesday following -- this would be the second3 Wednesday following the storm -- at that time,

4 of course New Orleans was still flooded and5 there were still rescue efforts going on, and6 there were also a lot of -- there was a lot of7 I don't know whether it's information or8 misinformation about public safety threats and9 so on. So my first trip we went with a police

10 team into the city. I have some pictures, you11 know, but they're all wearing flack jackets and12 carrying submachine guns and we're just walking13 around in hardhats. But, you know, and there14 was never any threat or anything. But, um --15 but we were -- in that trip we were inside16 boats, we were -- we launched off the

17 Interstate ramps, and this was mostly looking18 at flooding volumes. Later -- I'm sorry.19 EXAMINATION BY MR. SMITH:20 Q. Excuse me for interrupting, but you21 say we. Who is we?22 A. Um -- it was a team actually organized23 by Dr. John Pardue at LSU.24 Q. Was he with you?25 A. He was with me. And, um -- there were

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1 a number of technicians along. This was, for2 me, kind of a reconnaissance trip. I didn't3 actually -- I collected some -- remember, we4 had lidar data, so what I tried to do was

5 collect some depth information at the center of6 street intersections from the boats to get a7 good estimate on flooding. This was in the8 Central Business District. Well, a little bit9 more like in the Treme area.

10 Then after that, we worked primarily11 outside the levee system.12 Q. You say it was principally a13 reconnaissance trip for you. What does that14 mean?15 A. Basically, to get an understanding of16 how we could operate out there, um -- you know,17 what kind of equipment we would need, what kind

18 of, you know, what was the sort of law19 enforcement situation, you know, how difficult20 it was going to be to get around, that sort of21 thing.22 Q. Was Dr. Pardue collecting high water23 mark --24 A. He was not as much interested in high25 water marks, he was interested in the, um --

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1 level of pollution in the water, basically, and2 produced a report within probably a month of3 the disaster giving some initial ideas of what

4 the level of contamination was.5 Q. So were the technicians collecting6 water samples for Dr. Pardue?7 A. Yes.8 Q. So on this trip, as I understand it,9 then, you really weren't collecting high water

10 mark data, you were collecting --11 A. I was collecting depth information12 which then went into --13 Q. Still water elevations.14 A. Yes -- because we were trying to15 understand how many -- this was before the16 pumps had started -- what was the volume of

17 water that had to be removed. Okay? And we18 were sort of experimenting with using the lidar19 as a container, essentially, and then looking20 at any variability of depths across that area,21 and could we come up with a pretty good idea22 of, you know, what the ring on the bathtub was.23 Q. And then did you make subsequent trips24 to --25 A. Yeah. After that, I went with a

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1 smaller team. I'm sorry.2 (Off the record.)3 EXAMINATION BY MR. SMITH:4 Q. Did you make subsequent trips to

5 collect high water mark data?6 A. I did.7 Q. And when were those subsequent --8 subsequent trips made?9 A. I never actually compiled a log of all

10 the trips. I have a field book that has most11 of that information in it. Um -- I could12 probably reconstruct that. But, um -- I was13 not -- I was not going strictly to New Orleans.14 Also I was going around the north shore of Lake15 Pontchartrain, and actually made a trip over16 into Mississippi.17 But as it began to be easier to work

18 in New Orleans, I started -- I initially19 focused on the area around the mouth of the20 17th Street Canal. That was an area the model21 had shown that we should not have seen22 overtopping of the flood walls in that area,23 and we were -- so we initially got a number of24 high water marks in that area and were able to25 get a petty clear understanding of what the

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1 actual elevation of the surge was. We were2 gratified to see that it was so close to our3 predictions. And then I wanted to be sure that

4 there was no harmonics in the canals or special5 sloshing or waves that could have caused6 overtopping in excess of the surge, and so7 traveled down the canals, looked at the -- any8 evidence of overtopping in the surviving areas9 of the flood walls, and then, um -- looked at

10 high water marks in the pump outfall bays.11 And, you know, at that time we were working12 just off of essentially water levels as our13 data and using a laser -- a laser level to14 translate. So. Approximate, but pretty good.15 Q. Was this surveying that you're16 describing now done after the hindcast was

17 performed?18 A. It was probably about the same time.19 Um -- our forecasts -- one of our forecasts was20 actually better than the hindcast, but they21 were both within about 15 percent.22 Q. When was the hindcast completed?23 A. If you don't mind, I'll look at --24 Q. Yes. Pleas do.25 A. Um --

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1 MR. O'DONNELL:2 What exhibit are you looking at?3 A. I'm looking here at Exhibit 4 because4 I noticed that there were some, um -- okay. It

5 doesn't show -- Advisory 31 was one of the last6 advisories issued by the National Hurricane7 Center for Hurricane Katrina. So the storm at8 that time, this was on August 30th at about ten9 o'clock, it's 1500 hours UTC, so that's ten

10 o'clock Louisiana time.11 EXAMINATION BY MR. SMITH:12 Q. Ten o'clock a.m.13 A. Yeah. They issued -- and at this time14 the storm center -- it was a topical storm and15 it was --16 Q. Had gone ashore?17 A. It had gone ashore. It was up in

18 Tennessee someplace. So that was the time that19 the advisory was issued. And I thought I had20 written down here surge analysis complete.21 Q. What are you looking at, sir?22 A. I'm looking at, I'm sorry, Exhibit 4.23 There was -- on Page 10, there's Table 1 and --24 Table 1. At the top of there, it shows the25 advisory date and time and then it shows the

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1 time that the surge analysis was complete. And2 I thought it would say when we did the3 post-storm analysis, but I suspect it was about

4 a week later. Obviously, at that point the5 hours were not that important. Remember, we6 were trying to race to get these things out7 within the six-hour intervals. Sometimes we8 succeeded, sometimes we didn't.9 Q. And then, so does this Table 1 reflect

10 all of the surge analyses that were performed11 by you and your colleagues at LSU?12 A. I believe it may not include all of13 them, because we may have run some off track14 surges. And some of those we may not have even15 analyzed as they later became passe.16 Q. Sure. Do you believe that these are

17 all of the on track --18 A. I believe so.19 Q. I'm sorry. Let me finish. I'm slow20 with my questions because the words are hard21 for me. But this is a complete list of the on22 track simulations that you and your colleges at23 LSU did with respect to Hurricane Katrina?24 A. That's correct. They can be found25 today as they came out of the computer. They

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1 are still on our website.2 Q. Do you believe there would be anything3 on the website that would indicate when the4 post-storm analysis was completed?

5 A. Probably.6 Q. But you believe --7 A. I should say, you know, I'm no longer8 associate with LSU so I'm not sure how they9 maintain that site. Yesterday I went looking

10 for it and I couldn't find it, but prior to11 that it was always there.12 Q. Well, if you can't find it, I doubt13 that I'll be able to.14 A. Um -- you know, I certainly hope they15 keep it there, because what we established as a16 precedent was that we would put everything that17 came out of the computer on there and people

18 could come and look at it. It was always19 labeled as experimental and they could make of20 it what they wanted. But none of that has been21 modified subsequently.22 Q. Are the opinions that you've expressed23 in your report for this litigation based upon24 any or all of these simulations that are listed25 in Table 1 on Page 10?

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1 A. I would say that the initial kernel of2 my understanding of the effect of this channel3 came out of that experience. Subsequently, we

4 have looked in much more detail than, um --5 than is documented in Team Louisiana.6 MR. O'DONNELL:7 But it does form one of the8 bases.9 THE WITNESS:

10 It forms -- that was how I got11 started in it.12 MR. O'DONNELL:13 Okay. You've done work since the14 Team Louisiana report.15 THE WITNESS:16 That's right.

17 MR. O'DONNELL:18 Okay.19 EXAMINATION BY MR. SMITH:20 Q. When you say subsequently you've taken21 a closer look of --22 A. That's right. That's right.23 Q. -- what data have you relied upon24 after you completed the simulations that are25 represented in Table 1 on Page 10 of Exhibit

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1 Number 4?2 A. Well, I was probably one of the most,3 um -- consummate consumers of the IPET report,4 for example. Probably one of the few people

5 that has read every volume of it.6 MR. O'DONNELL:7 You read it. You didn't eat it.8 A. Well, I'm a consumer. So -- and I of9 course was greatly informed by the ILIT team

10 and actually have maintained contact with a11 number of members of that team. And, you know,12 I've -- in the course of this work, after I13 finished the Team Louisiana report, I was14 recruited for this effort and have been15 involved in guiding some of the subsequent16 analyses that inform this effort.17 EXAMINATION BY MR. SMITH:

18 Q. When you say this effort, you are19 referring to the litigation?20 A. That's correct.21 Q. Have you performed any ADCIRC modeling22 since the completion of the final simulation23 that's set forth in Table Number 1 on Page 10?24 A. Yes. I remained at LSU through25 February of this year, and during that period

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1 we were funded to look at specifically the MRGO2 closure plans that were being developed, that3 Congress has now, um -- has now cited that the

4 MRGO should be closed and are -- the Hurricane5 Center was involved in some of the -- putting6 some of the options on the table in terms of7 the closure approach, and that required some8 simulations.9 Q. So are those simulations published

10 somewhere? Are they publicly available?11 A. Um -- let's see. I guess -- they may12 be in some of the reports that the Lake13 Pontchartrain Basin Foundation has issued with14 respect to the Mississippi River Gulf Outlet.15 Um -- in the Team Louisiana report you can see16 some of the initial efforts there, looking at

17 what would happen if you had a barrier, for18 example, that prevented surge from entering the19 MRGO Reach 1 and the IHNC.20 Q. I'm sorry. You say that's in the Team21 Louisiana report?22 A. Yes. Yes. There's a simulation.23 Q. Can you show me where that is, please?24 A. I'm saying you can see some of the25 early stages of that in this report. And it

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1 may take me a second to find. I think there's2 a mention of it also in the Science report that3 came out in April.4 Okay, if you look --

5 MR. O'DONNELL:6 Page?7 A. Okay. If you look in Appendix 4 --8 and I apologize, but Appendix 4 does not seem9 to have page numbers -- it's Figure A4.9.

10 THE STEVENS:11 What page is it on?12 MR. O'DONNELL:13 A-IV.14 A. But the whole appendix has that. So15 you have to look for Figure A4.9. This is an16 example of a -- now, this is what we call a17 MEOW, a maximum elevation of water. So one of

18 the products that ADCIRC produces, as to all19 search models, is a maximum elevation of water.20 This is not the elevation at any particular21 time, it is the maximum observed over the whole22 model domain during the run.23 MR. O'DONNELL:24 So where it says ten feet, it25 might be one time, but eleven feet a

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1 different time?2 THE WITNESS:3 No. It will never be higher then

4 ten feet --5 MR. O'DONNELL:6 Okay, thank you.7 THE WITNESS:8 -- but it could be eight feet, it9 could be nine feet.

10 MR. O'DONNELL:11 Right.12 A. So in this case, what he what we did13 was -- or I should say what Dr. Mashriqui did14 was essentially raise all the nodes to form a15 barrier across the funnel, essentially. You16 can see this kind of wavy white line that

17 separates the green. This is on the east side18 of the river in the funnel area along the shore19 of Lake Borgne, where Lake Borgne would be.20 Actually, you can you see in Figure A4.8, you21 can see an outline of the particular design.22 Okay? So this is an effort to model that23 configuration of a, um -- an improved levee24 system, or an improved flood protection system.25 This is very similar to what the folks

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1 in New Orleans East suggested in 1965. It's2 essential the same design. And what it shows3 is that then the area in the apex of the funnel4 and in these connecting channels, the IHNC and

5 what IPET has called MRGO Reach 1 are then6 controlled by lake levels -- Lake Pontchartrain7 levels rather than Lake Borgne levels. Okay?8 So this was an example of showing, um -- some9 of the ways that the MRGO and what kind of

10 closure would really be required. And most of11 that is in response to the congressional12 interest in the closure plan, trying to look at13 the --14 Okay. This is Appendix 4, Closing New15 Orleans Back Door, a Plan to Reduce16 Consequences of the Mississippi River Gulf17 Outlet and Improve Flood Protection. I believe

18 this was probably submitted as part of, um --19 testimony to Congress. I'm not sure.20 EXAMINATION BY MR. SMITH:21 Q. When it says, looking at the subtext22 below Figure A4.9 --23 A. Yes.24 Q. It says that peak surge in the25 southeastern part of the MRGO levee is raised

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1 about two feet, though it is greatly reduced2 elsewhere. What's that referring to?3 A. Okay. One thing about surge, and, you

4 know, we are dealing with Newtonian physics5 here, so water is essentially incompressible.6 So there's no free lunch here. When you7 prevent surge from going someplace it goes8 someplace else. And in this case, it piles up9 on that, um -- connecting levee, that structure

10 that has been created -- fictional structure.11 MR. O'DONNELL:12 As shown on Figure A4.8?13 A. Yes. That's correct. A4.8. And you14 can see actually you have this yellow color15 which is indicative of much higher surge, on16 the order of 19 feet or so, is actually

17 occurring now out midway out the MRGO Reach 218 as opposed to in the apex of the funnel where19 it occurred during Katrina.20 EXAMINATION BY MR. SMITH:21 Q. In fact, during Katrina it didn't22 actually occur in the apex of the funnel, did23 it?24 A. Actually, the maximum elevation25 occurred on south shore. There were -- you

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1 know, if you look -- if you take it time step2 after time step, there are many times when it's3 highest in the apex and other times when4 it's --

5 Q. Well, actually, I don't see any where6 it's highest in the apex. If you look at your7 own report --8 A. Okay.9 Q. -- and I'm again looking at Kemp

10 Declaration, which I think we have marked as11 Kemp Exhibit Number 1?12 A. Okay.13 Q. No, it's not Number 1. What number is14 that? I'm sorry.15 A. 3.16 Q. Number 3. Figure 12 on Page 30, which17 I believe you've previously pointed out was a

18 hindcast product --19 A. Page 30.20 Q. Page 30. I'm sorry.21 A. Okay. Yeah. I don't have a color22 copy.23 MR. O'DONNELL:24 Here. (Tendering.)25 A. Okay. So this is a -- okay, this is,

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1 um -- a snapshot taken at a particular time.2 At this particular time, the surge is highest3 on the south side. At other times it's highest

4 in the apex.5 EXAMINATION BY MR. SMITH:6 Q. And at this time, it's highest at the7 midpoint of the MRGO Reach 2 levees?8 A. Right.9 Q. Is that correct?

10 A. I mean, it's moving around so that's11 where it is then, yes.12 Q. This is at the peak surge time?13 A. That's at peak surge time.14 Q. And we can look at some different15 times by looking at, um -- the Team Louisiana16 report which has --

17 A. If you like, I can show you a number18 of times when it's highest right here.19 Q. I'd like to show you some times when20 it's not.21 A. It moves.22 MR. O'DONNELL:23 Okay. You're both right.24 A. Yep.25 THE STEVENS:

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1 Which comes first, the chicken or2 the egg? At the apex?3 MR. O'DONNELL:4 Let him ask his question.

5 MR. LAMBERT:6 Dr. Smith, when is it highest?7 EXAMINATION BY MR. SMITH:8 Q. Well, we have just looked at when it9 was highest, right?

10 A. That's correct. In this particular11 storm the maximum elevation is reached along12 Reach 2 of the MRGO. That doesn't mean that at13 other times it's not -- that the maximum14 elevation at that time step is not right in the15 throat of the funnel, because for a long time16 it was.17 Q. Well --

18 A. I think part of the, um -- we're used19 to representing things in this MEOW, that is,20 the maximum elevation of water, which usually21 represents no particular time step.22 Q. I'm sorry. I want to direct your23 attention to Exhibit Number 4 which is the24 report you prepared on July 28th of this year.25 A. What page is that?

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1 Q. Page 13, Figure 5.2 A. In the version I have, it's 15. Oh,3 no, this is --

4 Q. That's the wrong document. I'm sorry.5 A. This one.6 Q. Yes.7 A. Page 13. All right. Yeah.8 Q. This shows four different time stamps,9 correct, from the ADCIRC --

10 A. That's correct. Yes. I apologize for11 the reproduction here.12 Q. It appears that each of these times13 that the maximum storm surge is piling up all14 along the Reach 2 levees, not in the throat; is15 that correct?16 A. Um -- no, there are four times given.

17 In the first one on the left, which is at18 7:00 o'clock in the morning, it shows a pattern19 of surge on the south levee. I'd have to look20 and see if it's actually highest -- where it's21 actually highest in there. But it looks to me22 like its pretty much along the whole -- from23 the apex all the way out.24 If you look at when the storm is25 actually in the funnel itself, the eye of the

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1 storm indicated by the arrows circulating --2 MR. O'DONNELL:3 Which of the four is that?4 THE WITNESS:

5 This would be the one on the left6 on the bottom.7 MR. O'DONNELL:8 Okay.9 A. Okay. So you can see the storm is

10 moving north here.11 EXAMINATION BY MR. SMITH:12 Q. Right. The sequence goes, top left,13 top right, bottom left, bottom right; correct?14 A. That's correct. Okay. Yes. And at15 the top right, it -- you know, I'd have to look16 in detail to see where the actual highest is,17 but, yes, it's accumulated there.

18 In the next one, it's actually lowest19 in the apex because the storm is reversed, the20 wind direction, it's blowing out. But I can21 provide much better, um -- like I said, we're22 looking now at ten-minute intervals, so.23 EXAMINATION BY MR. SMITH:24 Q. Right. I can apologize, I don't have25 an extra copy of the IPET Volume Number 4, but

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1 I think you've previously mentioned that you've2 read this, and I think you indicate you relied3 in their work.

4 A. To the degree that it was reliable,5 yeah.6 Q. Sure.7 A. The appendices were generally more8 reliable than the rest.9 Q. Well, here's a detail of water surface

10 elevations which are Figures 5-8, um -- and11 there's a whole series of them. I ask you to12 look at those and comment on those surge13 elevations. I believe those are taken every14 hour, I believe?15 A. It looks like every two hours. Let me16 find the beginning. Okay, these are different

17 tests, testing different boundary layer effects18 on winds. There are probably minor differences19 among them, I would suspect. And so as you20 page through, you march two hours at a time.21 Q. In sequence, right.22 A. And, you know, initially, of course23 the surge is along the lower part of the24 Mississippi River out towards the mouth, but25 then we begin to see --

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1 Q. When you say initially, you're looking2 at Figure 5-7C, is that correct?3 A. That's right.4 Q. And why would the surge be highest

5 along the Mississippi River at that time?6 A. Well, also shown on this diagram is --7 are the direction of the winds. It's not --8 actually, they're showing magnitude also. And9 so the winds tend to be pushing the surge into

10 that indentation in the coast.11 Q. A little pocket is created there by12 the levees along the Mississippi River, is that13 correct?14 A. That's right. And then as the15 storm -- it's essentially following a due16 north -- a northerly track across the mouth of17 the river. And of course on the other side of

18 the river it's blowing water out, and so the19 water is actually reduced on the downwind side20 of --21 Q. Western side of the river.22 A. -- river.23 Q. But now, if look at these, if we focus24 our attention on what we have called Reach 2 of25 the MRGO where the hurricane protection system

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1 structures bordered the channel --2 A. Uh-huh.3 Q. -- we see wind currents which are

4 basically perpendicular to that levee reach, is5 that correct?6 A. Um -- I'm trying to see where -- okay,7 it looks like they're pretty close to normal,8 yes. They're slightly to the north of9 perpendicular.

10 Q. Normal meaning?11 A. Orthogonal. 90~degrees.12 Q. Thank you.13 A. And then two hours later, we see that14 the -- that the model is predicting the first15 overtopping in the Inner Harbor Navigation16 Canal. And probably, if anything, the vectors

17 for the winds are more exactly perpendicular to18 the reach.19 Q. And again -- excuse me. I'm sorry for20 speaking over you. But again, the surge is21 piling up all along those hurricane protection22 structures along Reach 2 of the MRGO?23 A. That's correct. And then as you move24 into, um -- as you move into two hours later,25 then we now see the surge is -- of course, the

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1 storm is centered, now, essentially at the2 Breton Sound end of the gulf outlet, and so3 you're closer to the center of the storm, and4 circulation then is actually on the -- it's now

5 veered back around, so it's a little b

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