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WESTERINK (VOL II), JOANNES1/28/2009

Johns Pendleton Court Reporters 800 562-1285

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF LOUISIANA

IN RE: KATRINA CANAL BREACHES CIVIL ACTION

CONSOLIDATED LITIGATION

NO. 05-4182

"K" (2)

PERTAINS TO: MRGO ROBINSON JUDGE DUVAL

MAG. WILKINSON

VOLUME 2

VIDEOTAPED DEPOSITION OF

JOANNES WESTERINK,

taken in the offices of the United States

Department of Justice, 400 Poydras Street,

Suite 900, New Orleans, Louisiana 70130, on

Wednesday, January 28, 2009.

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1 APPEARANCES:23 THE GILBERT FIRM

BY: ELISA GILBERT, ESQ.4 325 East 57th Street

New York, New York 100225 ATTORNEY FOR THE PLAINTIFFS

6LAW OFFICE OF JOSEPH M. BRUNO

7 BY: SCOTT JOANEN, ESQ.855 Baronne Street

8 Third FloorNew Orleans, Louisiana 70113

9 ATTORNEYS FOR PLAINTIFFS LIAISONCOUNSEL

10

11 LAW OFFICE OF ELWOOD C. STEVENS, JR.BY: ELWOOD C. STEVENS, JR., ESQ.

12 1205 Victor II Blvd.Morgan City, Louisiana

13 ATTORNEYS FOR PLAINTIFFS14

15 UNITED STATES DEPARTMENT OF JUSTICEBY: ROBIN SMITH, ESQ.

16 JACK WOODCOCK, ESQ.Torts Branch, Civil Division

17 1331 Pennsylvania Avenue NW

Room 8095N18 Washington, D.C. 20004

ATTORNEYS FOR UNITED STATES OF19 AMERICA2021

VIDEO BY: Gilly Delarmal22 Depo-Vue2324 REPORTED BY: ROGER D. JOHNS, RMR, CRR, CSR

Certified Court Reporter,25 State of Louisiana

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1 S T I P U L A T I O N23 It is stipulated and agreed by and between

4 counsel for the parties hereto5 that the deposition of the aforementioned6 witness is hereby being taken under the7 Federal Rules of Civil Procedure, for all8 purposes, in accordance with law;9 That the formality of reading and signing

10 is specifically not waived;11 That all objections, save those as to the12 form of the question and the responsiveness of 13 the answer, are hereby reserved until such14 time as this deposition, or any part thereof,15 may be used or sought to be used in evidence.16

17 * * * *18

19 ROGER D. JOHNS, RDR, CRR Certified Court20 Reporter, for the State of Louisiana,21 officiated in administering the oath to the22 witness.23

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1 VOLUME 2 OF THE VIDEOTAPED DEPOSITION2 OF3 JOANNES WESTERINK,

4 who, after having been duly sworn by the5 before-mentioned court reporter, did continue6 to testify as follows:7 EXAMINATION BY MS. GILBERT:8 Q. Good morning.9 A. Good morning.

10 Q. We're going to continue from11 yesterday and I am going to jump right into12 your report if it's all right. Actually, we13 went over yesterday the Manning coefficients14 --15 A. Yes.16 Q. -- that you had mentioned were --

17 that you had and I just wanted to -- Actually,18 you know what? Before I do that, I want to go19 right into your surge thing. Can you turn to20 206, your figure 196.21 A. Yes.22 Q. Okay. Now, I am just going to ask,23 this is a storm surge hydrograph for station24 number 1315, and that would be the area25 closest to the Lake Pontchartrain entrance to

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1 the IHNC?2 A. Let me check that. Gosh, I'm having3 a hard time seeing at this scale.4 Q. That was part of the --

5 A. I should have put this thing a6 little bit bigger. Can you see, Jack?7 MR. WOODCOCK:8 Where is the station?9 THE WITNESS:

10 It's in 192.11 EXAMINATION BY MS. GILBERT:12 Q. Can we mark the Notice of 13 Deposition? It's right here.14 MR. WOODCOCK:15 Put these glasses on.16 THE WITNESS:17 No kidding. Actually, we have

18 been looking at this electronically.19 You don't mind if I pull up an20 electronic copy, do you?21 EXAMINATION BY MS. GILBERT:22 Q. No, feel free. But before you do, I23 wanted to mark this also. This is the Notice24 of Deposition that was served for this25 deposition and it has an Exhibit A on it with

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1 documents that were requested; and among the2 documents that were requested were the maps,3 larger versions of these maps. But please

4 feel free to call it up if you have it so that5 we can get through discussing this.6 MR. WOODCOCK:7 It looks like 1318 is just west8 of the confluence between --9 THE WITNESS:

10 It's 1315 actually.11 MR. WOODCOCK:12 Oh, 13 --13 EXAMINATION BY MS. GILBERT:14 Q. So it's GIWW/IHNC.15 A. All right. That would be closer to16 the confluence.

17 Q. Yes. I see what you're saying.18 Yes, that would be by the bottom. But just19 when they're entering. Are you following me?20 Are we -- You're still waiting for it to pull21 up?22 A. I'm just pulling it up here so I can23 see.24 MR. SMITH:25 What page are we on?

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1 MS. GILBERT:2 It's 206. It's the surge map.3 THE WITNESS:4 Do you have a PDF version, by the

5 way?6 EXAMINATION BY MS. GILBERT:7 Q. Do I have a PDF version of your --8 A. An electronic PDF version of the9 report.

10 Q. What I printed out was from the PDF11 version.12 A. Okay. So if --13 MR. SMITH:14 I think he was just asking if you15 could pull it up on the machine, you16 could enlarge it yourself.17 THE WITNESS:

18 Yeah.19 EXAMINATION BY MS. GILBERT:20 Q. Oh, yes. Well, I kind of know where21 I am talking about. I misspoke before, but I22 think I have got the right idea.23 MR. SMITH:24 It would have been figure 19- --25 EXAMINATION BY MS. GILBERT:

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1 Q. Figure 196. Do you have it?2 MR. WOODCOCK:3 We're just trying to figure out

4 where that is.5 (Whereupon a discussion was held6 off the record.)7 THE WITNESS:8 Okay. So 1315, it's right at the9 confluence of the GIWW/MRGO Reach 1

10 and the IHNC, a little bit on the --11 it's right within the MRGO/GIWW Reach12 1.13 EXAMINATION BY MS. GILBERT:14 Q. Is it that dot that's closer to the15 Reach 1 or is it the dot that's kind of a16 little bit further into the IHNC?

17 A. It's just a little bit to the east,18 so there's two in the southern segment of the19 IHNC. There's three in the northern segment.20 One in Lake Pontchartrain just to the west of 21 the Lakefront Airport. And then there's four22 in the GIWW/MRGO and it's the westernmost one.23 Q. Okay. So would this station be the24 place that would see the largest impact of the25 water flow from the MRGO into the IHNC that we

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1 could --2 A. Maybe you could clarify that?3 Q. Well, would this be the correct4 station to identify, to look at to see the

5 surges, the impact of the surges from the MRGO6 into the IHNC?7 A. Well, that's the -- it's really the8 flow of the surge that gets developed to the9 east of Paris Road. Right? Then there's

10 surge elevations right on the southern shores11 of Lake Pontchartrain, and those two points12 really control the flow through the MRGO/GIWW13 Reach 1/IHNC.14 Q. Okay.15 A. So really there's a whole16 variability of flow and elevations along that17 stretch.

18 Q. Okay. Would this be the location,19 though -- Of all of these station markers to20 look at on your surges, would this be the one21 that would identify most clearly the impact or22 an impact of -- if we're looking at all six23 scenarios on this, --24 A. Yeah.25 Q. -- so I am trying to figure out

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1 which would be the most effective location,2 station marker to look at to see just an3 overall picture of where the most impact of

4 the MRGO as a whole would be in the IHNC.5 A. Okay. So the maximum impact,6 potential impact, or the maximum difference7 between the basin area and some of the8 perturbed scenarios would be located in and9 around this region.

10 Q. Okay. So if we look at this just --11 this particular surge -- I am just trying to12 isolate which one would be the best one to13 discuss for a general outcome of all six14 scenarios. So on this particular surge map,15 which is on -- which is figure 196, just as a16 general interpretation of this surge

17 hydrograph, it shows that there is a reduction18 of about, let's see, 3 and a half feet from19 H-1, which is our base line scenario, right,20 that black line?21 A. Right.22 Q. To the "No MRGO", which would be I23 guess -- H-2 is down right above -- on the24 horizontal line, it's right above 10 and right25 next to -- right to the right of 29.3?

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1 A. Uh-huh (affirmatively).2 Q. Okay. And that's a reduction from3 approximately -- you know, a little lower than4 14, maybe about 13 and a half to 10? Does

5 that -- Is that a proper interpretation?6 A. At that location, yes.7 Q. At that location. So we have a8 reduction of approximately 3 and a half feet9 of surge height with the removal of the MRGO

10 in your study at this location.11 A. Yes.12 Q. I am just trying to read through it13 with you so that I understand.14 A. That's just at that location,15 though.16 Q. Sure.17 A. Of course, there's the -- The

18 differentials between the various cases --19 Q. Yes.20 A. -- changes dramatically along the21 entire Chalmette levees.22 Q. I'm asking only about this so I23 don't want to confuse it --24 A. Sure.25 Q. -- so that we can get through this

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1 particular thing.2 And then with regard to the3 configurations that deal -- and -- The surge

4 levels and the times. So we have basically a5 still water differential of 3 and a half feet6 between those two configurations and shorter7 durations. You basically have shorter8 durations of waves, of surge, and lower9 elevations of surge, without the MRGO in this

10 because that bump there?11 A. That's for cases H-2 and H-3 --12 Q. H-3.13 A. -- and H-4.14 Q. And H-4. And then with regard to15 cases H-5 and H-6, there's a reduction in16 surge level, but there isn't too drastic a

17 reduction in duration.18 A. I would say that there's a -- you19 know, maybe, what would you say, maybe a20 quarter of a foot reduction in surge level and21 the duration is pretty much the same.22 Q. Okay. On those two. But there is23 some difference no matter what, assuming all24 the variables that are input and all of your25 studies are correct, at this location you have

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1 both -- you have some reduction in the surge2 level and the elevation in wetlands -- I mean,3 surge level and the duration just by the4 influence of the wetlands, and a much greater

5 apparent reduction in surge level and duration6 with the removal of the MRGO?7 A. Actually, I think the predominant8 influence on this particular set of 9 hydrographs and on the surface elevations

10 along the GIWW/MRGO Reach 1 and the IHNC, and11 particularly in the heart of it where we're12 looking right now where there's pretty much13 the maximum differences, that those were14 predominantly due to the reduction of the MRGO15 Reach 1 channel, MRGO/GIWW Reach 1 channel to16 the 1958 GIWW width and depths.17 Q. Okay. I understand. We'll go into

18 the specific variations on it. But as a19 general proposition looking at this just on --20 on all of them, not which is the most and21 which is the least, --22 A. All right.23 Q. -- but just looking at this location24 and all of your scenarios, and assuming all of 25 the data is accurate, do you see a reduction

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1 -- We're just getting the base line2 understanding then.3 A. Okay.

4 Q. You can see a reduction in surge5 level just with the effect of the wetlands and6 you see a greater reduction in surge level and7 duration with removal of the MRGO on any of 8 the scenarios that deal with the MRGO, with9 the removal of the MRGO.

10 A. Well, just to modify that a little11 bit, --12 Q. Okay.13 A. -- I believe that our -- that, first14 of all, that the predominant or major15 influence was the reduction of the GIWW/ --16 Q. Okay.

17 A. -- MRGO.18 Q. I understand we have got different19 variations on the scenario --20 A. Right.21 Q. -- but we have got -- we have got22 them all defined in your surge patterns.23 A. Correct.24 Q. So each one of them -- But all of 25 them have the same pattern. So we'll go into

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1 the H-1, H-2, H-3 and which one it is2 separately.3 A. All right.4 Q. But looking at this on a just

5 general basis, those statements are correct?6 That the scenarios H-5 and H-6 reduce the7 surge level from the H-1 scenario, and the8 scenarios H-2 and H-3 and H-4 both reduce the9 surge level and reduce the duration of the

10 waves?11 A. Okay. Maybe I could give my12 interpretation of looking at these. I would13 say that, and not getting into causes right14 now, but my conclusion of this particular set15 of hydrographs is that H-4, H-5 and H-6 have a16 very -- a minor reduction, and let's call it17 on the order of less than half a foot or a

18 quarter of a foot, in that range somewhere,19 and pretty much the same duration as the base20 case. And then I would say that H-2, H-3, and21 H-4 have a more substantive reduction at that22 particular location, and I think it's up to23 about 3 and a half feet for H-2 and H-3, and24 then somewhat less for H-4. And also the25 duration is in fact less.

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1 Q. Okay. So that's pretty much the2 same. We're not disagreeing. You're making a3 qualitative different on what you consider

4 significant or substantive, but, in fact,5 there is a reduction in H-5 and H-6, and6 there's a greater reduction for H-2 and H-37 and the duration issue. Right? I am just8 trying to make sure I understand it.9 A. Well, it's just, you know --

10 Q. We're saying substantively11 different, substantially different. I'm just12 saying different. It's lower. We'll get into13 the significance or the difference.14 A. Okay.15 Q. Because I think, if I am not16 mistaken, the significance of the difference

17 in the substance of the great -- the height18 and the duration is affected by the input19 information, the data you input for that.20 Correct?21 A. Well, it's affected by the storm22 certainly, yeah.23 Q. Well, it's also affected by all of 24 the relative data that the computations have25 concluded. So assuming that all of the data

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1 computations that are in there are correct,2 this hydrograph shows a reduction based on the3 scenarios H-5 and H-6 and a greater reduction4 and a shorter duration for H-2 and H-3, and

5 that's assuming everything is correct in your6 computations.7 A. Well, just add a little bit more8 information there. The correctness of the9 computations, of course, we make sure that we

10 input everything correctly is -- is11 substantiated by the validation process.12 Q. I am assuming -- That's part of this13 question.14 A. Okay.15 Q. I am assuming that we have validated16 it and I am assuming for the purposes of this17 question, which is a very simple question, --

18 A. Okay.19 Q. -- that that is all accurate.20 A. Right.21 Q. And I am not arguing with any of 22 that. I am asking you purely the simple23 question of whether or not this hydrograph24 shows a reduction in the height of the surge25 for H-5 and H-6 at this location and this

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1 hydrograph also shows a greater reduction in2 surge and a shorter duration for H-2 and H-3.3 It's a base line question just trying to get

4 to the next one, Doctor. I am really not5 getting into --6 A. I know, but, you know, you do7 understand that what is a substantive8 reduction, that in a model if you have a very9 --

10 Q. It's a graph; no? It's a graph. Is11 it lower?12 A. It's very -- very slightly lower.13 Q. On H-1. For H-1 -- for H-5 and H-614 it's slightly lower, and for H-2 and H-3 it's15 more than the other distance lower. Correct?16 A. Yes.

17 Q. Okay. That's all. That's it.18 Because we want to get past this one graph. I19 just want to get the base line interpretation20 on the record. It's really not a trick 21 question.22 A. I understand it's not a trick 23 question, but, honestly, in the engineering24 world you have to really look at the -- how25 different things are. And, of course, the

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1 importance of that --2 Q. And we'll get into that.3 A. Okay.4 Q. But this is a graph that was

5 produced, and to read this graph, you need to6 understand that if those lines are lower, what7 you're trying to show is that the surge is8 less; and if they're closer together, the9 duration is shorter. And that's really what I

10 am trying to establish, because somebody has11 to read this --12 A. Right.13 Q. -- and understand how to read this14 from reading this. And that's really it. And15 --16 A. Right.17 Q. -- then we'll get into whether or

18 not it's a substantial difference --19 A. Okay.20 Q. -- or whether you consider it a21 great difference.22 A. I just wanted to make sure that we23 understand the adjectives.24 Q. And we'll get into it. But it's25 very important that you answer the question I

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1 ask, because we won't get on to any of that if 2 we don't get those questions out of the way.3 A. Okay.

4 Q. And we want to get to that stuff.5 It's very important to everyone --6 A. I know. Right.7 Q. -- and we will get to it if we get8 off these basic questions easily.9 A. Can I make a quick comment?

10 Q. Okay.11 A. I am from just trying to make sure12 that we are very precise in terms of how we13 describe these things.14 Q. I appreciate --15 A. That's very important from a16 engineer's perspective.

17 Q. I understand. But if you listen to18 the question, I was not making a value19 judgment on this. I was just asking you to20 help me read this into the record. And we21 will, when we have to analyze this stuff --22 You have got a 300 pages here.23 A. Yeah.24 Q. And we would like to get to them.25 A. Right. And also I was just

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1 clarifying, in terms of your general2 statement, that you were saying that what the3 origin was, I just wanted to make sure that we4 will get to those details later as well.

5 Because that's important as well. And it's6 covered in the report.7 Q. It's covered in the report. We want8 to get to the report. I would love to get to9 the report.

10 A. All right.11 Q. Okay.12 A. Go for it.13 Q. All right. Yesterday we talked a14 little bit about a study you had done, and I15 am not sure whether I have the correct -- Let16 me just check whether I have. Where you're --17 You discussed briefly a study that you did

18 where, prior to working on this, and I believe19 it was prior to IPET, where you had examined20 closing the MRGO Reach 2 and the effects of 21 closing the MRGO Reach 2 --22 A. Yes.23 Q. -- on flooding in the area. And I24 just want to ask you if this report "Notes on25 influence of Mississippi River Gulf Outlet on

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1 hurricane-induced storm surge in New Orleans2 and vicinity," report dated February 21st,3 2006 by Westerink and Ebersole, reflects that

4 study parameter.5 A. I believe this is a little bit later6 study. And -- Yeah. I believe.7 Q. It think it describes it in the --8 A. That this study modified more than9 just the MRGO.

10 Q. I think that study might actually11 reflect all of the studies previously. It has12 a section that discusses -- If you'll turn to13 page 3, it describes three previous studies.14 And if I am not mistaken -- I couldn't15 actually find a report for each one, but I16 think it outlines all three of them in there.

17 A. Uh-huh (affirmatively). Right.18 Q. Is that correct?19 A. And two are the ones that I20 described to you yesterday.21 Q. And then I think that one that you22 -- What was the company?23 A. The Brettschneider and Collins one24 from 1966 we did not talk about yesterday.25 Q. Okay. And then there's one where

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1 LaLoutre Ridge was cut off, and that was a2 study done -- a barrier was put up at LaLoutre3 Ridge.4 A. So this --

5 Q. And there was a study -- I'm sorry?6 A. This study, by the way, talks about7 the one, just to clarify, about that study we8 were talking about yesterday and then a9 follow-up URS study, right? It talks about

10 the follow-up URS study?11 Q. Yes. It suggests also that there12 was another study maybe that -- Did you13 participate in the URS study?14 A. No. We -- Okay. Let me just15 clarify my participation is we handed them the16 code, we handed them the grids that we had;17 they proceeded to do the rest of the study.

18 We did not -- We provided the model and the19 code and then they conducted the study20 entirely on their own.21 Q. Did you do a subsequent study where22 you ran it with the MRGO -- the Reach 223 entirely closed? Or --24 A. Well, if memory serves me correctly,25 in our initial study, which would be in this

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1 document that you have, study 2, I believe, we2 closed the MRGO Reach 2; and I don't recall3 the details of the URS study. I would have to

4 look through my notes. May I read through5 this document here?6 Q. This document says that the second7 study cut off the MRGO Reach 2 at LaLoutre8 Ridge.9 A. Oh, okay. So here it's the closing

10 -- Okay. Yes. Actually, now I -- my memory11 is refreshed. That is correct. So we12 actually just put a barrier in at LaLoutre13 Ridge, and it was actually in this study where14 we actually filled it all the way in.15 Q. Now, you filled it in in study16 number 2 where you put the barrier at LaLoutre

17 Ridge?18 A. All right. Let me -- Can I read this19 carefully for a minute?20 Q. Please.21 A. Okay. So it's study number 222 actually sticks in a barrier at LaLoutre23 Ridge.24 Q. Right. It doesn't fill it in?25 A. No, it doesn't fill it in.

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1 Q. Okay.2 A. So actually, unlike I said, there's3 been a whole bunch of these things. So it was4 only during this study that you just handed me

5 that we actually filled the whole MRGO Reach 26 in.7 Q. And the study, that was a study that8 was done by URS?9 A. Well, let's see.

10 Q. The follow-up study at the bottom11 says "Commissioned by the State of Louisiana,12 Department of Natural Resources and13 implemented by URS Corporation".14 A. Right. Yeah.15 Q. So you never did a study that filled16 in all of Reach 2?17 A. Well, this study over here did.

18 Q. Okay. All right. Let's turn to the19 last figure, 4-B, of this study. And we can20 mark this for the record if you don't mind.21 Can you put a sticker on the front22 page of that, Doctor?23 A. Oh, sure.24 Q. Thanks. And we'll mark as Exhibit 325 for the record, is the full report of "Notes

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1 on influence of the Mississippi River Gulf 2 Outlet on hurricane-induced storm surge in New3 Orleans and vicinity", dated February 21,

4 2006. It's a 21 page document.5 All right. Now, does this graph,6 figure 4-B, reflect the increase in water7 level in the vicinity as a result of having8 filled in all of the MRGO Reach 2 for the9 Hurricane Katrina event?

10 A. Let's see. Maximum hurricane event11 differences in feet in Metropolitan New12 Orleans and vicinity for simulations with and13 without the MRGO in place. Positive14 differences indicate increased elevations with15 the MRGO in place, while negative differences16 indicate decreased water levels.

17 Q. And those positives and negatives18 are reflected in the graph on the upper19 left-hand side?20 A. Right. And it looks like the scale21 is about a tenth of a foot, so each -- each22 difference is about a tenth of a foot. So,23 for example, a white area within white regions24 are within a tenth, and then it looks like --25 like some of the differences, well, the

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1 greenish or most of the scale in and around2 Lake Borgne and to the east of the New Orleans3 -- I mean to the east of New Orleans East and4 to the east of the St. Bernard polder are just

5 even a little bit lower or maybe a tenth,6 two-tenths of a foot higher.7 Q. So there is -- So that light blue8 area by -- Well, let me just ask one other9 question. Do you have levees -- Do you know

10 what the height of the levees were that you11 set up for the purposes of this study?12 A. I think those were probably our best13 estimate of pre-Katrina levees at that time.14 Q. How were you calculating your best15 estimate of pre-Katrina levees at that time?16 A. Data from the Corps of Engineers.17 Q. Was that from a survey? Do you

18 know? Or do you have any idea how those levee19 heights were calculated?20 A. Those were -- Those were datas --21 data that they had in their -- from their22 surveys that were provided to us.23 Q. When they provided the survey, do24 you know when that last -- when the survey was25 taken, or do you have any idea?

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1 A. I would have to try to go back 2 through my notes on that.3 Q. So you wouldn't know whether it was

4 like the design -- as designed heights or5 somebody went out and took a survey more6 recent?7 A. Oh, no they were -- they had actual8 elevations.9 Q. They had done an elevation survey?

10 A. Uh-huh (affirmatively).11 Q. Okay. For this particular -- At12 this time. Okay. So that was before Katrina13 they had done the elevation surveys?14 A. They had data that they then15 adjusted, and I am not sure whether this was16 -- this study was yet at the 2004.65 datum.

17 I would have to go back through and look at18 that very carefully.19 Q. Well, I am going to would ask if you20 could to provide -- We'll leave a blank or21 we'll request it officially through your22 Counsel also, but we'll put a mark in the23 record, if you would, for a request for that24 information.25 A. Because the 2004.65 vertical datum

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1 was, of course, evolved as things went along.2 Q. Okay.3 A. And this is, of course, fairly early4 on after the hurricane event. So I am not

5 sure whether the NOAA/Corps of Engineers team6 that was responsible for adjusting or finding7 out what the true vertical datum was had8 completed their work. In fact, my assumption9 would be that they had not.

10 Q. Okay.11 A. So it looks like actually that we12 were still working with NGVD --13 Q. NGVD --14 A. That we were still working with NGVD15 29.16 Q. NGVD 29 elevations for the levees?17 A. Right. And also for the water

18 levels.19 Q. Okay. NGVD. Okay. And does this20 reflect that there was an increase in water21 level, however slight, in New Orleans East,22 the metro -- the New Orleans metro bowl and23 the St. Bernard central wetlands area?24 A. Well, it looks like there's a little25 bit of a decrease in and around the large

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1 segment, east-facing segment of the Chalmette2 levee.3 Q. A decrease?

4 A. Correct.5 Q. Meaning --6 A. Slightly water -- Slightly lower7 water levels. Those are kind of the blues and8 purples.9 Q. Oh, down further on MRGO Reach 2

10 area, the darker blues are decreased. Okay.11 A. Right.12 Q. I see. And then moving up towards13 the Reach 1 area where the confluence of Reach14 1, Reach 2 is at, it's increased right at that15 --16 A. Yeah. Just ever so slightly. Maybe

17 two-tenths of a foot or something like that.18 Q. And north of the GIWW it's increased19 also ever so slightly, but it's increased like20 a .2 or .3 north of the GIWW there?21 A. You mean in New Orleans East?22 Q. Right.23 A. A little bit, yeah.24 Q. And there's an increase in water25 level in the metro area, the Orleans metro

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1 area, which is the area I guess west of the2 IHNC?3 A. Okay. So one thing I should clarify4 is -- And then it looks like there's -- Well,

5 first of all, it looks like there's less than6 a tenth of a foot right in the IHNC in the7 western segment of MRGO/GIWW Reach 2 -- Reach8 1. I'm sorry. And then --9 Q. Okay. You're talking about --

10 A. I should clarify --11 Q. Wait. Let me just clarify, because12 I want the question answered, because13 otherwise it's just going to unreadable. At14 the end of the day it's not whether I15 understood what you showed me on a picture;16 it's going to be whether we can read it.17 A. Sure.

18 Q. So it's a little tedious, but if 19 you're patient we can get through it.20 A. Absolutely.21 Q. What my last question was, with22 regard to the area west of the IHNC, there is23 that light bluish-green markings.24 A. Right.25 Q. And based on this scale, that

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1 suggests or says that there is an increase in2 water level, either .2 or .3 west of the IHNC;3 correct?

4 A. Well, I should add a little bit of 5 clarification if I may.6 Q. Uh-huh (affirmatively).7 A. The ADCIRC calculations were not8 used for interior drainage. So within the9 polders. And one of the reasons that they

10 were not is that we do not account for wave11 overtopping. Wave overtopping --12 Q. Okay. Wait. I hear you. I want to13 -- First let's get to the answer to that14 question and then we'll get into wave15 overtopping, because that will be a whole16 another subject and we'll be talking about

17 that for a while. And I don't want to divert18 -- While we're talking about it, there is an19 increase in water --20 MR. SMITH:21 Elisa, excuse me. Just before22 you go on, would you allow him to23 complete his answers before you24 interrupt?25 MS. GILBERT:

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Page 34

1 Well, my only question -- my only2 fear is that, and the only reason -- I3 am not trying to stop him from4 answering that portion of the

5 question. I just don't want to lose6 track of the question I asked. He can7 answer; I'm more than happy to have8 him answer the question. He answered9 about the ADCIRC and the calculation

10 of running out, but I don't want it to11 be not clear why we're asking -- why12 that's out there. It's important, and13 I am happy to have him explain it, but14 if he starts a question with "Yes,15 that area is blue, and this is my16 clarification for that," or "No, that17 area is not blue, and this is my

18 clarification for that," I'm happy to19 let him do that. But if he could just20 answer the portion of the question21 first and then elaborate as much as22 you want.23 EXAMINATION BY MS. GILBERT:24 Q. And I don't want to interrupt you on25 it, because it is important for me to know

Page 35

1 that and I am not trying to cut you off. Just2 the question was, does that blue area --3 MR. SMITH:

4 Elisa, just before you go on, you5 have been cutting him off repeatedly.6 MS. GILBERT:7 The question -- But, Robin, --8 MR. SMITH:9 And I ask that you allow him to

10 finish and then if you want to follow11 up to clarify --12 MS. GILBERT:13 We'll just have to go back and do14 it.15 MR. SMITH:16 Elisa, you're interrupting me

17 now. Then if you want to go back and18 clarify your question or reask your19 question another way, that's fine to20 do so. But please stop --21 MS. GILBERT:22 Okay.23 MR. SMITH:24 -- interrupting the witness when25 he's talking.

Page 36

1 EXAMINATION BY MS. GILBERT:2 Q. And I am going to ask also that if 3 it's possible for you to start your question4 -- your answer, even if you want to clarify,

5 which I am happy to have you do, if you start6 with the answer and then clarify what the7 answer is, we can move on to the next8 question.9 A. Sure.

10 Q. And I can ask it. So that would be11 great. Okay.12 A. All I am trying to do is make sure13 that you understand the context in which the14 calculations are done, what the models are15 used for, and if there's -- for example,16 models that these calculations are not used17 for, the interior drainage, there's a whole

18 team that did those calculations. So that --19 the -- We are not to the point that we -- we20 used the ADCIRC calculations for the interior21 drainage within the actual polders and that22 there's just a lot more detail that still goes23 into those calculations and -- for example,24 during IPET and beyond. So that it's a25 complicated process. So yes, we can talk

Page 37

1 about these numbers, but there's a lot more to2 it that we didn't -- those details were not3 yet in this model.

4 Q. Okay. But for the purposes of this5 model, what that shows is that there was an6 increase in water in those -- in the area west7 of the IHNC; is that correct?8 A. So it looks like -- West or east?9 MS. GILBERT:

10 I just got turned off. I don't11 think this thing is working. Off the12 record for a second.13 VIDEO OPERATOR:14 We're off the record.15 (Whereupon a discussion was held16 off the record.)

17 VIDEO OPERATOR:18 Back on the record. It is19 10:10.20 MS. GILBERT:21 Can you just read back the last22 question and answer part?23 (Requested question read back.)24 EXAMINATION BY MS. GILBERT:25 Q. The question was west of the IHNC.

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Page 38

1 A. Okay. So my answer is, this2 particular calculation shows that there's3 about a tenth of a foot increase in surface4 water elevations, but in general, any of the

5 interior drainage calculations should not be6 trusted because of the, A, level of detail; B,7 we didn't include breaching in any of this.8 Right? So that the levees were not breached.9 And, 3, we didn't have any kind of wave

10 overtopping. So that's why for the Corps'11 purposes, these interior, inside the polders12 calculations from ADCIRC were not used. And13 more detailed models on interior drainage were14 used for that purpose.15 Q. Who did the interior detailed models16 for drainage purposes in those areas?17 A. Well, there's a whole team at the

18 Corps. For IPET, it was led -- co-led by19 Steve Fitzgerald.20 Q. Okay.21 A. And the Corps has its own22 capabilities of computing interior drainage.23 Q. Okay.24 A. And they hire contractors to do it.25 Q. But did they take this data to start

Page 39

1 off, you know, as we talked about yesterday,2 did they take this data to start their3 building blocks and then they started, they

4 did their own additional analysis on that?5 A. Interior drainage. And so they --6 That's correct. So they take this data7 external to any of those major leveed polders8 and then they take it from there.9 Q. Okay. That's great. Thank you.

10 All right. Now, yesterday we11 talked a little bit early -- towards the end12 of the day about the Manning coefficient typo13 in your report and I want to get back to that14 for a second if I could just to clarify for15 the record the specifics of that. In your16 report at --

17 MR. WOODCOCK:18 89.19 (Whereupon a discussion was held20 off the record.)21 EXAMINATION BY MS. GILBERT:22 Q. Just to back up a bit, you, in order23 to calculate the terrain in the vicinity of 24 the MRGO, you used the LIDAR -- or what did25 you do in order to calculate the terrain in

Page 40

1 the vicinity of the MRGO?2 A. Okay. So their early models used3 LIDAR data. But the LIDAR data was deemed as,4 because of a whole bunch of issues,

5 reflectivity off the marshes, the porosity of 6 the marshes, et cetera, it's quite difficult7 for them to manipulate. Also, there's datum8 issues. So for early studies, we did use the9 LIDAR, but we found actually that there were

10 some discrepancies between the various LIDAR11 tiles. So all of a sudden the same marsh a12 couple of feet over would be dramatically --13 100 feet over would be dramatically different,14 or different within I believe it was a half a15 foot to a foot. But we -- Obviously that was16 not -- We knew that there was a problem with17 this data and that's become pretty

18 recognized. All of this LIDAR data, by the19 way, is pretty new. So then we had extensive20 discussions with USGS and their specialists21 and they informed us that there's a very good22 consistency to the elevations of the coastal23 marshes relative to the water levels in this24 area. That if you know the type of marsh and25 the type of land cover, then you can actually

Page 41

1 establish a fairly accurate surface elevation.2 Q. Who was it that told you that?3 A. Mr. Baras --

4 Q. Okay.5 A. -- and other people at the Corps. I6 think Bob Kleiss and I forgot some of the7 other people that were involved.8 Q. Can you spell that Kleiss? Is it a9 "K" or a "C"?

10 A. "K".11 MR. WOODCOCK:12 "K".13 THE WITNESS:14 L E I S S, I believe.15 EXAMINATION BY MS. GILBERT:16 Q. And did they refer you to any

17 documentation or any support for that?18 A. They actually at the time did share19 data with that, but then they gave us -- they20 gave us guidance as to what the surface21 elevations should be.22 Q. And how did that guidance -- what23 form did that guidance come in?24 A. It related a land marsh type to a25 surface, approximate surface elevation.

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Page 42

1 Q. Was it in a graph or was it in a2 chart or was it actual --3 A. It was in a list of land types4 related to surface elevations.

5 Q. So it was not one of these color6 charts? It was an actual list?7 A. Well, we -- we then, of course, base8 it off their -- either our gap data, which is9 a color chart; right?

10 Q. Yes.11 A. Or the, I forget what figure number12 it was, but was it figure 56 or something?13 Q. In your report?14 A. Yes. 55. We also keyed in to15 figure 55 for the 1956 configurations.16 Q. One second. Figure 55 is a color17 map.

18 A. Correct.19 Q. That was a Baras color map?20 A. Correct.21 Q. Now, was this based on the chart22 that you just described or the listing of the23 types? Is there a document that has the24 listing of the land types that you're25 referring to?

Page 43

1 A. If I am not mistaken, I believe it's2 in the report here. I would have to find it3 for you.

4 Okay. This is all described on5 page 11 and page 12 of the report. And so,6 for example, on page 12, within these marshy7 areas, it describes that freshwater marsh is8 assumed to be 1.5 feet above NAVD-88,9 2004.65. Non-fresh marsh is about 1.1 foot

10 above the geoid or above the NAVD-88 2004.65.11 Swamp is about 2 and a half feet.12 Q. I know that it's described. I was13 wondering whether there was a chart that you14 were relying on in the description you have --15 A. These were the numbers that were16 given to us.

17 Q. By Baras, but there is no document,18 or is there a document that he gave it to you19 on?20 A. I'd have to sort of look back and21 see.22 Q. Because in figure 55 when you look 23 at Baras in your references, it says that it's24 a personal communication that was the basis of 25 the understanding.

Page 44

1 A. Right. There's no -- I don't think 2 there was a published document. There was3 information that was transferred from him.4 Q. Okay.

5 A. And he does have data to back that6 up where he saw that.7 Q. But he just told it to you?8 A. Right.9 Q. Okay.

10 A. He's the ecologist, an expert in11 these kinds of things.12 Q. Okay. And then with regard to -- So13 that was a topographical -- Was that for the14 land elevations, or was that for the15 wetlands?16 A. Could you please clarify?17 Q. Well, when did he give you the chart

18 that is -- Did he ever give you the chart that19 was part of his report?20 A. He gave us the chart in figure 55.21 Q. Oh, okay. That's the only chart22 that you used, figure 55?23 A. That's what we key in to, yes.24 Q. Okay?25 A. And that, of course, just for

Page 45

1 clarification, that's the zone of influence2 where we change things.3 Q. Okay. And that was based on

4 communications that -- Selecting your zone of 5 influence was based on communications you had6 with -- I can't remember the name now -- Rich7 and Dunbar?8 A. That's right.9 Q. And those are also personal

10 communications? They weren't based on11 documentation?12 A. That's correct.13 Q. Okay. Now, when you calculated the14 Mannings coefficients for the land -- Turning15 your attention to page 89 -- 7 and 8- -- 8816 and 89, --

17 A. Uh-huh (affirmatively).18 Q. -- and can we pick a map that we can19 look at where the elevations have been20 applied? Let's say you did H-3. Let's try --21 Where is it? Yesterday you referred to H-3.22 Figure number 20 on page 101. Well, first,23 just looking at table 3 Mannings --24 A. Between -- I'm sorry, are we talking25 about surface elevations or Manning ends now?

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Page 46

1 Q. Well, figure 20 is Manning ends.2 A. Yes. Okay.3 Q. Isn't that what it says, H-3 model4 Manning ends?

5 A. Yes.6 Q. Bottom friction values?7 A. Yeah.8 Q. So we have now got table 2 and table9 3 from page 88 and 89 and we're looking at the

10 figure 20 on page 101. And first in11 calculating your table 3 Manning end values12 for 1956 land use calculation, you have a13 chart -- a column called "Type". Would that14 type be a number equivalent to the L.A. gap15 class column in table 2?16 A. Right. Yeah.17 Q. Okay.

18 A. But like I said, table 3 in this19 report is incorrect.20 Q. I know. We'll point out -- We'll go21 to exactly where you had the -- where there22 was typos and we'll correct those. Is that --23 But those type numbers are not incorrect.24 Correct? You do not identify --25 A. That, I would have to double-check

Page 47

1 based on the information I have. So we2 actually got types descriptions and then we3 went ahead and assigned Manning ends to

4 those. Okay? And then the color, in the5 information they sent us, -- Sorry, I can't6 see with my reading glasses. So they actually7 provided a type. Right? Because all of these8 different classifications, of course, rely on9 that. And then they described what the color

10 of the pixel is.11 Q. Right.12 A. So that's, of course, what we do,13 what we then analyze for what we go in and14 look at the pixels. And then what we do is we15 add in a Manning end, common Manning ends.16 Q. In your calculation, though, where

17 you have fresh marsh, you have type 3 to the18 -- in the first column and then you have19 "equivalent gap" column --20 A. Right.21 Q. -- that says "type 1 fresh marsh"?22 A. Right. That is correct.23 Q. So would you be then looking at24 table 2 and characterizing fresh marsh based25 on the Manning end coefficient of Louisiana

Page 48

1 gap class 1 or class 3?2 A. Class 1.3 Q. Okay.4 A. Yeah.

5 Q. So that would be 50.055 based on6 chart 88?7 A. Yeah. Yeah.8 Q. Okay. And the next one would be9 non-fresh marsh, and you have got a type 3/ 4

10 brackish and saline marsh as your equivalent11 gap. Is that correct?12 A. Yes.13 Q. So then we would be looking at table14 2 and you would want something in between15 brackish marsh and saline marsh?16 A. Right. And so again, so I am -- I17 need to check that particular number --

18 Q. Okay.19 A. -- and see if it makes sense.20 Q. Just for the record, on chart 88,21 brackish marsh is .045 and saline marsh is22 marked as .035. So what you would have wanted23 to do in your "Manning ends" column would be24 have something more like .40?25 A. .04.

Page 49

1 Q. .04. I'm sorry.2 A. Yeah. And if in fact we did use3 .05, then we would have over-estimated that.

4 Q. Okay.5 A. But let's see.6 Q. I just want to go through it for the7 record so that then we'll move on to how it8 was used.9 A. Okay.

10 Q. I just want to make sure it's clear11 how to read it, though.12 A. Sure. But, you know, we can13 actually probably just figure this out right14 now.15 Q. Well, please, --16 A. Okay.

17 Q. -- I want to do that.18 MR. SMITH:19 Wait a minute. No, you please.20 Please. Please.21 MS. GILBERT:22 No, no, no. Wait. Wait. I have23 a question pending.24 MR. SMITH:25 Please.

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Page 50

1 MS. GILBERT:2 I have a question pending and I3 really want to just --4 MR. SMITH:

5 Then let him answer. Don't6 interrupt him, Elisa.7 MS. GILBERT:8 But he said he wants to do it9 right now, and I will do it next.

10 I'll do it in just a second, Robin.11 MR. SMITH:12 Elisa, listen, the way a13 deposition works, you ask a question14 and he gets to answer.15 MS. GILBERT:16 He answered. Right. But he17 answers the question.

18 MR. SMITH:19 Don't interrupt him when he's20 talking.21 MS. GILBERT:22 He answers the question. I'm23 more than happy to hear him. I just24 want to hear this answer to this25 question, Robin.

Page 51

1 MR. STEVENS:2 Robin, the answer is3 non-responsive to the question.

4 MS. GILBERT:5 It's non-responsive.6 MR. SMITH:7 And you can move to strike, but8 stop interrupting the witness.9 MS. GILBERT:

10 I don't want to move to strike11 his testimony.12 MR. SMITH:13 Then stop interrupting.14 MS. GILBERT:15 I just want him to answer the16 question when we're doing that.

17 Because we're going to go through it18 all.19 MR. SMITH:20 Stop. Stop interrupting the21 witness. If he's talking, let him22 finish before you talk again.23 EXAMINATION BY MS. GILBERT:24 Q. Professor, --25 A. Yes.

Page 52

1 MR. SMITH:2 Are you finished? Did you3 finished your answer?4 THE WITNESS:

5 Well, I was just going to suggest6 that if -- if we're really focusing on7 these numbers, we could just establish8 whether that was correct or not.9 EXAMINATION BY MS. GILBERT:

10 Q. Well, can we do that? If I ask you11 a question, you answer it, and I promise to do12 that next, will you let me ask that question13 next?14 A. Absolutely. Sure.15 Q. Very good. Thank you.16 Just so for the next column, you17 have a description item "Forest" and it's type

18 5. So if you're looking at table 2, you look 19 at column "Louisiana gap class 5", and your20 wetland and forest coefficient is .140. And21 that would be what you would have wanted to22 put there?23 A. That is -- I am 100 percent certain24 that's a mistake and that's not the number we25 used.

Page 53

1 Q. Okay. But the number you would have2 wanted to use was the one in the Louisiana gap3 classification?

4 A. .14 would be --5 Q. Would be the.14. Okay. And then6 for the next row, you have "Swamp". And it's7 characterized again as type 5 wetlands8 forest. Would that have been -- You would9 have wanted to characterize that as .140

10 again?11 A. Actually, now, that's probably not12 correct. And the reason is, is that a swamp13 is somewhere between a wetland -- between a14 marsh and has some trees in it, but the15 classifications that were provided to us16 separated out trees. I.e., forests, right?

17 There were forest classifications in the18 clarifications that were given to us for the19 1956 land cover. So you would probably want20 to pick something that was in between a --21 some kind of marsh and a forest, and you would22 not necessarily apply a forest value, because,23 of course, a marsh, you have some trees here24 and there sticking out, but it's not a solid25 cover of trees like a forest.

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Page 54

1 Q. Okay.2 A. So we -- we would want to pick and3 we did pick something that was in between.4 Q. So you would have picked -- When you

5 were doing this classification you would have6 picked something in between type 5 wetlands7 forest and what? Type 4? Or type --8 A. Something like -- Something like9 maybe --

10 Q. Or a mix?11 A. Something between one of the types12 of marshes, say, and some kind of scrub shrub13 or wetland forest.14 Q. And which of these classifications15 on type 2 would you consider most closely16 characterize those, what you have just17 described?

18 A. On table 2.19 Q. On table 2. I'm sorry.20 A. Okay. Well, you know, again,21 something that would be somewhere between one22 of the marsh types and -- and one of the23 forest types. I believe what we did was that24 we actually picked wetland shrub scrub25 deciduous, type 12, as being something that

Page 55

1 might more closely describe the frictional2 resistance that occurred in the marsh.3 Q. In a swamp?

4 A. Sorry, in a swamp, yes.5 Q. So you characterized 16, Louisiana6 gap characterization 16 as swamp?7 A. In table 2 you mean?8 Q. Yes. From the Louisiana gap class,9 table 2, you have got --

10 A. Oh, no. More something like wetland11 scrub shrub, type 12, L.A. gap class 12.12 Q. Okay. So .60?13 A. It's .06.14 Q. .06. I'm sorry. That's what you15 would have had for swamp.16 A. Yeah.

17 Q. Are there trees in swamps?18 A. There are some trees in swamps.19 Q. Okay.20 A. But it's not a forest.21 Q. Okay. Now, but it's not -- What22 would be a shrub or -- I mean, is a shrub a23 tree or is a scrub a tree?24 A. Well, shrubs and scrubs are probably25 small woody-like trees.

Page 56

1 Q. And was this part of what Mr. Baras2 suggested, Dr. Baras suggested that you3 characterize swamp as? Or how did you come to4 the conclusion that characterizing swamp for

5 the purposes of your Louisiana land6 classification in 1956 would be more like7 shrub and scrub than forest?8 A. I would have to check with John9 Atkinson on that decision. We did discuss it

10 and then did come to the conclusion that11 something in between the marshes and the12 forest and something like a shrub scrub would13 be -- would be the best way to go on that.14 Q. But it was just -- it was an15 internal communication?16 A. It was an internal communication.17 Q. Okay. And looking at his map --

18 looking at Dr. Barris' map would reflect that19 there was something less than trees in the20 area that was characterized as swamp?21 A. Well, you can see in figure 55 that22 I believe the -- I think -- I don't -- We23 don't have it in the caption, but I believe24 some of the green is forested.25 Q. So it's not reflected in your

Page 57

1 characterization, but green in your chart in2 figure 55 by your recollection would be3 forest?

4 A. By my recollection. And the other5 thing is that almost all of this stuff that6 we're talking about, the swamp that we're7 talking about, is interior to the drainage8 system. To the polder. And, of course, our9 intense focus was exterior to the -- to the

10 polders.11 Q. But the objective is to characterize12 the area, --13 A. Yeah.14 Q. -- accurately characterize the area?15 A. That's correct.16 Q. And it does matter what's on the

17 outside as well as what's on the inside of the18 polders for the purposes of determining how19 the water flows?20 A. Well, the water doesn't -- for our21 calculations, with the exception of case 4,22 the water doesn't flow back from the polder23 into the external drainage system. It24 basically tops the levees, for example, the25 St. Bernard polder, right? And gets pulled

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Page 58

1 out of the -- of the exterior -- exterior2 system into the interior system, but the3 levees, we don't breach them, we don't have4 wave overtopping, and we don't allow that

5 water to flow back because it simply can't.6 It never gets high enough. And so in all the7 cases except for case 4, what we put interior8 to the drainage system would not make a9 difference. So inside the St. Bernard polder

10 would not make a substantial difference to11 what happens. It would make no difference, in12 fact, to what happens exterior to the system.13 Q. Okay. Moving on to the next one,14 agriculture pasture would then be15 characterized as type 18, agriculture. In16 your table 3 it has .140.17 A. Right.

18 Q. And 18 on the Mannings end table 219 is .040.20 A. Right. And you can see that21 obviously agricultural pasture are not22 reflected by .04 in table 2. And it looks23 like it has more of a forested value there.24 Wetland deciduous forest.25 Q. You have .1 --

Page 59

1 MS. GILBERT:2 Could you -- Can you read back 3 that? I'm sorry. One second.

4 EXAMINATION BY MS. GILBERT:5 Q. So for agricultural pasture you6 allocated .140? That was not an error?7 A. That's an error.8 Q. Oh, okay.9 A. I said that it should be more like

10 .04.11 Q. Right. According to the Mannings12 table.13 A. Table 2, yeah.14 Q. Table 2. Okay. And the next row is15 "Developed, Urban developed type 19", and16 your chart has that at a Mannings of 1 --

17 .160. And according to the Manning18 classification, urban vegetated areas, .120.19 A. Right. But, of course, urban --20 vegetated urban might be different from21 concentrated urban. So there may be some22 differences in how that classification was. I23 would have to check what we actually used.24 Q. Okay. And for water, type 23, you25 -- it looks like you picked the same

Page 60

1 classification.2 A. Uh-huh (affirmatively).3 Q. All right. Now, moving over to just4 how -- Now, did you include the central

5 wetlands unit in your run, in H-4?6 A. Well, we moved the Chalmette -- we7 removed the Chalmette levee and we then raised8 the 40 Arpent levee. So the central wetlands9 would have been part of the -- those

10 calculations.11 Q. With regard to the definition of 12 swamp that you characterized in your -- in our13 discussion just now, did you rely on Baras at14 all to determine what the definition of swamp15 would be?16 A. I believe that, and I would have to17 check on this, but that John Atkinson probably

18 had discussions with John Baras on that. But19 I can't say that. I would have to check with20 him.21 Q. And would John Atkinson or John22 Barris' opinion on what characterizes swamp be23 more accurate?24 A. I would say that probably John25 Barris'.

Page 61

1 Q. Okay.2 A. So it -- But the -- the -- where it3 really mattered -- would have any kind of

4 influence would be case H-4, but there, in and5 of itself, because it's so close into the6 system, there are a number of fluid mechanics7 reasons that might not play that large of a8 role.9 Q. Understood. In appreciating what

10 was done here, whether it plays a large role11 statistically or scientifically, it would be a12 different number if Mr. -- if Dr. Baras had13 characterized the swamps as something closer14 to a forest or a wetland forest. That would15 be -- The impact on the flow would be, or the16 Mannings efficient is that it would have a

17 greater friction than if it was characterized18 as -- what was it that you guys had just19 described, --20 A. Scrub shrub.21 Q. Right. Is that correct?22 A. Would you like me to address the23 impact on the flow or the impact on the24 Manning end?25 Q. The Manning end.

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Page 62

1 A. Okay. So -- And what is --2 Q. My question was, if Dr. Baras3 characterized swamp as something closer to4 wetland forest type 5 and you have just

5 defined it as something closer to wetlands6 scrub shrub, --7 A. Yes.8 Q. -- the impact on the coefficient9 friction would be that shrub scrub would have

10 a lower coefficient of friction than forest;11 correct?12 A. Correct.13 Q. So it would have -- it would create14 more friction and more of an obstruction if it15 was forest than if it was shrub, scrub shrub?16 A. So it would create more friction,17 but may I just address the impact on the

18 actual calculations that we do?19 Q. Once we get to that H-4, unless -- I20 understand that when you move it and the21 polders and your results are different and22 that the significance is different, but I just23 want to get the fundamentals down.24 A. Okay. So we are going to discuss25 then how much of a potential impact that would

Page 63

1 have -- could have in my opinion in the2 calculation for case H-4.3 Q. Yes.

4 A. Which is really the only case that5 might be impacted by -- by any potential6 differences of opinion in what the Manning end7 should be there.8 Q. Okay. Yes. We'll go to it. And9 actually, if you want to do that right now,

10 you can do that right now for this, for H-4 on11 this particular -- assuming for the sake of 12 argument that you have reduced the Manning13 coefficient in the areas of what was14 characterized as swamp in the Baras maps, what15 effect, if any, would that have on your16 conclusions as they have been presented if it

17 was incorrect?18 A. Okay. So you notice that the area19 where -- which is colored light blue is very20 close to the actual levee system. Right?21 Q. Yes.22 A. And so --23 Q. Do you want to refer to a specific24 figure for the record?25 A. Let's say figure number 20.

Page 64

1 Q. Okay.2 A. And again, the way this -- Remember,3 the winds are very much from the4 east-northeast blowing towards that levee.

5 And what happens is that those winds, of 6 course, then grab that water and push it up7 and it gets stopped by the levee. The closer8 you get to the levee, the slower the flow9 goes. Right? At the levee, in fact, it's

10 stopped. It can't go any further. That's a11 physical obstruction stopping that flow. A12 little bit of overflow maybe, but not massive13 amounts. At any depth. Obviously in the14 crest of the levee there is a very fast flow.15 But -- So the -- the -- what we have in these16 types of situations is that the predominant17 balance is between the friction and the

18 surface gradient. That's the balance. So as19 you get close in this particular storm to the20 levee system. So that means that there's not21 much flow. Well, the friction depends on22 flow. You can't develop a frictional force if 23 you don't have flow. Just like we talked24 about the example of one of us tripping and25 skidding on this carpet and feeling that

Page 65

1 frictional resistance. Right? Well, that2 frictional resistance is only when there's3 relative motion between us and the carpet. So

4 that the closer you get, the less motion you5 have, the less the frictional force and the6 less the influence on the overall7 conservational momentum balance of that8 frictional force. So -- So ultimately I think 9 the results would be very, very similar for

10 case H-4.11 Now, you change the friction way12 the heck out, much further away from the levee13 system, then yeah, then you're going to --14 you're going to have rapid flow bringing water15 into the region and that's going to --16 obviously because you have got to get it all

17 the way over there, that's going to have a18 much more significant impact.19 Q. Okay. Just going through the charts20 again, turning your attention to figure 61,21 page 125, and 63, page 126, I am just looking22 at your meter --23 A. Figure 61 you said?24 Q. Figure 61, which is a detail of the25 SL-15 domain with bathymetry and topography.

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1 And that's on page 125. And figure 63, which2 is on page 126.3 A. Uh-huh (affirmatively).4 Q. I am a little confused reading your

5 scale in relation to the actual pictures. You6 have a kind of a wide view and then a close-up7 view of what appears to be the same thing.8 One being, you know, closer to the Lake9 Borgne, Lake Pontchartrain and one covering

10 the entire Gulf.11 A. Yeah.12 Q. And it appears to me that based on13 the scaling, you've got greater elevations in14 the blue; and negative elevations in the red15 section.16 A. Uh-huh (affirmatively).17 Q. And how -- is this a base -- the

18 water level, the bottom of the water that19 you're measuring or --20 A. So let's see. Does that match with21 the earlier plots? Actually, in the model,22 the -- Okay. Sorry. We transposed those in23 the model. We actually have depths as24 positive and we have --25 Q. Okay.

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1 A. -- what's sticking out of the water2 as negative. So those should have gotten3 transposed.

4 Q. So that's an error? That's just an5 error that they're marked as negative 15 and6 --7 A. It's actually an inconsistency.8 Because the model has actually has depth9 numbers, Z numbers, as positive down and

10 negative up.11 Q. So it didn't get transposed on these12 particular --13 A. It didn't get transposed when we14 made the plot to be consistent with what15 people normally think, and that's below the16 geoid.

17 Q. Okay. I understand.18 A. But the actual numbers that go into19 the model are in fact consistent with this20 figure.21 Q. It's just upside down, the coloring,22 the color scheme?23 A. Well, it's the -- we should have24 minuses on top and pluses on the bottom.25 Q. I see. Okay.

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1 A. But it's not a error in the2 calculation. It's just a --3 Q. Okay. I understand. I was just4 trying to figure out how that was higher and

5 lower and whether I was reading it6 incorrectly.7 A. It would be an inverted world,8 wouldn't it?9 Q. Well, I was thinking that we were

10 missing -- that we were trying to talk about11 low is -- the depth of the water as opposed to12 the height of the land.13 Okay. Let's see if we can get14 right into page 1 --15 A. Actually, the calculations aren't16 done in lats and longs and then, of course, we17 also do them in meters in terms of verticals,

18 and everything always has to be converted to19 whatever the, you know, the reference is.20 VIDEO OPERATOR:21 Going off the record, it's22 10:37.23 (Recess.)24 VIDEO OPERATOR:25 Returning to the record, it's

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1 10:41.2 EXAMINATION BY MS. GILBERT:3 Q. Let's, if you don't mind, let's turn

4 to page 44 of your report. Actually, page 405 of your report where you -- In page 40 of your6 report you describe wave radiation stress7 forcing.8 A. Yes.9 Q. Now, is that in any way affected by

10 the half plane or the full plane models that11 were performed? The half plane models that12 were performed for IPET and the full plane13 models that were performed for the close area14 of Lake Borgne?15 A. So the -- the half plane and the16 full plane models actually compute the wave

17 field. That wave field is then used to18 computed wave radiation stresses. As wave19 radiation stresses are taken into the ADCIRC20 model and they are the ones that compute the21 surface water elevations.22 Q. Say again?23 A. Or they influence the surface water24 elevations.25 Q. Do they compute the wave on top of

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1 the surface water elevations or do they just2 the still water height?3 A. Which one? The ADCIRC or --4 Q. The wave radiation stress forces --

5 forcing that you're calculating.6 A. Okay. So let me provide a little7 bit of clarification there. So the waves,8 when we transform, they actually put momentum9 into the water column. All right? And so the

10 example again is when that wave breaks, it11 trips it, then pushes the water surface. So12 that's what's happening. And so in fact then13 the action of the waves, when they break or14 when they in fact -- even when they grow is to15 affect the water surface elevation. So the16 still water surface elevation is in fact17 affected somewhere between a foot and a half

18 and 3 feet by the wave action.19 Q. And in the calculation of the still20 -- the wave radiation stress forcing,21 yesterday you described that you'd take the22 long range waves from the Gulf and then you23 calculate a narrower section of more immediate24 waves or surge in the vicinity of the MRGO25 area. We were talking about the half plane

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1 and the full plane analysis of the range of 2 the boundaries that were examined versus the3 -- for the Gulf surges. Am I not making my

4 -- My question is not correct?5 A. Well, I don't think we talked about6 a half plane and full plane yesterday, did7 we?8 Q. I don't know whether we did. Okay.9 When you're doing your calculation of the

10 boundaries, how was that calculated?11 A. Okay. So it's a -- actually, a12 sequence of nested models. So we actually13 take the WAM model, which is a Gulf-wide model14 that actually is used -- so there's again the15 code and the model. But the WAM code computes16 deep ocean waves.

17 Q. Is this reflected on figure 57 of 18 your report, page 122?19 A. Yes, it is.20 Q. Okay.21 A. So there's --22 Q. The WAM is a bigger boundary. It's23 the entire Gulf?24 A. And then the STWAVE is the more25 localized domain.

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1 Q. And do you use the same parameters2 for analyzing the wave productivity or the3 wave height for WAM as you do at the STWAVE4 closer --

5 A. Well, --6 Q. -- nested grids?7 A. Well, they're different models. WAM8 is a deep ocean wave model. And STWAVE is a9 near shore wave model. And in terms of

10 exactly what parameters get used for those two11 models, you'd have to ask Jane Smith and Bob12 Jensen.13 Q. Bob?14 A. Jensen, J E N S E N.15 Q. Do you know if they used a full16 plane model for the STWAVE calculations?17 A. The models that were used here were

18 actually three of them. Didn't use all five19 of those shown here. As reflected in the20 text, they used the southern Louisiana,21 southeastern Louisiana, the Mississippi22 Alabama models. And those were used in half 23 plane mode, but I believe that further into24 the system they used a nested -- a further25 nest, and that was a full plane model.

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1 Q. Okay. So for the STWAVE, it was a2 half plane mode. For the nested, closer to3 Lake Borgne and the area and the vicinity of

4 MRGO, it was a full plane?5 A. That was another STWAVE model that6 was further in.7 Q. And do you know what the impact of 8 -- Can you describe for the record the9 difference between a half plane, or the effect

10 of a half plane model versus a full plane11 model?12 A. Sure. A half plane model13 essentially propagates wave energy 18014 degrees, not a full 360 degrees.15 Q. Okay. So is there an effect of 16 having the further -- the larger boundary wave

17 only generating numbers for 180 degree waves?18 Will that have an effect on the interior19 analysis of the waves closer to the MRGO?20 A. Okay. May I provide an answer on21 that and use a little bit, in addition to some22 physical rationale, also draw from our Office23 of Naval Research project?24 Q. Okay.25 A. Okay. So actually, we've -- we're,

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1 as you know, as when we went through our2 projects yesterday, we have a project with3 Delft University to develop SWAN. SWAN,4 unstructured grid version of SWAN that we run

5 simultaneously with ADCIRC, are very tightly6 coupled. And we have run SWAN on the SL-157 grid simultaneous to ADCIRC. Very close, very8 tight coupling. A lot of information gets9 much more quickly transferred back and forth.

10 And, of course, SWAN is a full -- full plane11 model. Always. The unstructured grid version12 is always. And so we looked at both the wave13 action or the wave spectrum and the14 significant wave heights as well as the wave15 radiation stress-induced setup and compared it16 to the half plane STWAVE calculations.17 They're, in fact, extremely similar.

18 And there's a reason behind that.19 If you look at the evolution of waves in this20 whole area, the huge waves are generated in21 the Gulf of Mexico, up to 15 to 20 meters. We22 don't know exactly how high, because those23 waves -- those highest waves have never been24 measured. But according to most models,25 somewhere 15 to 20, even up to 25, some

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1 models.2 So those waves, when they start to3 feel the bottom and get into less deep water,

4 they start to break and they start to5 transform and they -- in the deep water. And6 that's kind of a -- somewhat of a continuous7 process, they get smaller and smaller. But8 the bottom line is, particularly in the early9 -- in the important parts of the storm, the

10 water was pushed, the waves were pushed in11 from the Gulf of Mexico and from the east.12 And so -- and they were large waves and long13 period waves, and the long period waves are14 the really important ones in terms of the15 radiation stresses. So what happens then is,16 is that the directionality is really from the

17 ocean side in terms of the waves that really18 matter.19 Q. All right.20 A. So that's -- that's -- And again, I21 am not an expert in waves, but this to me22 certainly are a good set of indicators as to23 why the SWAN, our SWAN calculations on the24 SL-15 grid give very similar wave --25 significant wave heights and wave periods to

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1 the STWAVE calculations; and in fact, they2 give very similar wave radiation stresses; and3 they give very similar wave-induced setup. So4 the portion of the water levels that are

5 affected by the wave breaking process is very6 similar.7 Q. All right. I have to read that8 answer now. I'm sorry.9 (Whereupon a discussion was held

10 off the record.)11 EXAMINATION BY MS. GILBERT:12 Q. When you're using the half plane13 models, not specifically responsive to your14 answer, but the 180 degree analysis of the15 wave, or calculation of the wave, does that16 have the effect of eliminating the return --17 the impression of returning waves? Or how do

18 you only take half a picture?19 A. Well, you have to see where the20 waves are coming from. Right? And the waves21 are predominantly coming from the ocean. And22 basically they're propagating towards land.23 Q. Right.24 A. And so in terms of where all of 25 these waves that are being propagated into the

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1 system, they are coming roughly, and that's2 why the orientation of the model kind of 3 follows the orientation of the coast line, and

4 in picture 57, that's why those waves come5 from the ocean and propagate in. Now, in Lake6 Pontchartrain, for those calculations, full7 plane model is used. Why? Because8 essentially when the wind is coming out of the9 north, they're being generated from the

10 north. When the wind is coming out of the11 south, they're being generated from the12 south. So there's a lot of shifting going on13 there, so it makes a lot of sense to -- to14 have a full plane model there. But in terms15 of the waves, the predominant waves that are16 coming in for the south-southeast, the

17 Mississippi-Alabama domains, those are coming18 in from the ocean side, so then if you take19 that line and shoot waves essentially in to20 the east or to the west or to the east or to21 the southeast or the northeast and southwest22 or east and west of the Mississippi-Alabama,23 you have pretty much got all the24 directionality covered.25 Q. Even on one where there's like a

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1 crescent or sort of a rounded edge? Like if 2 you're seeing -- if you're going into a beach,3 I can understand it not mattering. But there4 is an edge or a sort of crescent, wouldn't it

5 make a difference anyway that you're only6 looking at half model?7 A. Well, you're radiating in all of 8 those directions. Right?9 Q. Are they overlaid? You overlay this

10 data on top of each other so that when you11 actually finally calculate it, the different12 directions or the different half plane models13 are joined together?14 A. We actually determine which model to15 use where. And so, for example, here, east of 16 the Mississippi, it makes sense to use the17 southeast model. West of the Mississippi, it

18 makes sense to use the south model. So19 there's a hierarchy to those.20 Q. So where it curls or where it21 becomes a crescent in the coast line, if it's22 going -- if you're only going into one23 direction, do you lose the return waves?24 A. Well, again, if I may, if we're not25 going in one direction, right, we're not just

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1 propagating in this direction, we're2 propagating in 180 degrees. So waves can go3 in this direction, can go in this direction,

4 this direction (indicating), so there's a5 whole directionality of 180 degrees of where6 you can go, where the waves can go. So7 they're not just limited going perpendicular8 to the coast. That wouldn't make sense. So9 the waves can go in a full set of directions.

10 Q. Okay.11 A. But really, the people to speak to12 to address this would be Jane Smith and Don13 Resio. But may I just summarize our interest14 in this?15 Q. Okay.16 A. Okay. So our interest, of course,

17 is wave radiation stresses. And again, our18 results with a full plane SWAN model for19 Katrina are extremely similar in terms of wave20 radiation stresses and wave-induced setup.21 Q. Do we have the data from your SWAN22 studies included in what you have produced?23 A. No. I mean, that's Office of Naval24 Research. I'm just drawing from information25 that is being done for the Office of Naval

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1 Research.2 Q. And that was done for the Office of 3 Naval Research analyzing Katrina?4 A. Right.

5 Q. Okay.6 A. Yeah. In conjunction with our study7 that's joint with Delft University.8 Q. Okay. With Delft. Okay. On page9 42 of your report, you describe the simulation

10 performed in five computational parts or11 production steps, boundary conditions, tidal12 potential functions, wind and pressure fields,13 and the wave energy spectrum boundary14 conditions as computed by the deep water wave15 model, WAM, that we just discussed --16 A. Uh-huh (affirmatively).17 Q. -- are all required inputs into this

18 system. You then describe only four outputs19 for ADCIRC. And I am wondering if one is20 missing. You describe ADCIRC 0, ADCIRC 1, 2,21 and ADCIRC 3. And my question is, is one22 missing or is STWAVE for ADCIRC 2 a separate23 computational part that's included in the24 production?25 A. It's actually all of these steps.

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1 Right?2 Q. Uh-huh (affirmatively).3 A. So it -- in terms of when you kick

4 on certain forcing functions. And there's5 some relevance to that. Because the models6 are actually started from -- from no motion.7 And so, for example, the Mississippi River,8 the Gulf of Mexico, the Atlantic Ocean are all9 flat. And then we have to ramp up the

10 Mississippi River. So we actually ramp that11 up and start putting flows into the12 Mississippi River near Baton Rouge. And so13 what happens, of course, when you put flow in14 a river, you start to build up frictional15 resistance; and when you build up frictional16 resistance, the surface elevation is built

17 up. Well, that doesn't happen18 instantaneously. So in order to represent the19 response of the flow in the Mississippi River,20 you have to give the model a little bit of 21 time to adjust, and that's what we're doing.22 The same thing for tides. They are tidal23 forcing functions, both interior forcing24 functions, interior to the domain that are25 laterally pushing back and forth the water.

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1 In addition, there's an interaction with the2 Atlantic Ocean. And again, that is -- the3 response is not instantaneous in terms of 4 these forcing functions. It takes a while for

5 that response to settle down and get the right6 dynamics. And so we, in all of these model7 simulations, we very carefully check how long8 that takes. And so that's the basic part.9 Zero. And then some of the other parts that

10 are described, we start to add forcing11 functions.12 Q. So can you describe then the first13 step on ADCIRC 0 is to start up the flow of 14 water from the Atchafalaya --15 A. The flow of rivers, yeah.16 Q. The flow of rivers from the17 Mississippi and the Atchafalaya.

18 A. Yeah. And there's a little bit of a19 similar complexity. I don't know if you want20 me to get into that one.21 Q. Why don't we just go through the22 steps in as basic a way as you can.23 A. Okay.24 Q. Unless you think that there's some25 specific nuance that needs to be --

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1 A. All right.2 Q. So the first step is to start it up3 and run the water from the Atchafalaya and the

4 Mississippi rivers. And then you increase the5 boundary -- you set up the boundary conditions6 based on WAM at this stage.7 A. At step zero?8 Q. Well, it says the river boundary9 conditions are then switched to radiation type

10 so the downriver flow is maintained, but the11 tide surge are allowed to propagate upriver.12 A. Right.13 Q. So that's not where you start doing14 the --15 A. That's not where we start doing WAM.16 Q. You are doing STWAVE there?

17 A. No. No. No wave models at all.18 Q. Okay. Can you go through the steps19 --20 A. Okay.21 Q. -- that you do it?22 A. Okay. So the first -- Just to23 address the question you had there, we24 actually force a flow down the Mississippi25 River. But you also have to let things

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1 propagate up the Mississippi River. And these2 boundary conditions are quite complicated3 mathematical equations. And so if you just go4 ahead and say I want to have a constant flow

5 at Baton Rouge into the river, and you apply6 that boundary condition, what actually happens7 is then you propagate a surge up the river,8 let's say a five meter surge. That surge will9 actually reach Baton Rouge and then reflect

10 back. So you'd actually sit at New Orleans11 and watch your surge propagate by New Orleans,12 up to Baton Rouge and then maybe four hours13 later you would see it passing New Orleans14 again.15 Q. Oh, okay.16 A. In reality, of course, what happens17 is that surge goes past Baton Rouge and goes

18 up the Mississippi River and eventually19 attenuates, way up the Mississippi River when20 it becomes shallower. And so that's very21 unrealistic. So we have to try to capture the22 physics. And the physics says that yeah,23 things that we shoot up that river, like tides24 and storm surge, they keep on going. And so25 what the radiation boundary conditions that

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1 we're talking about there are not wave2 radiation stresses; they are boundary3 conditions that allow energy to be radiated up

4 out of the river while maintaining the flow5 that is coming from the whole Mississippi6 River system past Baton Rouge.7 Q. Okay. So that's the first step.8 A. Uh-huh (affirmatively). And then,9 in addition, there's tides. And as I

10 explained, we also have to start up those11 tides. But we can't do the river while we're12 simultaneously doing tides, because we switch13 over from a forced flux condition to a14 radiation condition that understands what kind15 of flow now has evolved and what kind of 16 conditions exist at Baton Rouge so that it

17 allows energy that's propagated into the18 river, such as tides, because tides also19 propagate into the river and certainly can go20 as far as Baton Rouge, how those tides21 propagate out. So we can't start up the tides22 until we have established how the river should23 respond for a given flow.24 Q. Okay.25 A. And so then we start up the tides

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1 after.2 Q. That's ADCIRC 1? That's the next3 step?4 A. That's ADCIRC 0 here.

5 Q. Oh, you're still at ADCIRC 0?6 Okay.7 A. Oh, yeah, I'm still at zero. So8 then we fire up the tides, and certainly9 fairly easy to do, and we allow those tides to

10 reach a dynamic equilibrium. I.e., water11 level's not constant, but if you were to do a12 harmonic decomposition of the tidal energy,13 then you would find that yeah, lo and behold,14 I had my -- I get the same tides here as here15 as here, et cetera. So you allow them to16 dynamically adjust and the system to reach its17 dynamic equilibrium. And then that, of

18 course, depends on the energy dissipation in19 the system.20 Q. Okay.21 A. So then we save off everything and22 then we're ready to fire up some winds.23 Q. So the next step is to fire up the24 winds?25 A. So we have got river and tides in

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1 zero. In ADCIRC 1 we fire up the winds.2 Q. Okay. And that's PBL you're using3 in the wind field data to insert?

4 A. Right.5 Q. That's H wind and PBL combination?6 A. It's just H wind IOKA, OWI winds.7 Q. From the start of the PBL the wind8 field is about 24 hours? You don't use PBL9 there?

10 A. Okay. I'm sorry. That's a typo.11 This is -- It's the generic procedure.12 Whatever wind model.13 Q. Oh, I see. So this is -- You didn't14 use PBL here?15 A. No, we didn't.16 Q. Okay. So that's an error. And what

17 did you use as a wind model?18 A. The H wind IOKA product.19 Q. IOKA?20 THE WITNESS:21 Jack, can you make a note on22 that? Page 43? I suppose I can't23 mark up this copy, can I?24 EXAMINATION BY MS. GILBERT:25 Q. No, because you can't keep it.

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1 A. Page 43, the top of the page.2 Q. I mean, if you want to make it --3 You'll get the transcript to review later and4 you can find it. We can put a mark on the

5 transcript. Can you mark the transcript?6 A. Take me another two days to wade7 through all of this stuff.8 Q. I know. Well, enjoy. We'll find9 all the typos together. Can you put a mark

10 there so that he can know where it is in the11 transcript?12 Okay. All right. So you'll be13 able to reflect back on that.14 Okay. So it's H wind IOKA, not15 PBL at this stage?16 A. Correct.17 Q. Okay. So you input the H wind

18 data. And then it's output to a disk. Is19 that the process? That --20 A. It's actually saved off and --21 Yeah.22 Q. In some sort of format you keep that23 information?24 A. Correct. Yes.25 Q. The next step, what happens, after

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1 you get to ADCIRC 2?2 A. We actually have to -- We -- This is3 a save point essentially where we're going to

4 restart this calculation. Now remember that5 there's a two-way communication that has to6 occur. STWAVE actually needs currents and7 water levels to operate. So then this ADCIRC8 2 actually computes the -- computes the9 response during a two-day period, and what we

10 do with that particular response is we pass11 that along to the STWAVE model. But we don't12 have STWAVE waves yet so we don't have any13 wave radiation stress-induced setup. We don't14 have any wave radiation stresses to -- in the15 ADCIRC model, so we really can't compute the16 effects of the wave. Because before we can

17 compute the waves --18 Q. You have to create them?19 A. -- you have to have the water20 levels, because, remember, the waves run on21 top of the water.22 Q. The water. Right. So again, this23 is using the same data that you got from24 ADCIRC 1. So this is again the type of 25 determination that the PBL wind pressure field

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1 is in error?2 A. Correct.3 Q. But what you mean is that now you4 have saved the ADCIRC 1 output and now you're

5 beginning to generate -- What are you trying6 to generate in ADCIRC 2?7 A. So this is a two-day portion of the8 run. Right? We have saved ourselves off 9 here. And the reason is because we can go

10 back to that point and restart the run.11 Q. Sure.12 A. Because we know what everything13 looked like, boom, we're ready to start from14 that point again. And in ADCIRC 2, what we're15 doing is, we are now proceeding two days, the16 two days that the wave model will be run, and17 we are computing water surface elevations and

18 currents so that we can pass those to STWAVE19 so that STWAVE knows what the water level and20 current environment looks like.21 Q. The water level and current22 environment.23 A. Uh-huh (affirmatively).24 Q. And you don't yet add the wind?25 A. No, these are the winds, absolutely.

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1 Q. That's what you need for the wind,2 is the water level, current, and wind?3 A. So these are rivers, tides, and

4 winds.5 Q. Okay. So that's what comes -- When6 you're done with ADCIRC 2, you have got river,7 tides, and winds together?8 A. Correct.9 Q. Okay. And what does that get output

10 to?11 A. That's gets output to STWAVE.12 Q. So now STWAVE is run. Is that the13 third stage?14 A. It's actually, looks like, the15 fourth step. Right?16 Q. No, it's -- Yes, I believe you're

17 right. So that would be the fourth stage.18 Okay. Because it's -- Okay. And now you run19 STWAVE with the river, tides, and winds?20 A. Yes.21 Q. And you get --22 A. And by the way, you'll notice that23 it's run for exactly the same time period as24 ADCIRC 2. Right? Because we have got all of 25 this.

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1 Q. You have to match it up; right?2 A. You got to match it up.3 Q. Okay. Now, I got you. ADCIRC --4 Now you have got that data. You have run

5 ADCIRC -- the winds, rivers, and tides and now6 the waves.7 A. Uh-huh (affirmatively).8 Q. And ADCIRC 3? What's the --9 A. So now you have got waves and those

10 waves are used to compute wave radiation11 stresses, and now we go back to the beginning,12 so now we have a whole wave radiation stress13 field. Right? We can use. And we go back to14 the end of ADCIRC 1 and, i.e., to A-281215 o'clock UTC.16 Q. Okay.17 A. And now we not only run the winds,

18 the tides, and the rivers, but now we also19 have the wave radiation stresses to run.20 Q. Okay.21 A. And so we add those in and then22 we're -- we basically go to the very end of 23 the run in order to allow the recession24 process to occur as well.25 Q. Okay. Where do you get the water

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1 level output, the surge level output in this2 process?3 A. Well, --

4 Q. Is that the --5 A. -- both in ADCIRC 2, for example, --6 Q. Okay. That's surge?7 A. That's surge and currents. And8 remember, those surge and currents don't9 include the wave radiation stress-induced

10 setup.11 Q. No winds. Right.12 A. And then we go, once we have that13 wave radiation stress setup, we -- wave14 radiation stresses or forces, we actually go15 back and redo those two days of calculations16 and we save off the information again.

17 Because now it includes that additional force18 that's pushing up the water from the waves.19 Q. So you have got surge and you've got20 a wave?21 A. You have got surge and wave22 radiation stress-induced setup. So water23 levels are still water levels out of ADCIRC,24 now include the push that was provided by the25 transforming waves, either growing waves,

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1 breaking waves, whatever the waves are doing.2 Q. Got it. Okay. And does it include3 velocity of the waves, of the water?4 A. Now, STWAVE, I don't -- to the best

5 of my knowledge, does look at the velocities6 of the water as well, but you would have to7 ask Jane Smith on that.8 Q. At what stage -- Jane Smith would9 know that. So you don't know which stage of

10 these five stages they would be computing11 velocity?12 A. Oh, we're computing velocity in13 actually all of the stages. We have to. But14 ADCIRC --15 Q. Outputting that data?16 A. And we are -- we are outputting it17 in ADCIRC 2 and we are outputting it in ADCIRC

18 3.19 Q. Velocity is outputted in ADCIRC 220 and 3?21 A. Yes.22 Q. And Jane Smith -- Is that the name,23 Jane Smith?24 A. Yeah.25 Q. She would know more about the

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1 details of the velocity?2 A. Well, whether she uses it in STWAVE.3 Q. Oh, okay.

4 A. I mean, I know about the velocities5 on our end, but what she uses, that's --6 that's, you know, what she --7 Q. Okay. But it's computed in your8 ADCIRC five-stage process?9 A. Oh, yeah.

10 Q. And that information is given to11 them for the STWAVE?12 A. Yes.13 Q. All right. Now, we're on page --14 We're getting to your scenarios. H-1, page15 44. Just on an aside, do you know -- Let me16 read my notes here.

17 Did you study where the flow18 velocities discharged and the surge elevations19 changed? Did you study the discharge, the20 flow velocity discharges?21 A. The flow velocity discharges of 22 what?23 Q. In the vicinity of the GIWW.24 A. We certainly have in the course of 25 numerous studies looked at the velocity of the

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1 flow throughout the domain and also we have2 looked at some of the flow fluxes. You3 haven't included that in this particular4 report.

5 Q. Did you do it for this study?6 A. We did not, to the best of my7 recollection, look at it for this study.8 Q. All right. Would you be able to9 identify that through the colors on your

10 velocity maps if you were going to try and11 determine where the surge elevation might have12 changed based on the discharges? Can you look 13 at your current contour maps and identify,14 based on the color scheme --15 A. How fast the velocities --16 Q. Yes, with the reduction. For17 example, like in the GIWW Reach 1, if you've

18 got bionic eyes like me, you could look at19 this -- And I am just trying to understand if 20 I am reading this at all right, but --21 A. Which figure are you looking at?22 Q. I am looking at 130 on page 163.23 A. Uh-huh (affirmatively).24 Q. And I -- To my eye, it looks as if 25 the water -- the color inside the GIWW Reach 1

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1 of the MRGO is lighter blue.2 A. Is darker blue you mean.3 Q. Lighter blue inside.

4 A. Where are you seeing this? Oh,5 inside the GIWW?6 Q. Yes, inside the GIWW. Not on the7 outer edges in the polders, but inside, where8 the actual flow currents are. It looks9 lighter blue. And to me, that is an increase

10 on the side -- on your color chart; right? It11 goes from 1, 2, 3, if it's lighter blue, it's12 going up.13 A. Yeah.14 Q. Okay. So you can identify that in15 there?16 A. It's not in -- It's basically the

17 velocities --18 Q. Are increasing?19 A. -- in the GIWW and IHNC appear to be20 higher than, for example, to the east of the21 New Orleans East polder or within Lake22 Pontchartrain. Right? In that particular23 area.24 Q. Yes. So that -- And what about for25 the Reach 2? Is it right -- It's a funnel

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26 (Pages 98 to 101)

Page 98

1 going into the GIWW. It's lighter blue inside2 the GIWW.3 A. Which figure are you looking at?4 Q. I'm looking at 130 and I might be --

5 If you go to the funnel --6 A. Yeah. Right -- Where are you7 looking?8 Q. Right where it's darker blue.9 A. Do you mind if I come and look?

10 Q. You can come look at my picture.11 A. All right. We're still on the same12 page here.13 Q. I am looking at this and I see the14 funnel is a darker blue which I would15 characterize as 1 --16 A. Right.17 Q. -- and then when it gets into the

18 channel it's turning --19 A. Yeah.20 Q. -- lighter blue 3, 4. So that means21 it's moving faster inside the channel; right?22 A. Yeah. And so there -- obviously23 water is being pushed because of the surface24 water gradient at -- between Paris Road and25 Lake Pontchartrain, and Seabrook, and you have

Page 99

1 a, as we have established in the report, a2 significant gradient. So that means that3 certainly water does want to flow --

4 Q. It's going west. Fast.5 A. -- through that channel and, you6 know, it's -- the gradient is not as large as7 in other parts of the system. So, for8 example, if you look at the Rigolets, you're9 seeing tremendously high velocities there.

10 Q. Okay. Yes. It's a bigger area,11 too. It's just that I am trying to -- You12 know, up at the Rigolets it's big. You know,13 you can see it easier.14 A. Yeah. Those velocities actually end15 up filling -- And because, of course, the16 Rigolets is a huge channel, --

17 Q. Right.18 A. -- those actually end up filling19 Lake Pontchartrain. But this is, of course,20 in response to the gradients that exist.21 Q. Because it's higher in Lake Borgne22 than it is in Lake Pontchartrain?23 A. Right.24 Q. So it's moving fast into the other25 direction.

Page 100

1 A. Right. And the predominant balance2 in the conservation momentum equation now is3 between frictional resistance and surface4 elevation gradient. And so the frictional

5 resistance is in fact incurred by the -- by6 the velocities. Right?7 Q. Right.8 A. So the velocities, the faster the9 flow goes, the more frictional resistance you

10 have and the more you start dropping the water11 levels.12 Q. Okay.13 A. And so the currents are the response14 to the surface elevation gradients that exists15 between those two points.16 Q. Uh-huh (affirmatively).17 A. And as you know, water wants to flow

18 downhill.19 Q. Right. Okay. So the -- So when20 you're talking about this frictional --21 there's a Manning end factor there with that?22 A. Absolutely. Yeah. You have to.23 Q. All right.24 A. Otherwise, you'd --25 Q. Stop?

Page 101

1 A. You'd be sucking out all of the Lake2 Pontchartrain and have a super conductive3 channel. That doesn't exist.

4 Q. Okay. Now I have lost track of my5 world. Hold on.6 In your figure, your simulation H7 -- scenario H-1 --8 A. Yes.9 (Whereupon a discussion was held

10 off the record.)11 EXAMINATION BY MS. GILBERT:12 Q. On your page 45 of your report, in13 paragraph -- at the end of your first14 paragraph -- the middle of your first15 paragraph you note "The importance of raised16 features enhanced by the presence of shallow

17 water adjacent to the raised feature. The18 shallower the water, the more effective is19 wind stress for increasing surface gradient20 and piling water against the obstructions."21 Is that concept -- Is that the concept of wave22 run-up?23 A. No.24 Q. What is that describing?25 A. That's the basic conservation of

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27 (Pages 102 to 105)

Page 102

1 momentum. And --2 Q. Okay.3 A. -- the shallower the water --4 Essentially, the wind forcing term has a one

5 over the total water column depth in front of 6 it. So, i.e., if you have a lake that's 1007 meters deep and you blow a wind stress on it,8 then you will -- and then you compare that9 same calculation or same situation with a lake

10 that's 10 meters deep, you have ten times more11 surge in the -- the situation where the --12 you've modified the depth by a factor of 10.13 So there's a one over the total water column14 in front of the wind forcing term. And so15 it's extremely important how deep that water16 is. The deeper the water, the less effective17 the wind stress is in pushing the water.

18 Q. And then in your next sentence when19 you're talking about the broad shelf and you20 get to ubiquitous shallow water bodies, is21 that how wide the water conduit is?22 A. Well, the Continental Shelf,23 remember, is the inundated part of the24 continent. So it typically goes to about 20025 meters or so. And so you have this wide swath

Page 103

1 of fairly -- particularly in the Gulf of 2 Mexico -- shallow water right next to -- right3 next to the shore like. And so that the wider

4 that is, the shallower that is, the more5 effect storm surge is in developing. So it's6 extremely important in terms of the geographic7 location. If you look at Hawaii, they don't8 get storm surge due to the wind-driven surge9 the way we do in the Gulf coast here. But

10 they get some other effects. They get11 wave-induced setup. But that's another story.12 Q. So is there an effect of having a13 narrower channel, the narrower water along the14 MRGO giving it a large wave action as a result15 of that?16 A. So you're asking about the wind

17 waves?18 Q. Well, I am asking about the shape,19 the geometry of having a narrower and20 shallower area or a narrower and deeper area21 affecting the waves.22 A. Oh. Okay. So I get you. So you're23 talking about the width of the shelf. Because24 --25 Q. Yes.

Page 104

1 A. -- here the description is -- I got2 it. So yeah, if you have a narrower shelf,3 i.e., it's not as big a distance to where the4 ocean gets really deep to where you have the

5 shore, if you reduce that width, then6 absolutely you will get less storm surge.7 Q. Okay.8 A. Wind-driven storm surge.9 Q. Okay. 7:00 o'clock UTC, what time

10 is that in normal people time?11 A. Let's see. That would be -- That's12 always a toughie, because --13 Q. Normal people don't talk in terms of 14 UTC.15 A. No. Because, you know, they don't16 have Daylight Savings time. And I guess we're17 still on Daylight Savings time and, of course,

18 you're going from London to here, so that's19 six hours. But then there's always an hour20 shift in there somewhere.21 Q. Right. We have got the -- So what22 would that be in terms of --23 A. So that would be roughly 1:00 --24 1:00 A.M. Standard time. But then it's, what,25 it's -- probably go to summertime then so I

Page 105

1 move the clock to -- spring ahead, so it's2 12:00 o'clock.3 Q. So this is 12:00?

4 A. Something like that. But I can't5 guarantee it. I have to always plug this in.6 Q. Okay. This would be -- Well, I am7 just trying to figure out what the time line8 on here -- on your -- For roughly 12:009 o'clock, assuming that that's the -- Where

10 would you have to plug that in?11 A. It's just a website for time12 conversions.13 Q. Okay. Let me just do that. 12:0014 UTC.15 MR. STEVENS:16 When in doubt, find a website.

17 MS. GILBERT:18 Right. Exactly.19 EXAMINATION BY MS. GILBERT:20 Q. August, what do we have in21 Louisiana, August?22 MR. STEVENS:23 Daylight Savings.24 MS. GILBERT:25 Central.

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28 (Pages 106 to 109)

Page 106

1 MR. STEVENS:2 CDT. Central Daylight.3 (Whereupon a discussion was held4 off the record.)

5 THE WITNESS:6 It's minus five to London from7 Eastern and then six minus to Central.8 MR. WOODCOCK:9 To Central. And then you've got

10 to subtract or add an hour for11 Daylight Savings.12 MR. SMITH:13 So it's minus five. That's what14 I am saying. It's minus five. I15 mean, I have been doing this for two16 years.17 MS. GILBERT:

18 Okay.19 MR. SMITH:20 We have been doing this stuff in21 UTC and I always subtract five to get22 local time to UTC.23 THE WITNESS:24 I think you're probably right.25 MR. SMITH:

Page 107

1 That's all I am saying. If I am2 doing it wrong, I am pretty sure --3 MS. GILBERT:

4 You have been doing it wrong.5 MR. SMITH:6 I have been doing it wrong for7 two years.8 THE WITNESS:9 You move the clock ahead.

10 (Whereupon a discussion was held11 off the record.)12 THE WITNESS:13 Robin is right, it's 2:0014 o'clock. It's spring ahead. So you15 don't subtract off an hour. You add16 an hour.

17 EXAMINATION BY MS. GILBERT:18 Q. So this is 2:00 A.M.?19 A. Yeah.20 Q. Okay.21 MS. GILBERT:22 Thank you, Robin.23 THE WITNESS:24 With 95 percent certainty.25 EXAMINATION BY MS. GILBERT:

Page 108

1 Q. With the Robin factor. The two year2 Robin factor. So it's 2:00 A.M.3 A. We just operate in UTC. It's much4 more convenient.

5 Q. Yes, for you. Everybody's talking6 the same language.7 A. All the data is in UTC, so --8 Q. Yes, we're just trying to convert it9 to what happened in our knowledge of the --

10 you know, what's going on here. And so 2:0011 A.M. And looking at figures 71, 82, 93, 104,12 and 115. Now, 71 and 82 I believe are pretty13 much a close-up and a long view of the same14 image. Right?15 A. Yes.16 Q. 92. 72 is the Gulf, the entire17 Gulf. And 8- --

18 A. So 71 is the winds. 82 is the storm19 surge elevation and wind vectors.20 Q. Right.21 A. So versus 71 has the wind iso vals,22 i.e., it indicates -- colors indicate how fast23 the wind is blowing. And 93 shows the current24 contours. And then the rest of them are the25 same thing except zoomed in a little bit.

Page 109

1 Q. So at 2:00 A.M. you have your model2 reflecting that the surge, without a wave,3 that's just the surge, is 10 feet at the

4 Bernard Chalmette protection levee; correct?5 A. Let's see. It looks like -- Yeah,6 it looks around 10 feet. By the way, this --7 Q. Looking at --8 A. This does include the wave radiation9 stress-induced setup. So, i.e., the effect of

10 any waves that are breaking in the system is11 --12 Q. But not the height of additional13 wave water?14 A. Correct. So this is still water15 levels, but it does reflect the action of the16 waves on the still water level.

17 Q. And which figure is the one that --18 is it 93 or 104 that shows it more clearly?19 One is bigger that shows the Chalmette --20 A. 104 is a better zoom-in.21 Q. Okay.22 A. Well, 104 is the wind speeds again.23 Q. But it's a zoomed in version. And24 115 is the -- Right?25 A. Yeah.

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Page 110

1 Q. Okay. And you can see that you have2 got 10. 115. And you can see that you're at3 10 feet because it's bluish green.4 A. Well, it's green, right.

5 Q. Green. Right. It's between 9 and6 11. So it's green and it's 10. Okay. Got7 it. All right. That's 7:00 o'clock.8 Now, we move on to 8:00 o'clock.9 Let's see. Have we got anything else? Well,

10 actually, you have got your water bodies, the11 velocities at the Rigolets and Chef Menteur, M12 E N T E U R, at 4 to 7 feet per second and you13 can see that in your velocity map. Okay.14 At what is now 10:00 UTC minus15 five, which would be 5:00 A.M. according to16 the Robin factor, we have got wind speeds17 moving up to 90 to 95 knots, and do we have

18 how high -- 116. And you're still green.19 Between 9:00 and 11:00ish. 10 feet surge.20 Right?21 A. Uh-huh (affirmatively).22 Q. Okay. And the INHC is now green.23 A. IHNC.24 Q. IHNC. Is green at 11 feet. All25 right. Now we're at 11:00 UTC, minus five,

Page 111

1 what is that, 6:00 A.M.? Surge continues to2 build up against St. Bernard Chalmette3 protection levee. You're up to 13 feet in

4 figure 117, and that's the orangy-yellow5 reflected in figure 117 at the levee?6 A. Looks like it.7 Q. Okay. And this is still not8 reflecting any -- the height of waves on top9 of the surge. The setup is in there creating

10 the still water height or elevating the still11 water height, but you're not reflecting any12 waves on top of that?13 A. That is correct.14 Q. Okay. The difference between the15 water level in Lake Pontchartrain and Lake16 Borgne is increasing to 7 and 8 feet, and

17 that's what's creating that gradient that we18 were talking about before; correct?19 A. The -- It's creating, driving the20 large velocities in the Rigolets and Chef 21 Menteur, that is correct, yes.22 Q. And that's also creating a gradient23 in the GIWW --24 A. Yeah, the -- that's right.25 Q. -- that we were talking about?

Page 112

1 A. Yes.2 Q. That was creating the --3 A. Yes.4 Q. Okay.

5 A. That's correct.6 Q. We're now at 12:00 UTC, 5:00 A.M.7 Is that right? No. I'm sorry. That's not8 right. That's 7:00 A.M. You've got -- Let's9 see. You're at wind speeds of 80 to 100

10 knots; winds over Lake Borgne now blowing --11 surge has started to -- surge continues to12 build up along the river levees and now13 reaches 16 feet along the St. Bernard14 Chalmette protection levee. Right? So that's15 image -- You have got 118. And this is the16 first map -- Oh, no, it's not the first map17 you have got it, but you've got -- you have

18 got your actual numbers in here of the19 contours in figure 118. Are you with me on20 that?21 A. Yeah. Actually, the other ones have22 numbers, too. Right?23 Q. Right. Yes. No, I know. It's not24 the first one. But in reading this, the25 numbers of the contours are reflected at 11

Page 113

1 feet in the green, and that's below -- that's2 in the English Turn area. And I am just3 trying to identify where we have the 16 foot

4 contour. So at the IN- -- at the Chalmette5 levee, it's a little orangeish. It doesn't6 have a number, though, in that vicinity.7 Correct?8 A. That's correct.9 Q. But that's, if I were to put a

10 number at 16, it would be the line right above11 the Chalmette levee?12 A. Well, it looks like 7 -- 16 to 17 is13 clearly orange. Right? 15 to 16 is clearly14 yellow. So you can see that the Chalmette15 Extension Levee area, there's slightly --16 Q. Orangy-yellow?

17 A. Yellow.18 Q. So it's going from 16 to 17.19 A. Right.20 Q. Right. Okay. And that's surge21 still, no -- no wave on top, wave height on22 top?23 A. Yeah.24 Q. And that's at -- we're still at 7:0025 A.M. Wind is being driven through the

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30 (Pages 114 to 117)

Page 114

1 GIWW/IHNC, Lake Pontchartrain.2 Turning to the next time interval,3 you have got 13 UTC, minus five, is 8:00 A.M.4 Figure 119. Your maximum -- Your surge is now

5 up to -- Did you identify the peak surge in6 this paragraph?7 A. I am looking at --8 Q. It doesn't look like it.9 A. 13 UTC you said?

10 Q. 13 UTC doesn't have an identified11 maximum peak surge at the Chalmette. It's12 peaking, but you don't have a number there in13 your narrative. In your image, you have got a14 contour that shows it peaking between 16 and15 17 in the figure. Or, no, --16 A. That's what it looks like about,17 yes.

18 Q. 16 to 17. Okay. So you're at 1619 and 17. So it's peaking in St. Bernard Parish20 protection levee. All right. And now, at21 1400 UTC, which is now, 14 minus 7 --22 MS. GILBERT:23 Can you do my math, Robin?24 EXAMINATION BY MS. GILBERT:25 Q. 9:00 A.M. You are now at -- The

Page 115

1 surge along the St. Bernard Chalmette2 protection levee is attenuating and water is3 accumulating from the east and overtopping the

4 CSX Railroad between Lake Borgne and Lake5 Pontchartrain. How far, when you're6 calculating this, how far up are you7 calculating the CSX Railroad? Because it's8 not listed or identified on your map, your9 contour maps. How are you reflecting this

10 overtopping at the CSX Railroad?11 A. Well, the CSX Railroad is a barrier12 that slows down the flow from coming -- going13 east to west; right? That's fully integrated14 into the model.15 Q. Where do you identify it in the16 contour map?

17 A. Well, --18 Q. If you do.19 A. -- the con- -- You would have to --20 We would have to look at the grid. And we can21 even find it in the grid.22 Q. Okay. Which one is it?23 A. I think we just have to probably24 take a look at it with a little bit more25 detail.

Page 116

1 Q. Which grid would you look at, would2 you refer me to? It would be 120 or 131?3 A. Let's see. Well, if you look at4 figure 64, it's pretty clear in there. It

5 kind of seems to blend in a little bit with6 the yellow contours. And I think that's7 happening in these contour maps of surface8 water elevation as well.9 Q. Can you repeat that? 64. Okay?

10 A. Figure 64. So you go from the New11 Orleans East polder and then you go kind of in12 a northeast direction, you can see those13 straight lines there, that's the CSX14 Railroad. The squiggly lines to the north --15 northwest of there is US 90. And then the16 broken lines that kind of stick out of the17 northeast section of the polder and kind of

18 stop, that's the I-10 bridge.19 Q. Okay. So right -- it's running20 parallel to GIWW, the CSX Railroad; right?21 A. Yeah. Well, not -- It is running22 parallel -- It's not right adjacent to it, but23 it's not far away, yeah.24 Q. It's the only thing that's running25 parallel in the brown line?

Page 117

1 A. Right.2 Q. Where is the overtopping along3 that?

4 A. Well, you can see it clearly in5 picture, let's say figure 120. Right?6 Q. Figure 120.7 A. You can see that water, you can see8 very, very significant gradients there at that9 railroad. And, of course, it was largely

10 washed out, up to about five or six feet, but11 still there's a five or six foot core that12 remained after the gravel was washed off of 13 it.14 Q. Got it.15 A. And again, that's quite a hump,16 speed bump there for the water and that

17 process is in fact slowing the flow of water18 into Lake Pontchartrain.19 Q. Okay.20 MS. GILBERT:21 Can we -- Not to interrupt the22 flow of this, which is moving along,23 can we take a quick break?24 VIDEO OPERATOR:25 Going off the record at 11:40.

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31 (Pages 118 to 121)

Page 118

1 (Recess.)2 VIDEO OPERATOR:3 Returning to the record, it's4 11:45.

5 THE WITNESS:6 Am I coming through loud and7 clear for everybody, by the way?8 EXAMINATION BY MS. GILBERT:9 Q. For me. We were at 10:00 A.M. Let

10 me just look at the record for a second to see11 where we were.12 (Whereupon a discussion was held13 off the record.)14 EXAMINATION BY MS. GILBERT:15 Q. Okay. We were at 10:00 A.M., which16 is 1500 UTC. And we've got surge propagated17 from the south in Plaquemines Parish now

18 combined with local surge generated by strong19 southerly wind. Now, what's the difference20 between surge and local surge in that21 sentence?22 A. Okay. There's local generation.23 Something is generating storm surge.24 Q. Okay.25 A. And so, for example, we saw that

Page 119

1 evolving process as water was being pushed up2 onto the shelf and due to the shallow depth,3 pushed up against the Plaquemines Parish

4 levees. And there's got to be something that5 stops surge. Right? I.e., you -- if you put6 a wall up, then that water will start building7 up. I.e., Plaquemine's levees are that wall8 and the Mississippi River banks and et9 cetera. So -- But that actually creates a

10 wave. So any time you have a perturbation in11 the water, that is a wave. So, for example,12 you throw a stone in the water and you see13 waves coming off of that, that's because you14 created a perturbation in the water and that15 water starts generating away from its source.16 The same thing happens when you pile up a

17 bunch of water in Plaquemines. Some of it18 gets in the Mississippi River, it starts19 propagating very rapidly, and that's a wave.20 That's a long wave surge wave that's21 propagated.22 Q. So that's a local wave. That's a23 local surge?24 A. No, that's a -- that's a surge that25 has --

Page 120

1 Q. It's generated locally?2 A. That's been -- that exists3 regionally and maybe guided by the winds, but4 it's propagated. In addition, you have the

5 winds pushing local water up, regional and6 local water up in wherever they're directed7 to. And so really what you -- what the8 pictures show --9 Q. What picture?

10 A. -- is that one -- If you go back a11 little bit here --12 Q. To 121?13 A. 120, 119, you see that mound of 14 water propagating north through these15 pictures.16 Q. Right.17 A. And then certainly also you see

18 those -- at the very end I think we were19 talking about 15 UTC, then finally you get20 very well directed southerly winds up against21 that coast, and those are at that point then22 effectively pushing water up against the23 coast.24 Q. Okay. In your -- I hate to go back 25 in time, but in the discussions of 9:00 A.M.,

Page 121

1 you've got the water level in Lake Borgne --2 in Lake Pontchartrain is still increasing?3 A. Yeah.

4 Q. Is there a flow still coming through5 the GIWW at this time?6 A. There's -- Of course, locally the7 water level may decrease or increase in Lake8 -- In Lake Borgne or Pontchartrain?9 Q. Nevertheless, the difference in

10 level in Lake Borgne --11 A. Which -- What UTC are we at?12 Q. We're just above where we were on13 page 50. It says "The gradient and water14 level between the northern and south side of 15 the lake increases to about 7 feet.16 Nevertheless, the difference in water level in

17 Lake Borgne and Lake Pontchartrain is still18 increasing and causing high volumes of water19 to flow into Lake Pontchartrain." Is that20 still flowing through the GIWW as well as the21 Rigolets?22 A. The predominant, if you look at23 where the major fluxes are, those fluxes, that24 -- really the movement of water, large scale25 movement of water between Lake Borgne and Lake

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32 (Pages 122 to 125)

Page 122

1 Pontchartrain is through Chef Menteur and the2 Rigolets, which is in fact also where the3 major gradients exist. Right? If you look,4 for example, in page -- in figure 121.

5 Right? You can see the yellows and oranges6 and reds in the vicinity of the Rigolets and7 Chef Menteur. Now, we never had that dramatic8 set of gradients in between the Paris Road and9 Seabrook. So the gradients are much more

10 substantial than water level differentials11 and, therefore, --12 Q. But it is still travel at this rate13 -- at this time it's still traveling in --14 along the GIWW up into Lake Pontchartrain?15 A. Well, that I -- I would have to16 check that and look at the data very carefully17 and look at -- pull up some zoom-ins. Because

18 you can see that right now the winds are over19 -- over Lake Borgne area and the golden20 triangle, they're coming out of the west. And21 so --22 Q. What time are you?23 A. On figure 121.24 Q. Oh. Sorry. I was one behind you.25 Okay. They're coming from the west.

Page 123

1 Correct.2 A. And you can see they're kind of, in3 the golden triangle, they're kind of --

4 Q. Going to the --5 A. -- yellowish, greenish and at6 Seabrook they're solid green. So that the7 water level differential probably, just, you8 know, based on very rough estimate of the9 color bars, I would have to check that, is

10 less than a foot. So there's still a little11 bit of -- probably a little bit of water being12 driven in that direction. However, the other13 thing to consider is that you also have14 currents being driven by the wind. So I15 would, in order -- before I could conclude16 which way -- certainly before the water was

17 clearly flowing in from --18 Q. Right.19 A. -- the golden triangle, but past20 Seabrook -- past Paris Road into -- past21 Seabrook, but I'd have to take a careful look 22 at that particular -- this particular point in23 time which direction it's flowing in.24 Q. Okay.25 A. But one thing that one can conclude

Page 124

1 is that the differential has gotten a lot less2 and probably the associated currents would be3 less.4 Q. Okay. Now, continuing on, 1600 UTC,

5 which is, less five, so what is it, 9:00?6 10:00 A.M.? 11:00 A.M. Yes. 11:00 A.M.7 You've got surge level in Lake Borgne up to 188 to 20 feet reflected in figure 122. Is that9 --

10 A. Uh-huh (affirmatively).11 Q. In Lake Borgne. I see it. Up in12 the right, upper right-hand. And Lake13 Pontchartrain is 12 feet. So that's still a14 huge difference. It's like six feet of 15 difference of gradient.16 A. Right. But that's in the, kind of 17 the terms of north end of Lake Borgne, more

18 towards --19 Q. Right.20 A. -- its intersection with Mississippi21 Sound. Right? So that's where -- we're22 really focusing on the water levels that are23 being driven to --24 Q. Okay.25 A. -- the water differentials across

Page 125

1 the Chef Menteur and Rigolets. Which, by the2 way, is an important mechanism in terms of 3 pumping water into Lake Pontchartrain.

4 Q. All right. At 12:00 noon you note5 that "Water is turning -- has started to turn6 toward the Gulf, causing high velocities over7 the Chandelier Islands, Mississippi Sound8 Islands, and you note the difference between9 the surge level at the Gulf side of the

10 Chandelier Islands and the Sound side. These11 islands act like a barrier resisting the high12 waters flowing from the Sound back to the open13 Gulf." Do you see that sentence going from 5114 to 52?15 A. Let's see.16 Q. It's the last sentence, the last

17 sentence in 51 on page 51. Continuing on to18 page 52.19 A. Okay. The current vectors. Yes.20 Okay.21 Q. Current vectors? Oh, yes. Yes. Do22 the barrier islands, did they act like -- did23 the islands act as a barrier resisting high24 waters flowing in at the earlier part of the25 hurricane?

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Page 126

1 A. Okay. To answer that question, I2 have to refer to LACPR studies.3 Q. Okay.4 A. And I am -- I do not recall the

5 effect of the barrier islands specifically in6 the Katrina case. Once they -- They slow the7 initial propagation of water into the system;8 however, -- And again, I would have to look at9 this very carefully and, you know, you have to

10 do sensitivity studies where you take out the11 barrier islands, you put them back in, you12 make them taller, et cetera, to carefully13 quantify this effect, but --14 Q. But you don't recall studying it for15 this?16 A. Well, we studied it for a set of 17 statistical storms.

18 Q. But not for this particular project?19 A. Not for this project, no.20 Q. Okay.21 A. But it -- it probably does not have22 that dramatic of an influence in ultimate23 surge heights, although it could have a small24 effect. But what it's particularly effective25 in is keeping the water from flowing back out

Page 127

1 into the ocean as this --2 Q. Why would that be? If it would not3 have an impact going in, but it would have an

4 impact going out?5 A. Because your -- your initial surge6 elevations are much high -- so it basically is7 a difference between the low energy end of the8 spectrum where your elevations aren't quite as9 high and then slowly retaining versus the very

10 forceful pushing that you do early on. But11 again, --12 Q. Just so I can understand what you13 just said, to repeat what you just said, is it14 because of the force of the water coming in is15 higher?16 A. You're pushing the water in very

17 quickly with waves, with winds, hurricane18 force winds obviously, and so generically when19 you look at the inundation curves and the20 rates over land or behind barrier islands,21 storm surge comes in much more quickly than it22 leaves. So these kinds of things are much23 more effective in retarding the recession24 properties when you don't have the hurricane25 winds forcing the system.

Page 128

1 Q. Do you have any -- The LACPR studies2 have data on what the effect of the barrier3 islands were on the propagation or the initial4 surge of the Katrina event?

5 A. I do not recall whether we looked6 specifically at the Katrina event. And again,7 that's -- there are lots of different storms8 being run. I'd have to look carefully at9 that.

10 Q. Okay.11 A. And, of course, it's an issue of 12 significant interest.13 Q. Why would that be?14 A. Well, in terms of some people in15 Louisiana say that you might want to increase16 the, and maintain the barrier islands, that17 are actually degrading quite rapidly, in order

18 to achieve coastal protection.19 Q. For general coastal protection20 issues, the barrier islands are considered --21 A. Yes.22 Q. Is that because they're considered23 -- Is there a hurricane protection component24 associated with the concerns to preserving the25 barrier islands?

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1 A. Well, there is really not a large2 amount of data available to ascertain that,3 and that's, what, part of what LACPR tried to

4 establish.5 Q. How high -- roughly how high were6 the barrier islands, do you know, at the time7 prior to Katrina?8 A. It depends on which one. The9 Chandeliers were already fairly low-lying.

10 Q. What would that be like, roughly?11 A. I would have look that up, but, you12 know, somewhere in the 1 to 2 to 3 foot range13 I would say.14 Q. Okay. And some of the other ones15 were higher?16 A. Some of the Mississippi Sound

17 islands, portions of them were quite high.18 Q. What would be quite high for a19 barrier island?20 A. 10 feet, say.21 Q. Oh, okay.22 A. But again, I would have to check 23 those numbers very carefully.24 Q. Okay. And the effect of a barrier25 island would be the same as the effect of like

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1 a wetland in terms of keeping the -- The2 manner in which a barrier island would prevent3 the propagation of surge would be the same4 concept as what's discussed in the heights of

5 like the wetlands and the coefficient of 6 friction that's given to the heights of the7 wetlands? Assuming that it's that same8 height?9 A. Come back again.

10 Q. The concept and the way that you11 evaluate the effectiveness of a barrier island12 to obstruct surge is the same -- still water13 height is the same concept as you consider14 when you're evaluating the wetlands heights?15 A. The wetlands height in terms of 16 ascertaining what the wetland height is, or17 just in terms of ascertaining the

18 effectiveness of the marsh? Okay. Well,19 there -- you know, certainly that is one of 20 the features that is important to evaluate,21 but it's very geographically and very22 storm-dependent. So you have to put it in23 that type context. Right? We make a point in24 the, or I make a point in the report that if 25 the wind blows long enough, particularly in

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1 this protruding delta, the water is going to2 get there. It's just, you know, -- If the3 storm passes very quickly, then perhaps you're

4 in a situation where, well, gosh, it held it5 back long enough.6 Q. Right.7 A. But if the wind blows long enough in8 any situation and, of course, how long that is9 depends on the physical characteristics of the

10 region, then the storm, et cetera, but if it11 does blow long enough the water will get12 there. So, i.e., wetlands don't necessarily13 protect you.14 Q. Unless they're really thick or15 unless they have some sort of capacity to16 delay the storm's progress?

17 A. If they have the capacity to delay18 the storm --19 Q. And the storm is moving at a rate20 that would make it delayed long enough for the21 water not to get through it?22 A. Then there's the possibility that23 there's a reduction in storm surge. However,24 in the east bank of the Mississippi River,25 certainly the -- and again, this is storm

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1 track dependent, but you have those -- those2 very persistent easterly winds and so that --3 that is a problem in terms of allowing storm4 surge to build up in this region. I.e., you

5 give that storm a lot more time to pile up6 surge.7 Q. Right. And then -- Okay. I8 understand. Moving to page 52, starting I9 guess with the continuation of 4:00 P.M., we

10 have already talked about the "conflict of the11 outflow surge being resisted by the barrier12 islands. Maximum surge levels that occurred13 during Hurricane Katrina --" Is this a14 portion of your -- is this relating15 specifically to 4:00 P.M. or are you now16 discussing maximums just in the flow of your17 dialogue?

18 A. What time are we? We were at --19 Q. The last time frame you were20 discussing in your narrative is 4:00 P.M. on21 page 52.22 A. Okay.23 Q. The next paragraph says figures 13724 to 141 show maximum surge levels that occurred25 during Hurricane Katrina --

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1 A. Uh-huh (affirmatively).2 Q. -- at various scales of interest.3 That's not responsive to the time frame?

4 That's maximum over the entire hurricane?5 A. Right. That's the event maximum6 water level.7 Q. Okay. And the event maximum water8 level shows 16 to 17 feet at the MRGO levees.9 And that's reflected --

10 A. At the Chalmette levees you mean?11 Q. Well, it says here "Adjacent to the12 levees along the MRGO, maximum computed water13 levels of 16 to 17 feet" and it doesn't say14 where.15 A. Okay.16 Q. So the question then is, if you turn

17 to figure 137 or 141, 137 is the entire Gulf 18 region, and 141 is on page 168, which makes it19 really hard -- So let's go back to 137.20 Maximum -- 16 -- Maximum computed water levels21 is 16 to 17 feet along the MRGO.22 A. Right. So that really should be the23 MRGO -- MRGO going to Chalmette levee.24 Q. That's a Reach 2 length?25 A. Reach 2, yes.

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1 Q. And you can see that in figure 137,2 because it's an orangeish-yellow along your3 elevation curve?4 A. Right. Perhaps --

5 Q. Contour?6 A. -- figure 140 would be a better one7 to kind of see that, too.8 Q. Well, figure 140. Okay. That's --9 A. A little bit different scale.

10 Q. Elevations in feet. Okay. So now,11 that line, that sort of coarse line there12 along -- has the green along the gray, is 1613 to 17 feet.14 A. Yeah.15 Q. Okay. That would be on figure --16 Hold on. 149, 141. Is that through 141? I'm17 sorry.

18 So how high are the levees at the19 -- How high are the MRGO levees that you're20 calculating when you're doing this contour21 map?22 A. I'd have to check with the data in23 terms of exactly --24 Q. Where would that data be?25 A. Well, that's right in the input

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1 files for ADCIRC.2 Q. Okay. So is it something that could3 be printed out?

4 A. Sure.5 MS. GILBERT:6 So we're going to call for the7 production of the printouts of the8 levee heights that were input for the9 ADCIRC.

10 MR. WOODCOCK:11 That's already been requested.12 MS. GILBERT:13 Yes. It's on the record. So14 it's been requested. We'll mark the15 record here for that. And I16 understand whatever has to be dealt

17 with on that. I am just going to make18 the request.19 EXAMINATION BY MS. GILBERT:20 Q. Okay. Now, according to -- all21 right. Let's see now. So you're at 16 to 1722 feet on figure 40.23 A. Figure 140?24 Q. 140. I'm sorry. All right. Now,25 you have the same -- Is the map below figure

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1 141 the exact same time frame and the exact2 same maximum image, just you have changed the3 contour, the black contour line to 3 foot4 elevations instead of 1 foot elevations?

5 A. Figure 141 to 140 you're saying?6 Q. No, those are both 3 feet. I'm7 sorry.8 A. They're the same and it's --9 Remember, it's the maximum storm surge

10 elevation.11 Q. Right. I am just trying to figure12 out the black lines versus -- Now, if you go13 to the page before that, figure 138 and 139, I14 am just trying to discern the line, the15 contours. 138, you have got your elevation16 contours at 1 foot marks.17 A. Yeah.

18 Q. And then 139, you start converting19 to 3 foot contours? That's where you got the20 black line?21 A. The black lines are 3 feet, but you22 can see that there's --23 Q. Yes. I am just asking about the24 black lines. I understand that you have got25 the different colors that are in there.

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1 A. Yeah.2 Q. And that the different colors3 reflect a variation in the contour.

4 A. Yeah. Just trying not to, you know,5 put too much black in there so you can discern6 some of the differences.7 Q. And when you're reading these maps,8 the 139, every black line would be9 corresponding to a 3; zero, 3, 6, 9, 12, 15

10 contour? Correct?11 A. That looks correct, yes.12 Q. Okay. And -- Okay. Why did you go13 from the 1 foot black lines to the 3 foot14 black lines?15 A. Well to try to -- because you can16 start to see the -- When you're getting close

17 in like this, you can see the color18 differentials quite -- quite nicely. So then19 the black lines kind of reference you and then20 you can count up contours just by looking at21 the color differentials.22 Q. Okay. When you generated these23 contour maps, did you give all of them, or how24 did the data go from you to another person on25 the team like Ebersole or Resio?

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1 A. Well, we had transferred the2 requested -- Their interest, of course was,3 for example, on the interior drainage. What4 the hydrographs along the boundaries of the

5 St. Bernard polder were. Right? So they --6 we provided them with -- with time histories7 of surface water elevation, i.e., time8 elevation, time elevation, time elevation, a9 whole list of that, along a sequence of points

10 throughout the system.11 Q. So did you give it to them in the12 color contour graph? What was the form of the13 output that you gave them?14 A. One of the main outputs that we gave15 them was the hydrographs.16 Q. The other ones that we looked at,17 the first things we looked at?

18 A. The history. I'm not sure whether19 John or Hugh gave them actual ADCIRC results20 and/or these pictures.21 VIDEO OPERATOR:22 We're now off the record. It is23 12:10.24 (Recess.)25 VIDEO OPERATOR:

Page 139

1 Returning to the record, it is2 12:13.3 EXAMINATION BY MS. GILBERT:

4 Q. Okay. And you've got the maximum at5 the MRGO Reach 1 GIWW at 14 feet. Right?6 According to -- on page 53.7 A. Uh-huh (affirmatively).8 Q. If you look at the contour map, you9 can identify that it's 14 feet on -- I guess

10 because in figure 138? Is that the right one?11 A. Well, maybe look at figure 141.12 Q. 141? Is there -- Is that a contour13 right above the brown line? Like it's a CSX14 Railroad line? In the IHNC? Is that an15 actual contour or is that something I have --16 A. IHNC? Where?

17 Q. Are we at 141?18 A. We're at figure 141 and you're19 looking in the IHNC.20 Q. IHNC, and I am trying to determine21 if in the IHNC there's a black contour mark.22 A. There's a little black contour line.23 Q. There is one? Yes?24 A. I believe that is correct, yes.25 Q. Is there another black contour line

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1 just up at the entrance to the Lake2 Pontchartrain?3 A. You know, it sure looks like it, but4 I'm not sure because I'd have to really zoom

5 in on that figure or produce another one.6 Because the thing is that that Seabrook is7 real narrow. So I am not quite sure.8 Q. Okay. So if there's a black contour9 line there, that would be 12 or -- because

10 that would be the number that would correspond11 to it? Is that how you would read it?12 A. Yes, probably.13 Q. That would be a 12 foot contour14 line?15 A. That would be more like 9 foot. At16 Seabrook you're saying?17 Q. I'm sorry, the one below it.

18 A. That would probably be 12, yeah.19 Q. That would be 12. Okay. And the20 one above it, if it is a contour line, would21 be 9. So wherever I see a black line it would22 correspond to one of the odd numbers?23 A. So you go south of that one near24 I-10. Right? And so now you're at 13. Then25 the next one is 14.

Page 141

1 Q. Wait. South of I-10. Where are you2 looking?3 A. Right over here (indicating).

4 Q. Okay. That would be 12 or --5 A. That would be 13. Because it's6 building up towards the east.7 Q. You're talking about the color, not8 the black line. But the change in color?9 A. So 12, 13, and then 14. So then in

10 that whole section there you got 14. And so11 you can certainly see that this is -- that12 most of the drop in the base case in surface13 water elevation and, therefore, most of the14 dissipation, occurred between roughly I-10 and15 Seabrook.16 Q. Okay.

17 A. Right. There's a 3 foot drop right18 in that short section. So certainly an19 indicator of the importance of all of those20 constrictions in that following channel.21 Q. Okay. Now, and that's with a 9 foot22 contour at Lake Pontchartrain which you have23 indicated. The maximum surge level is about 824 to 9 feet along the southern end and eastern25 shoreline.

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1 I guess we are done at this moment2 with the base case scenario. So if you don't3 want to go into -- If you don't want to start4 -- I'm going to start doing the systems

5 validation next, which could go for a little6 while. And if you want to break for lunch now7 and come back --8 A. It's up to you guys.9 Q. -- at a quarter to --

10 MR. SMITH:11 This is an good time for lunch,12 sure.13 MS. GILBERT:14 So we're going to start at 1:00?15 Can we start at 1:00? Or are you guys16 going to take --17 MR. SMITH:

18 What time is it now? 12:20. No,19 we're going to Palace Cafe. We will20 be back at 1:30.21 MS. GILBERT:22 1:30?23 MR. SMITH:24 I'm sorry we were so long25 yesterday. We got hung up. I don't

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1 know what happened.2 MS. GILBERT:3 All right.

4 (Whereupon a discussion was held5 off the record.)6 VIDEO OPERATOR:7 Off the record at 12:18.8 (Recess.)9 VIDEO OPERATOR:

10 Returning to the record, it is11 1:32.12 EXAMINATION BY MS. GILBERT:13 Q. Take a moment and turn to figure 13814 and 139, which we were looking at before on15 the contour maps. I think they're on pages --16 MR. WOODCOCK:

17 167.18 MS. GILBERT:19 Okay. Right.20 THE WITNESS:21 Yeah.22 EXAMINATION BY MS. GILBERT:23 Q. Now, in looking at the 1 foot24 contour elevations, if you look in the center25 of the dark red area which appears to be the

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1 eye on figure 138, would that contour be 182 feet? The circular contour?3 A. Yeah, it sure looks like it.4 Q. Okay. Now, would these two images

5 be identical runs of the same -- at the same6 time?7 A. Right.8 Q. Okay. Now, if you look at the9 figure below, the contour that I think

10 parallels that is -- it's in the yellow range,11 but wouldn't the black line suggest that it12 would be either 21 -- I mean, my question is,13 it's a different shape.14 A. Well, the contour lines run15 differently. Right?16 Q. Right.17 A. So you look at the one that is minus

18 3 to 27. The other is minus 3 to 30.19 Q. Do you see that? What I mean, the20 contour is a different shape for what should21 be I assume either 18 -- the only shape that22 should reflect 18 feet is not the same shape23 and it's not the same size. Are these -- Is24 there --25 A. I'll have to -- I'll have to look at

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1 the data.2 Q. What would be the explanation for3 that that you would be looking for?

4 A. Might be a slightly earlier run or5 something like that that was done.6 Q. Oh, these could be two different7 runs?8 A. Slightly different ones.9 Q. But different ones? They're not the

10 same run, just different contours? It could11 be two entirely different runs?12 A. Well, it could be -- it could be two13 -- Like I said, if you look at the statistics14 in general, we generally plot differences15 between previous runs.16 Q. Where would that be? Where would

17 you find that?18 A. Well, the statistics are right over19 --20 Q. The plot, the scatter plots?21 A. The scatter plots. Like 140, 145,22 et cetera.23 Q. Does that reflects different runs if 24 you're looking at it?25 A. No, those are the same runs, but you

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1 can compare those to slightly earlier runs.2 Q. Oh, so nothing in what was produced3 would reflect an explanation for the4 difference in that contour map?

5 A. I would have to go and look at6 that.7 Q. Just for my own clarity, do I have8 something in my possession that I could have9 analyzed that would have explained that or is

10 that something I need to get from you still to11 understand the difference?12 A. We need to look at the values.13 Q. I need to get that from you? That's14 information that was not produced?15 A. Yes.16 Q. Okay. And if you had done separate,17 different runs, when would the different runs

18 have been performed? Or could that have --19 could they have been from a different study?20 A. Actually, these would have been just21 from an earlier set of runs. The area of 22 detail, of course, was plotted over here for23 the DOJ runs.24 Q. Which ones over here?25 A. 139.

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1 Q. 139 is the DOJ runs?2 A. Uh-huh (affirmatively).3 Q. Okay. And what would be 138?

4 A. I would have to check back in our5 catalog and look at what -- what -- which6 particular version. Although statistically7 there should not be a large difference. And8 again -- Well, let's check very carefully9 here.

10 Q. Well, can I just ask you the next11 question? What would be among the possible12 runs that the first one could have come from,13 figure 138? You say the second one from14 figure 139 was the DOJ run. And you're sure15 of that?16 A. Oh, absolutely, yeah.

17 Q. Okay.18 A. I produced those runs.19 Q. And did you give those, the second20 run to Ebersole and --21 A. Yeah.22 Q. So everybody who analyzed data based23 on this study analyzed data based on the 139,24 figure 139 run?25 A. Correct, yes.

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1 Q. Okay. And the possibility that2 figure 138 was from a different study, what3 studies would have been the possible options?4 The IPET study?

5 A. The what?6 Q. Could it have come from IPET or one7 of the other studies?8 A. Oh, no, not IPET. These models,9 it's an SL-15 grid.

10 Q. How can you tell that?11 A. Well, just look at the -- all the12 contours.13 Q. I'm sorry?14 A. Just look at all the -- the northern15 boundary shapes and the level of detail in16 there. There's no question that that's an17 SL-15.

18 Q. Okay. That would be what you mean19 when you say the resolution is higher, an20 SL-15, that you have more definition at the21 Mississippi border?22 A. Yeah.23 Q. Okay. So this had to be an SL-1524 grid?25 A. Oh, absolutely. There's no question

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1 about that, yeah.2 Q. But it would have been coming from a3 different run of the data?

4 A. It -- Well, no, it would have just5 -- Yeah, I'll have to -- I need to go back 6 and check this.7 Q. What would be -- What would you be8 looking at when you go back and check?9 A. I'd probably be going back through

10 our catalog and checking and actually11 inquiring the data and looking at the specific12 data and looking at the slight difference in13 the max, the peak value on that.14 MR. SMITH:15 Where is this difference? I'm16 sorry. I'm not with you here.

17 THE WITNESS:18 She's looking at this19 (indicating) versus this (indicating).20 MR. SMITH:21 Right.22 EXAMINATION BY MS. GILBERT:23 Q. It's about the same shape?24 A. It's about the same -- Well, it is25 the same shape. Just slightly depressed.

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1 MR. SMITH:2 But as you pointed out, the scale3 is different.4 THE WITNESS:

5 Right.6 EXAMINATION BY MS. GILBERT:7 Q. That's not really -- That shouldn't8 make a difference. They're both 18.9 A. This is 17 and then this is 18.

10 This is 15, 16, 17, 18.11 Q. So in the system validations section12 of the report on page 53 --13 MR. SMITH:14 Where is the discrepancy? I15 don't see what the discrepancy is.16 THE WITNESS:17 Well, she's saying that this 18

18 foot area --19 MR. SMITH:20 Is not as large as that one?21 THE WITNESS:22 -- is not as large as that one.23 MR. SMITH:24 Okay.25 EXAMINATION BY MS. GILBERT:

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1 Q. And in your system validations2 section, which -- would you have been using3 the figure 139?

4 A. No, the system validation is based5 on figure 139.6 Q. Okay.7 A. And probably the catalog run would8 have been a slightly different version of the9 IHNC -- IHNC grids. I'll have to look it up

10 and can get back to you on exactly what that11 is.12 Q. Okay. Well, we'll obviously need to13 get a supplemental -- whatever the data is14 that you're relying on.15 A. And if there's any corrections16 required, we can provide those.

17 Q. And the backup data.18 Can we mark the record, the19 transcript at this point, so I can get all of 20 that?21 But the documentation, that was22 sent to Ebersole -- I mean Ebersole and Resio23 --24 A. Oh, absolutely. Yeah. And then --25 Q. -- and Faust and everybody came from

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1 139. Because the representation is that it's2 the same information. It's just that it has a3 different contour marking of 1 foot. Right?4 A. Run that by me again.

5 Q. The representation on, you know, 1386 and 139 is that it's the same picture, it's7 supposed to be, it's just the different8 elevation contours are supposed to be marked.9 3 feet versus 1 feet. That's supposed to be

10 the only difference in these two images?11 A. Correct. Well, they're slightly12 different scales also.13 Q. Well, yes. But the information on14 there is supposed to be -- it's like a15 close-up, but it's supposed to be the same16 stuff?17 A. Yeah.

18 Q. Okay. And your system validation19 was run on figure 139?20 A. Right.21 Q. Now, can I ask you a question? In22 figure 139, if you look at the area around the23 central wetlands region --24 A. Uh-huh (affirmatively).25 Q. -- and the upper -- the New Orleans

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1 East --2 A. Right.3 Q. -- and the entire -- It's all gray.

4 A. Right.5 Q. What is the explanation for why that6 entire area is gray?7 A. Well, actually because we don't put8 levee breaks in, we don't have wave9 overtopping, and we do not have the details of

10 the interior drainage system. And Steve11 Fitzgerald did that with HEC-RAS. We actually12 just blanked out the results there.13 Q. Okay. So there may have been14 coloration in that area?15 A. Oh, there's definitely coloration in16 that area. However, the results are not valid

17 there. We do not have a valid calculation18 there.19 Q. Your analysis, it's like the other20 report that we looked at where you said that21 the polders -- the drainage polders weren't22 present so the drainage calculations for the23 polders weren't present, so you passed that on24 to Fitzgerald to analyze the drainage25 calculations?

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1 A. Correct. If I may make a comment2 referencing the report, on page 54 it says3 "The ADCIRC SL-15 simulations are not4 intended to model interior polder inundation.

5 Inadequate resolution in the circulation of 6 the wave models leads to limited prediction of 7 wave-induced setup and --" Oh, okay. That's8 another sentence. But anyway, so -- but it9 says right there that we didn't -- also we

10 don't include any high water marks in our11 comparisons for the most part. A couple of 12 exceptions on the interior portions of the13 drainage system. So, for example, Steve14 Fitzgerald, in his modeling, would be15 comparing what he gets and what he -- what was16 measured compared to his model that really17 focuses on the interior drainage.

18 Q. Now, would he base his model on the19 data that you provided him?20 A. Correct. Yes.21 Q. So if you gave him figure 139, for22 example, he would then base his analysis of 23 drainage on that original surge elevations?24 A. Well, we can't give him figure 13925 because he has to know the time history of the

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1 water elevations along the boundaries of the2 polder.3 Q. Okay.

4 A. So we actually have a whole sequence5 of -- of data points where we have hydrographs6 along the barriers and then he uses those to7 compute what the overtopping -- overtopping8 rates are. So yeah.9 Q. But it would be the data that was

10 generated with his run from 139?11 A. Correct. Yeah. Yeah.12 Q. Okay. And were those -- Do you know13 if that data run was produced at all? The14 data run that you furnished to Steve15 Fitzgerald -- Is it Steve Fitzgerald?16 A. Yeah.

17 Q. Was produced? Do you know if that18 was produced?19 A. What do you mean if the data run was20 produced?21 Q. If the actual data had been provided22 in the litigation, or was it just a report23 that came with it?24 A. Oh, no. No. You mean we provided25 -- within the framework of the litigation,

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1 the hydrographs. Right? Along the barriers.2 And I believe the routing was to Bruce3 Ebersole, who made some adjustments to make it4 match the data better. And then that was

5 provided to Steve Fitzgerald to do the6 interior drainage models.7 Q. Is that why Ebersole -- Well,8 withdrawn. If you look at figure 138, the9 contour line above the levees of the MRGO

10 Reach 2 levee, do you see the small contour11 line there?12 A. Uh-huh (affirmatively).13 Q. And consistently with your14 description, reflects in that contour line and15 in that contour map that the water level at16 the MRGO reach 2 is 16 to 17 feet. Correct?17 A. Yeah. Yeah.

18 Q. And on your figure 139, the contour19 line along the MRGO Reach 2 levee reflects20 that the surge elevation at the maximum time21 is only 15 feet. Do you see that?22 A. I don't think that's correct. I'd23 have to -- Again, I'd have to query the data24 to be exact, because there's a bunch of local25 minimum and maximum there.

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1 Q. Well, you have a black line there2 right along the MRGO levee on Reach 2.3 A. I think so.

4 Q. In figure 139?5 A. 15, 16 -- Because it's orange over6 in here (indicating), which would indicate --7 Q. When you're saying "over in here",8 you mean 138?9 A. 138. And if you look at that,

10 that's kind of 17 to 18, somewhere in that11 range.12 Q. That's correct. In 138.13 A. Right.14 Q. Now, if you look at 139, it's green15 and it's got a contour line next to it that16 says 15. That is a 15 -- It matches a 15

17 contour line.18 A. Yeah, can we check some of the19 hydrographs?20 Q. Well, can we answer this question21 first and then we'll move on to the22 hydrographs?23 A. Sure. Actually, to be honest, in24 order to make sure that what the values is --25 what the exact value is, I would go back to

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1 the actual data in maximum values and query2 that.3 Q. Well, in your narrative you said the4 maximum height was 16 to 17 feet, but this

5 contour reflects 15 feet as a maximum. That's6 why I am asking. I mean, just looking at this7 map, which is all that was provided to us, --8 A. Right. Right.9 Q. -- as well as your narrative in

10 comparison to figure 138, it's inconsistent11 with the conclusion that you describe in your12 narrative and it does -- and it reflects a 1513 foot surge elevation at the maximum water14 surface elevation for the MRGO Reach 2.15 MR. SMITH:16 Object to the form.17 THE WITNESS:

18 Well, to be honest, again, in19 order to ascertain the exact value I'd20 have to check and cross-check on the21 data and --22 EXAMINATION BY MS. GILBERT:23 Q. Is the data in the report?24 A. Excuse me? No, not the data in the25 report. The actual data that generated the

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1 plots.2 Q. Okay. But in these reports, is that3 picture, if you're just looking at that

4 picture, that picture reflects the contour5 line at 15?6 A. Yeah. Let me, if I may, just check 7 back in what values are in the report here.8 So 16 to 17.9 Yeah. I'll have to double-check

10 on those values.11 Q. I appreciate you'll have to check 12 the accuracy of it, but is that -- am I13 reading that map correctly, is what I am14 trying to find out, am I reading it correctly15 that that contour line is at the 15 mark, 1516 foot mark and it may be incorrect and you can

17 tell me that later and we'll go into that18 another day or at a different time, --19 A. Okay.20 Q. -- did that green line --21 A. Very -- Just looking at this, it22 would appear that way. However, I need to23 check the data.24 Q. Understood. Now, I have another25 question. If you look at the contour map

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1 below the line below the MRGO there, the black 2 line, I do not know how exactly to describe3 this, but -- Hang on. If you go right into4 the English Turn section of the contour maps,

5 right below, where you have got a black 6 delineation, --7 A. Yeah.8 Q. -- in the figure 139, below the9 ridge -- You know the ridge I am talking

10 about? The brown elevation?11 A. Right. The LaLoutre Ridge.12 Q. The LaLoutre Ridge. The elevation13 is to the east of LaLoutre Ridge in that14 illustration; correct?15 A. Yes.16 Q. And that's also a 15 foot contour17 line, according to this map?

18 A. Uh-huh (affirmatively).19 Q. Okay. So now if you look at the20 contour map above it, on the 1 foot contours,21 the ridge, the marked ridge is on the other22 side of LaLoutre Ridge.23 A. So --24 Q. The marked contour would be on the25 other side of -- for 15.

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1 A. So, for example, okay, so we're2 looking at the 15 foot contour over here and3 counting down --

4 Q. When you say "over here", you have5 to say the --6 A. It's south -- In the Caernarvon7 marsh.8 Q. That's figure 139?9 A. Figure 139. So we go back, 15, 14,

10 13, 12, and roughly 11. So that's pretty --11 looks like there's an 11 foot contour right12 over in figure 138 as well.13 Q. Wait. Wait. Wait. Okay. The 1114 foot contour? I am just -- The black ones15 would be 11 and, wait, would it be -- in 13916 you have a black contour at 12 feet and a

17 black contour at 15 feet? Correct?18 A. 15, right, and then 14, 13, 12. And19 then the next contour is 11.20 Q. Okay.21 A. So it looks like that matches up22 with the 11.23 Q. Well, where would the 11 one -- You24 don't have marked, black marked contours on25 11.

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1 A. Oh, 15, 14, right, 13 and then 12 as2 you're progressing.3 Q. Okay. So the black line is 12.4 A. And then you got 11 foot and then

5 you look in figure 138 and you have the 116 foot contour right over there as well.7 Q. Okay. Now, going back to the 158 foot contour line in figure 139, --9 A. Yeah.

10 Q. -- I may be describing the wrong11 thing, but you know that little squiggly line12 coming right into the green field going south13 in the 15 foot contour line? What is it?14 It's an elevation, a brown elevation, raised15 feature. Can I just show you on your map,16 sir?17 A. Sure.

18 Q. I'm talking about this little --19 this line here (indicating).20 A. Okay.21 Q. What is that? What do you call it?22 How would you identify it?23 A. It's a raised feature.24 Q. Can we call it something? Is it a25 specific ridge of some kind or --

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1 A. It's probably a little extension of 2 the LaLoutre Ridge and might be a little road3 that goes down there, something like that.

4 Q. Okay.5 A. I forgot exactly what it is.6 Q. So the contour line that goes to the7 east of that, --8 A. Yeah.9 Q. -- that's a 15 foot contour line;

10 correct?11 A. Yes.12 Q. Okay. And if you look -- and so13 let's see how we can say this for the record.14 A. And so if you look over here, that15 looks like the 15 foot contour line as well.16 Right?

17 Q. Actually, it seems to me that it's18 on the other side of that ridge. That's why I19 was -- If you calculate out where that20 offshoot of LaLoutre -- It's LaLoutre?21 A. Okay. So there's a slight22 difference there, yeah.23 Q. So the 15 is now on the other side24 of the contour.25 A. Yeah.

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1 Q. How would that affect the results of 2 Ebersole and Fitzgerald?3 A. Well, basically the bottom line is4 we took the results associated with 139 and

5 those are all the results that were passed6 along, or the results that produced the run7 which is H-1 that --8 Q. And that's what you gave to9 everybody to work with?

10 A. That's right.11 Q. Doesn't that give you a lower12 elevation at the MRGO Reach 2?13 A. I have to again check that. As I14 have described before, this narrative really15 was pulled from a previous document and there16 has been some evolution in the actual -- some17 of the details of the feature as the model has

18 evolved. So what H-1 has would be slightly19 different from this. But only slightly.20 Q. Okay. But we're talking about a21 difference between a foot or two on Reach 2 on22 the MRGO Reach 2.23 A. And so whatever I gave to Ebersole24 would have been right in -- right from figure25 139.

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1 Q. Which is -- Which reflects 2 feet,2 approximately 2 feet less --3 A. And then he would have adjusted

4 those numbers.5 Q. Okay.6 A. And up to the elevations of the7 nearby measurements and high water marks that8 he had.9 Q. Okay. So he would have gone to the

10 closest nearby water mark to -- high water11 mark that he could --12 A. Correct.13 Q. -- and calculate it out?14 A. Correct.15 Q. So if your data was not accurate to16 the closest high water mark, he would change

17 his results to reflect or to mirror the most18 -- the actual high water mark that he found?19 A. Correct.20 Q. Okay. So what would be the closest21 high water mark to that ridge? Do you know?22 A. I would have to check for the data.23 I mean, you'd have to -- Bruce Ebersole could24 give the best answer to that.25 Q. Okay.

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1 A. There's a number of high water marks2 in and around that area that he would have3 based his decision on.4 Q. If you were to look at the scatter

5 plot that you have in your production here,6 can you identify which would be the closest7 high water mark?8 A. Okay. Now, in terms of the -- you9 can see in and around the system there's a

10 whole bunch of high water marks.11 Q. Hold on one second. I can't see12 anything. Just a second.13 A. Figure 142.14 Q. Okay. Thank you. Okay. So the15 closest high water mark, would it be -- the16 dark blue would be the closest high water17 mark?

18 A. You can see that there's a bunch of 19 high water marks around the system,20 particularly through the IHNC and through21 MRGO/GIWW Reach 1; and these are, by the way,22 all good or excellent high water marks. You23 can see that there's right one near the end of 24 the Chalmette Extension Levee; there's one25 kind of on the eastern part of the Chalmette

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1 Extension Levee; and then there were some high2 water marks that had a little bit less -- less3 -- that were either not good or excellent

4 that would have given some guidance in terms5 of how some of that -- the -- what the values6 were along the Chalmette levee itself.7 Q. Did you do anything to verify8 whether or not the data that you generated was9 consistent with the high water marks that were

10 reflected in the field?11 A. Well, these plots are from the H-112 run.13 Q. Okay. So when you calculated the14 high water mark -- when you calculated the15 surge elevations along the MRGO Reach 2 and in16 the second run it came to a foot to 2 feet

17 less than -- in that run that you gave to18 Ebersole and Fitzgerald and everyone else, and19 the surge elevation, what you calculated as20 the maximum surge elevation appeared to be a21 foot to 2 feet less than what was in your22 original run, did you verify or did anyone go23 and verify against the high water marks that24 you had what would be the closest high water25 mark and what might be closer to an accurate

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1 number?2 A. Well, Bruce Ebersole did.3 Q. But your group at this point in this4 particular --

5 A. Well, --6 Q. -- report --7 A. Yeah.8 Q. -- did not make any accommodations9 for that?

10 A. Yeah. You can actually take a11 look. I mean, it's right in figure 143, 144,12 145. So we compared to the data sets. We13 compute the statistics which is what we do for14 every run.15 Q. And if you have an actual high water16 mark and it's not on your line and it's pretty17 far off your line, how -- would you have done

18 nothing as a result of that?19 A. As in -- Could you give some20 clarification?21 Q. Well, I mean, if, for example, the22 closest high water mark is at Shell Beach east23 and it's that dark blue dot, --24 A. Okay. Yeah.25 Q. -- okay, the dark blue dot at the

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1 end of the MRGO Reach 2, --2 A. Yeah.3 Q. -- then you go to your scatter plot

4 --5 A. Yeah.6 Q. -- and your scatter plot shows the7 predicted peak being -- near that blue dot --8 A. Right.9 Q. -- being --

10 A. Roughly 18 feet or so.11 Q. Well, no, the measured peak is 1812 and a half. The predicted peak is 15. Or13 15.3.14 A. Okay. Yeah. Yeah. So that -- that15 gets computed into the statistics.16 Q. So that's like a 3 foot difference

17 in actual elevation.18 A. Yeah. And again, there -- if you19 look at -- there's a certain -- a certain20 level of variability in high water marks21 themselves. So if you look at -- And I would22 have to look at the data very carefully. But23 a lot of these high water marks may have a24 very close high water mark and that could be a25 lot better. However, just because one

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1 particular high water mark as we add features,2 and this -- in this whole very close time3 period, for example, we got a much better4 rendition, or as far as the Corps is

5 concerned, a much better rendition of the6 LaLoutre Ridge. So that could be the7 difference between some of the two sets of 8 plots. They were done very close to each9 other. One had a little bit higher ridge than

10 the other. So that could make these kinds of 11 differences. However, we do not hand make any12 adjustments. We try to put in the best13 representation in the system. So if the14 numbers go slightly down, they go slightly15 down. But in terms of doing the Katrina16 inland simulations, those then would be done17 with the numbers that have been pulled up

18 slightly to adjust them to the nearest high19 water mark. So that's the part in the process20 where that would be done.21 Q. So the fact that you're -- Well,22 actually, can we -- One second.23 MS. GILBERT:24 Gilly, I am advised that we have25 no connections.

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1 VIDEO OPERATOR:2 We're working on it. Can we go3 off the record?

4 MS. GILBERT:5 Please.6 VIDEO OPERATOR:7 Off the record. It is 2:11.8 (Whereupon a discussion was held9 off the record.)

10 VIDEO OPERATOR:11 Returning to the record, it is12 2:21.13 EXAMINATION BY MS. GILBERT:14 Q. We're back on record. We were15 talking for a moment off the record about the16 high water marks and that they are not always,

17 I guess -- Could you just explain the18 significance of the high water marks as they19 are depicted on the --20 A. Sure. So high water marks can21 obviously come from a tremendous number of 22 sources. They can come from interior of 23 buildings and they can come from fences, they24 can come from wash lines, and they may have25 varying degrees of wave action in them,

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1 depending on what the wave action looked2 like. That's why we like to really take3 interior high water marks. But then there's4 also the surveyors, when they actually go in

5 and survey a high water mark. They have to go6 from inside of the house, shoot a line outside7 of the house, and then they have to, with8 whatever system they're getting their vertical9 datum, they have to reference to that. So if

10 you look, for example, at -- let's see which11 table it is, table 4, there is a -- there are12 some statistics for the -- which are estimates13 of the error of high water marks. So, for14 example, there's a standard deviation of about15 a half a foot there between the URS and the16 Army Corps of Engineers. So that means that17 about 60 percent -- or 70 percent, 68 percent

18 or whatever of the data, if you start looking19 at clusters of high water marks, 60 percent20 would be within about a half a foot. But that21 does mean also that roughly, you know, another22 25 percent would be within a foot and another23 5 percent would be within a foot and a half.24 So you can see right there that they are not25 an absolute measure. They, like anything one

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1 does when you measure it, has errors of 2 interpretation and has errors of measurement3 in getting the right value. So this is just a

4 very coarse estimate that we make, but we have5 to be able to quantify somehow how reliable is6 that, is the data that we're comparing to, and7 that's what we do right over there.8 Q. When you say "over there", where are9 you referring to?

10 A. Table 4, the column, two columns11 under "Measured high water marks", compute the12 statistics of the high water marks.13 Q. So the average -- And you've got two14 categories, two data sets. You've got the15 U.S. Army Corps of Engineers data --16 A. Yes.

17 Q. -- and the URS data set. What's the18 URS data set?19 A. URS is, of course, the, of course,20 URS Corporation. They are the FEMA contractor21 that actually goes and collects high water22 marks for FEMA.23 Q. And who does the U.S. Army Corps of 24 Engineers ones?25 A. Well, the U.S. Army Corps of

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1 Engineers has a variety of sources that are2 ostensibly described in the IPET data.3 Q. So the U.S. Army Corps of Engineers4 high water marks are all the IPET high water

5 marks?6 A. And they are selected to be only the7 good and excellent high water marks within8 those data sets.9 Q. And how do they consider what the

10 good and excellent ones are?11 A. There are photographs taken of the12 high water marks and we can then look in and13 try to come up with the ones that are from14 interior marks versus a wash line that can be15 many, many feet above the still water line.16 So our reference of comparison is still water.17 Q. Is that because a wave on top of a

18 surge won't come into an interior space?19 A. That is correct. It's -- It just20 acts like a stilling basin. And I believe we21 talked about that a little bit yesterday.22 Q. Well, we didn't talk about it in the23 context of it being the inside of a house.24 A. No. No, no, right.25 Q. We talked about --

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1 A. A stilling basin, essentially it2 averages out. So remember that mathematically3 what you're doing is looking at the water

4 surface elevation and then you're averaging5 that over five minutes or ten minutes or a few6 minutes, say. And so that's what that7 stilling basin does. The wave action doesn't8 go all the way down to the bottom. And the9 same thing, an intact house will not respond

10 -- the water level inside will not respond11 fast enough to the up and down action on the12 outside of the house.13 Q. Now, who is the -- where did the14 data for the high water marks that you used15 come from?16 A. So the one is -- the USACE is the

17 data in the IPET set. We took good and18 excellent high water marks. And URS, it came19 directly from URS Corporation.20 Q. And what is the -- Do you know what21 Ebersole did with those high water marks?22 A. So you -- I can give you a summary,23 but to get the details you would have to ask 24 Ebersole.25 Q. Okay.

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1 A. But essentially, again, he took the2 hydrographs --3 Q. That you provided?4 A. -- that we provided.

5 Q. Based on that figure 13- -- that6 resulted also in the contour map that was 137?7 A. No. 139. And I would like to go8 back to that and just revisit that in a minute9 if we may after you get through -- after we

10 get through with this question.11 Q. Okay.12 A. But we had quite a few hydrographs.13 The ones that are plotted in the report are14 just a few of those that are representative.15 Q. Can you mark that, please?16 Okay. Go on.17 A. And those then were passed along to

18 Bruce Ebersole. And then he looked at the19 available data that we had.20 Q. All of the data was passed on to21 Ebersole or just what was marked, what was22 plotted in that contour map?23 A. No, all the hydrographs.24 Q. All. Okay. Go ahead.25 A. And he made the adjustments and then

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1 Steve Fitzgerald took those and made those2 adjustments.3 Q. What adjustments did he make?

4 A. Or, I'm sorry, not adjustments. He5 used those to drive his HEC-RAS model.6 Q. HEC-RAS?7 A. Yes.8 Q. Really briefly --9 A. His contour drainage model.

10 MR. SMITH:11 That's H E C-R A S, all caps.12 EXAMINATION BY MS. GILBERT:13 Q. Okay. And that's the interior high14 water marks?15 A. Yes.16 Q. When you say interior, it's not

17 interior of a polder, it's the interior of an18 actual physical structure?19 A. Okay. So Steve Fitzgerald does the20 interior drainage within the interior of the21 polder and that's what he's driving his22 HEC-RAS model or interior drainage model.23 When we're talking about interior high water24 mark data, mostly interior, you would have to25 look at the IPET report, exactly what data

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1 point -- not data point, but when we2 quantified those as excellent or good, we then3 took those into that data set. URS did the4 same thing.

5 Q. Okay. So looking at the data that's6 reflected in figure 139, was it, 140 --7 A. By the way, could we go back to 1388 to 139 for a minute?9 Q. We're going there now. We're

10 heading in that direction. I have a couple of 11 questions for you and you can elaborate if you12 wanted to.13 For 138 and 139. And let's look 14 also at 140 and 141 if you get this up if you15 could. How does -- Just for clarification,16 how would the difference of a high water17 elevation discrepancy of 2 feet affect the

18 high water, or the surge level in the IHNC?19 A. Well, we'd really have to look at20 what the differences in Paris Road were.21 Right?22 Q. Okay. Where on this map, how would23 we identify the impact of that difference or24 how could we do that?25 A. So essentially you would look at

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1 Paris Road and see what the differential was.2 Q. Can we see it on your map or would3 it just be a difference of 2 feet?

4 A. No.5 Q. Let's say it's a difference of 26 feet at the high water -- high surge --7 maximum surge elevation.8 A. I don't think it's a difference of 29 feet, by the way.

10 Q. Well, if you have got 15 feet for11 this comparison, you've got 16 to 17 feet as12 your -- in 138.13 A. Right.14 Q. And that's what your narrative15 says.16 A. 16, 16. So --

17 Q. In your narrative it says 16 to 17.18 A. Right. And that's correct. 16 to19 17.20 Q. And then we're looking at the green21 one down at figure 139 and we know that it's22 15ish.23 A. 15 to 16, though.24 Q. Okay. So we're going to say 1 to 225 feet.

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1 A. Actually, it's less -- it's in the 12 foot range. Not the 2 feet range. Right?3 Otherwise, it would be 14 to 15.4 Q. Well, you wouldn't show 14. You

5 wouldn't show another contour until 12.6 A. No, because, look, it's -- it goes7 from that black line that's right under 28.068 feet. Right?9 Q. Uh-huh (affirmatively).

10 A. So that's the 15. I think we agree11 on that. Right?12 Q. Well, the one that's closest to the13 MRGO levee Reach 2.14 A. Right. I know. But I am going from15 that, from that one, which is clearly the 1516 foot. Right? And you go down into the dip,17 that's 14. So on the other side it's 14, so

18 it's 15 to 16. Right?19 Q. Okay.20 A. The other one, you go from the 17,21 that's 16; then we go to 15. The other side22 is 15, and you go to 16. So then it looks23 like 16.24 Q. Which one are you looking at?25 Figure 138?

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1 A. Right. So we see the 17 foot. So2 it's 17, 16, 15. 15, 16 to 17. Right?3 Q. Okay. So it's a foot -- It's

4 somewhere in between a foot and 2 feet over5 there?6 A. No, it's actually -- I disagree with7 that. It's somewhere around a foot.8 Q. All right. So you've get a9 difference of a foot you're saying now. I

10 mean, in your narrative you did say it was11 between 17 -- 16 and 17. And now -- Okay. So12 the reflected --13 A. Right. I think that's what we're14 saying.15 Q. So a difference of a foot at the16 IHNC -- I mean at the GW- -- I'm sorry,

17 withdrawn. A difference of a foot at the MRGO18 Reach 2 levees. You would -- The impact of 19 that difference in the IHNC and the GIWW,20 would that also be about a foot difference?21 A. Well, it depends on where. Right?22 It basically would lower the water levels23 slightly in the -- It would -- It would -- You24 would start off with a foot less. Right? And25 as you worked your way down gradient --

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1 Q. It would be even more?2 A. No, the difference would become less3 and less. Right? Because by the time you get4 to Lake Pontchartrain, it's going to be -- it

5 looks like both models are around that -- both6 at 9 feet.7 Q. So they're both going to be lower8 than 15 feet. So if you started at the GIW --9 I mean the MRGO Reach 2 at -- let's say the

10 lowest water level was 15. It's still not11 going to be 9. So it's going to end up being12 continuously lower. Towards 9.13 A. Right. But you start off let's say14 at a foot and then it works its way down to15 zero.16 Q. Oh, it wouldn't be necessarily a17 full foot all the way down to 9.

18 A. It will be some distribution that19 goes down from 1 foot to zero feet.20 Q. Okay. I see what you're saying.21 Okay. But it will be less than whatever it is22 the predicted number was or the -- or the23 reported number was if the model is 15 feet as24 it says.25 A. Well, not actually. The numbers in

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1 here (indicating) are all -- were -- in all2 the comparisons were taken from here and the3 differences were all based on the H-1, H-2,

4 H-3, H-4, H-5, H-6.5 Q. But all of those numbers were based6 on H-1.7 A. Right. So all the differences in8 all the subsequent plots were based on H-1.9 Q. Right. So if we're saying that H-1

10 has got a different number here from what11 you've calculated -- what you've narrated or12 explained, --13 A. Okay.14 Q. -- then the rest of the -- it's all15 going to flow. It's as we said before,16 everything flows from your data. So if the

17 data, you reported initially the results from18 138, but now you're telling me that all of the19 information really came out of figure 139, so20 the following, the results were based on the21 actually lower numbers.22 A. They were based on slightly lower23 numbers, but the -- all the comparisons and24 differentials --25 Q. All right. Proportionally, however

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1 you're going to do the proportion, it's just2 that the numbers are lower?3 A. The absolute numbers would be4 slightly lower, but in terms of interior

5 drainage, again, we're cognizant of that and6 that's why Bruce Ebersole took those numbers7 and pulled them up a little bit in terms of 8 assessing the interior drainage.9 Q. And what did Mr. Resio have to do

10 with the results of it?11 A. Well, I assume, and you would have12 to check with him, --13 Q. That he would have to make some sort14 of compensation also for this incorrect --15 A. Oh, no, he would probably -- This is16 an assumption, but he would presumably take17 the same numbers as Bruce Ebersole produced,

18 adjust for any biases that we would have right19 along these levees which obviously were --20 It's important to get that very as precise as21 we can. He would have taken those and22 adjusted those so that he could have the best23 numbers possible in terms of any wave24 overtopping into the levee system.25 Q. But he would be starting with a

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1 number of 15, not 16 to 17. So all of his2 numbers would be --3 A. No, no, he would be starting with

4 our number -- Bruce Ebersole started with our5 numbers, then made the adjustments based on6 the high water marks.7 Q. And would Resio have taken8 Ebersole's data or he would have taken your --9 A. Again, you would have to check with

10 him to make sure, but it's my -- my11 understanding that he would have taken Bruce12 Ebersole's numbers.13 Q. Okay.14 A. But again, you would have to check 15 with him to make sure.16 Q. And we would have to check with

17 other data to verify if the rest of the18 information that's contained in this report is19 actual high water marks or if there's other20 high water marks that aren't reflected in this21 data that you produced?22 A. Run that by me again. I don't quite23 understand the question.24 Q. This data that you have not produced25 that would reflect the accuracy of the numbers

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1 that you used to --2 A. Oh, okay. Right. It's not that we3 didn't produce it. It just didn't show up in4 the plots. I would have to check back there.

5 Q. Well, when I say you didn't produce6 it, I'm talking more on a legal sense; you're7 talking more on a production sense. It hasn't8 been produced to the Plaintiffs in this case9 to review. That's all I am talking about.

10 A. Right.11 Q. I'm not saying you didn't actually12 produce the numbers in your runs. I'm just13 suggesting that we don't have any of that14 information in what was produced in this15 litigation for us to evaluate.16 A. Right. Right.17 Can I provide a little bit of

18 clarification in terms of -- in terms of --19 within the context of the conversation we've20 been having?21 Q. Yes.22 A. So, you know, a lot of these plots,23 and I mentioned yesterday I believe when you24 were querying me about the sources of the25 description and the narrative, right?

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1 Q. Yes.2 A. The narrative, in terms of how the3 storm evolves, the reason that was put into it

4 is to provide an understanding of exactly, you5 know, where the storm surge came from and6 where the water came from and how the storm7 evolves in the context of in and around the8 system. Right?9 Q. Uh-huh (affirmatively).

10 A. And then -- So that's what that data11 provides. And again, it looks like we might12 have used a slightly older version of -- in13 those little bit further zoomed out figures to14 help in the description of that system.15 Q. So let me see -- Are you done? I'm16 sorry.

17 A. No. And so then all of the -- the18 specific detailed comparisons would have been19 done with the newest version. Right? And20 that's the basis of all the comparison.21 That's the basis of all the data. And that's22 also the basis of the error analysis. And23 those would have been adjusted upward in terms24 of what was done on the interior drainage,25 wave overtopping, et cetera, et cetera, to

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1 match the high water marks.2 Q. So if I understand what you just3 said, the narrative explanation in this report4 that you produced in this litigation is only

5 useful to the extent that it describes the6 direction of the winds and the timing of the7 --8 A. Well, it's -- generically it's9 correct. As I said, we always have very, very

10 small adjustments that we make in the system11 as we evolve. Yes.12 Q. I just need to finish the question13 on the record.14 A. Okay.15 Q. But the actual numbers that you have16 reported in the narrative of this report --17 A. Yes.

18 Q. -- are not necessarily accurate.19 When you say the actual -- the narrative has20 maximum surge elevations that were calculated21 and they're contained in your report and in22 your analysis, that those reported amounts are23 not accurate.24 A. Well, I am not going to say that25 they're not accurate. I'll have to

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1 double-check them to make sure that they match2 exactly with the H-1 run that's reported in3 here.

4 Q. Okay. And we will, of course, want5 to see whatever it is that you will be looking6 at to verify or change --7 A. Okay.8 Q. -- whatever those numbers are. But9 as we sit here today, we don't have a full

10 understanding of what the actual maximums are11 based on this single report as it's produced,12 nothing that you have back in your office, but13 what we have to work with?14 A. Right.15 Q. Okay.16 A. So what we will do is double-check

17 these numbers and make any corrections, and18 not where the corrections are and make sure19 that that's reflected in this report.20 Q. And with regard to levee heights21 within this report, have you included in your22 -- Well, in your analysis of the contour23 maps, do you have -- you would not show any24 overtopping in these gray areas?25 A. Well, we -- we specifically excluded

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1 the overtopping because our numbers aren't2 accurate. And again, I think we state that3 very clearly in the report.4 Q. Okay.

5 A. Because it is a very, very complex6 process that incorporates both the levee7 breaching, which, by the way, has to -- has to8 have tremendously high resolution in our model9 in order to compute that. It does not exactly

10 reflect the -- It does not well reflect how a11 wave would overtop a system like that and so12 that needs to be computed separately. And it13 doesn't reflect the details of the interior14 drainage. Again, the model would require a15 lot of extra resolution to resolve those16 processes. And so that's why we used a17 separate model.

18 Q. And that's why you gave your data to19 Resio and Ebersole?20 A. Ebersole, Resio, Fitzgerald, yes.21 Q. On page 55, your last paragraph says22 "With the wind fields are the best that have23 ever been developed to characterize a24 hurricane".25 A. Yeah.

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1 Q. Can you explain how that's2 calculated -- how you -- There's no footnote3 to that and I don't know exactly what the wind

4 fields are. Was this the H wind data that you5 were referring to?6 A. H wind IOKA.7 Q. And why are those the best that have8 ever been developed to characterize a9 hurricane?

10 A. Okay. So there's a very simple11 reason for that. And again, to get the12 specifics, you have to talk to the people that13 worked the IH -- H wind and IOKA. But simply14 summarized, there's more available better15 data, more data that can be used to go into16 what are called kinematic models. There's

17 radar-based flights that go through a storm.18 There are land-based radar stations. And I19 don't know how long those have been run, but I20 would guess about fifteen years or so. But21 you'd have to ask the meteorologists for the22 exact number. There's more anemometers.23 There's drop sondes.24 Q. Sondes.25 A. Sondes. So there's a tremendous

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1 amount of availability of data. Even the2 understanding of the structure of the storm3 has improved dramatically. So that the data4 to work with to characterize the winds has

5 improved enormously.6 Q. And yet you indicate that the data7 is not -- has a 5 percent error rate which can8 lead to, readily lead to a 10 percent to 169 percent error in the computed surge. How do

10 you then -- how would that translate into11 these contour maps? Does that mean that the12 16 to 17 foot maximum surge elevation that was13 originally reported is actually within an14 error rate of another 10 to 16 percent?15 A. No, that's reflected in the -- in16 numbers -- The ultimate comparison of what17 we're interested in is the base line. That's

18 the still water level. Right? And so our19 best estimate of how accurate the overall20 storm surge is, is reflected in the average21 absolute errors and the standard deviations.22 Q. Okay.23 A. And the -- a bunch of other24 statistics which we compute.25 Q. And that's -- In what table are you

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1 referring to?2 A. Table 4.3 Q. Table 4 reflects average high water

4 mark data and wind speeds?5 A. No, -- Well, of course, it reflects6 the winds as well. Right? But it -- All of 7 those errors can come from anything that gets8 input in the model. Right? So we have9 obviously the physical system. It's not

10 perfect. Guaranteed. There's errors in11 bathymetry, there's errors in topography.12 There's -- There's insufficient resolution in13 portions of the system. We still14 computationally don't have enough resolution.15 There's errors in the wave fields. There's16 errors in the wind fields obviously as we're

17 talking about there, because we have a18 correlation coefficient of about .43 in terms19 of comparing coefficient. And so again, that20 ultimately, all of those things together lead21 to high water marks that are computed. And so22 --23 Q. Computed high water marks. Okay.24 A. Computed high water marks. And then25 they compare those to the measured high water

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1 marks. And we also account for what we -- our2 best mathematical estimate of the variability3 in the measured high water marks, and that4 allows us to derive a measure of how accurate

5 all of those components are in ultimately6 deriving what is the basis of these designs,7 and that's the high water marks.8 Q. And how do you compensate -- Is9 there a formula? Is there a factor? Or how

10 do you compensate for the potential errors on11 each one of these things in determining your12 number?13 A. Well, what we do is we essentially14 compute each process that we can separately,15 but -- and quantify that error. But the16 bottom line is what we're after and what we're17 talking about here is high water marks.

18 Q. Uh-huh (affirmatively).19 A. Right? So certainly what all of 20 those other factors give is -- is give us21 guidance in terms of --22 Q. Computed high water marks?23 A. Well, they give us guidance in terms24 of how accurate all the components are in the25 system. Right? So then -- But at the end of

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1 the day, what are we computing? We are2 computing the error statistics between what we3 predict and what we measure as high water

4 marks.5 Q. Okay.6 A. And so that's roughly 1.5 to 1.47 feet in terms of standard deviation.8 Q. Okay.9 A. Now, again, we could take any

10 component of these models, friction factors,11 bathymetry, topography, winds, wave radiation12 stresses, and we could tweak those so that I13 could give you an absolute zero difference14 between every high water mark and what we15 produce.16 Q. And why don't you do that?

17 A. Because that -- that's basically not18 giving the best estimate on each individual19 component. And once you get -- that is,20 quote, unquote, tuning the model to specific21 case. Once you then go out of the range of 22 that specific case or walk away from the23 specific characteristics of that case, then24 you get a terrible answer. Because you may25 actually be falsely adjusting some of the

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1 physics to try to match -- get a better match2 in your three parameters there once you3 started adjusting those and your answers. And4 that would be basically trying to make two

5 wrongs into a right. So we want to have a6 good understanding of how reliable these7 models are. Obviously they're going to be8 used in design. And so at the design phase we9 want to be able to understand what the

10 reliability of the model is.11 Q. So for the purposes of projecting12 and designing new levee systems or hurricane13 protection systems, you want this modeling14 system to be reliable for future use, but with15 regard to the specifics of this particular16 hurricane, if you wanted to actually know the17 details of this hurricane, you could have made

18 this a perfect correlation to the facts that19 you knew, but it wouldn't make the model20 useful in the future?21 A. Well, not only wouldn't make the22 model, it could still give you -- adjust other23 components or other parts of this system24 incorrectly. So again, when you start tuning25 and tweaking, it's essentially like building a

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1 table with a warped, slightly warped table top2 and then really forcing it to make a fit.3 Basically you're not -- you're artificially --

4 then when you do that, your table might pop up5 and warp somewhere else. So it's6 over-constraining the system. And so it's not7 allowing the physics to really do what it8 does. And so obviously we understand that we9 have -- We do not in any engineering model, I

10 can tell you, have a perfect -- a perfect11 representation of all the physics. However,12 at the end of the day what we want to have,13 and that's what these numbers reflect, is an14 understanding of the reliability of the model15 and of its ability to simulate the physics.16 And I think those numbers -- I don't think --

17 I know those numbers reflect that level of 18 reliability.19 Q. So in addition to the wind surge20 error computation, you also have the LIDAR21 that adds another -- as much as 1 foot?22 A. No, not 1 foot in the -- in the23 water levels, but 1 foot in where the exact24 surface elevations is.25 Q. Surface elevations of?

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1 A. Of the ground.2 Q. Of the topography?3 A. Of the topography. Right.4 Q. Okay. So now let's move on to H-2

5 scenario. Your H-2 scenario is, let's see,6 the "no MRGO" with the 2005 wetlands. And7 this goes back to, you know, allocated --8 Well, we have got the 2005 wetlands in this9 scenario, so the only thing that you do is to

10 fill in the MRGO? Is that correct?11 A. Yes.12 Q. Okay.13 A. No, I mean, that we -- we fill in14 Reach 2 of MRGO. Right?15 Q. We fill in -- You tell me.16 A. Okay. Let me be specific then. We17 fill in Reach 2 of the MRGO and we took Reach

18 1 of the MRGO down to its 1958 configuration.19 Q. And is it --20 A. So that means that we substantially21 narrowed that.22 Q. And that would be before it was23 being dredged at all for the MRGO Reach 2;24 correct?25 A. That is correct. That is before the

Page 199

1 MRGO is constructed.2 Q. Okay. So when you bring the Reach 13 of the MR -- the GIWW -- I'm sorry,

4 withdrawn.5 For the purposes of H-2, you6 constricted Reach 1 of the MRGO down to when7 it was just the GIWW?8 A. As it was in a 1958 aerial photo,9 yes.

10 Q. In a 1958 aerial. Was the objective11 to have that be exactly the dimension that it12 was prior to any efforts towards making the13 MRGO Reach 2 part of the GIWW?14 A. The objective was to have that be15 the best representation of the GIWW as it16 existed prior to the construction of the MRGO.

17 Q. So there should be no reflected18 construction for expanding the GIWW to Reach 119 of the MRGO in that aerial photograph?20 A. Correct.21 Q. Okay.22 A. And the aerial photograph is23 included.24 Q. I see it. It's in figure 9 of your25 report. Page 95. Is that -- Is this the

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1 aerial photograph that was --2 A. Yes. It is. And you can see the3 red outline is the land-water interface.4 Q. Yes. Now, I have a question for

5 you. If that Reach 1 or the GIWW is larger in6 some area than it would have been prior to the7 construction of the MRGO, that would bring8 more water to the base line model; is that9 correct?

10 A. Can you be a little bit more11 specific on that question?12 Q. If the -- If you didn't actually13 bring the GIWW to its original design width --14 A. Okay. Or as it -- as it existed in15 1956?16 Q. Well, the objective was not17 necessarily as it existed in 1956.

18 A. Or '58.19 Q. The objective was before the20 construction of the MRGO.21 A. Uh-huh (affirmatively).22 Q. Okay. So whatever date that is,23 whatever the base line model is, should have24 no expansion for the MRGO incorporated in the25 GIWW in your calculations; correct?

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1 A. If -- In what -- Under what2 objectives?3 Q. Well, you're trying to build this --

4 you're building your scenario based on "no5 MRGO" and building -- and returning the GIWW6 to its design parameters prior to any7 expansion for the existence of the MRGO or the8 construction of the MRGO; correct?9 A. So the -- the H-2 is the "no MRGO"

10 scenario. Right?11 Q. Right.12 A. And so we specifically did not put13 in a MRGO Reach 1. So this is the GIWW as it14 existed in 1958.15 Q. Well, as it existed in 1958 before16 any dredging was commencing on the GIWW for

17 the construction of the MRGO?18 A. Before dredging and lateral19 expansion.20 Q. Okay. And if it had not been21 constricted for that purpose, it would not22 accurately reflect the base line of your23 model; correct?24 A. If it had not been con- --25 Q. Constricted. If it hadn't been

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1 completely narrowed to the GIWW dimension2 instead -- If it was bigger than the GIWW,3 then your base line model is not the GIWW as4 it existed before the MRGO; correct?

5 A. So you're saying if this did not --6 if this is wider than what the 1958 or7 pre-MRGO situation was, then that would not8 reflect --9 Q. Accurately the quantity of water

10 that was traveling in the MRGO/GIWW -- in the11 GIWW prior to the construction of the MRGO.12 A. I suppose that that would be13 correct.14 Q. And even if part of this had been15 expanded, you would be bringing more water to16 your base line model than --17 A. The base line model is which one?

18 Q. Your base line model for H-2 is the19 GIWW as it existed prior to the construction20 of the MRGO.21 A. Okay, because a little bit of 22 confusion there, because, of course, we call23 H-1 the base line model.24 Q. I'm talking about the base model for25 your presumption of scenario 2.

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1 A. Okay. So -- Okay. Scenario 2 --2 Q. Should have a MRGO Reach 1 that is3 the dimensions of the GIWW prior to any

4 construction of the MRGO.5 A. As -- As we -- With the data that we6 had available to represent it, yes.7 Q. Does that mean that it could have8 some expansion for the MRGO in that aerial9 photograph already?

10 A. No. Like I said, this is 1958.11 Q. Okay. Because I am looking at this12 and I see a rectangular shape that looks13 fairly broad towards the Paris Road in this14 aerial photograph.15 A. Uh-huh (affirmatively).16 Q. And I look at what looks like dredge

17 spoil next -- you know, a dredge mound next to18 it.19 A. Let's see.20 Q. And it looks about twice as wide as21 the rest of the GIWW depicted in that aerial22 photograph.23 A. Well, that's in a little ways from24 -- from the Paris Road, I believe.25 Q. Well, it's actually --

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1 MS. GILBERT:2 What do you call this, Scott?3 MR. JOANEN:4 What, this line here?

5 MS. GILBERT:6 Yes.7 MR. JOANEN:8 Paris Road.9 EXAMINATION BY MS. GILBERT:

10 Q. So Paris Road -- Yes, I'm talking11 about right by the bridge, right by Paris Road12 and going west towards the IHNC. I see an13 area that is outlined that looks to be14 geometrically almost a perfect rectangle twice15 the width of the remainder of the GIWW in16 there.17 A. Yes.

18 Q. Do you see that?19 A. Yes, I do.20 Q. Do you know if this aerial21 photograph was taken after they had already22 begun dredging the MRGO?23 A. You'd have to ask Mr. Dunbar who24 provided us with the photo.25 Q. Okay. If that design -- If that

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1 width there is actually reflecting more than2 the original GIWW as dredged out, then would3 that have altered your information and the

4 results of your study for H-2?5 A. Well, you can see the length of GIWW6 that we have. Right? So it's a pretty7 substantial length. This, you know, what8 would you say, this is maybe about 10, 159 percent of the length between the confluence

10 of the IHNC and -- and the -- and where the11 GIWW and the MRGO would have split off? You12 know, so --13 Q. So my question is, would it alter14 the information?15 A. Certainly we would have to test16 that, but I suppose it could, but it wouldn't

17 be a dramatic alteration.18 Q. Well, it's not what it should be.19 It's not what you're saying it is, is the20 bottom line. If that is actually not the21 width of the GIWW, but double the width of the22 GIWW, and even if it's a quarter of the space23 between what would have been the confluence24 and the IHNC, then you no longer are depicting25 an H-2 that is without the MRGO or any

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1 expansion of the MRGO in Reach 1. Correct?2 A. The numbers would change.3 Q. Okay.4 A. And again, we could -- we certainly

5 --6 Q. And doesn't the throat of the GIWW7 affect the amount of water that's flowing8 through the GIWW to the IHNC?9 A. It affects the rate at which the

10 surface gradients would change.11 Q. So that would ultimately affect --12 And if you look at your contour maps and all13 of your maps, that shape exists in all of 14 them?15 A. It does. Well, not --16 Q. Well, all -- Yes, actually --17 A. -- the base case. And also not in

18 H-5 and H-6, which --19 Q. Because that doesn't purport to be20 that. Right.21 A. They would have been in -- They22 would have been the design MRGO.23 Q. Right.24 A. Right. As designed.25 Q. As designed. But for any one of the

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1 scenarios that purports to represent the2 results without the MRGO, this is no longer3 accurate information.

4 A. Well, that, I am not sure of, you5 know, what that is.6 Q. Well, if that's not the GIWW as it7 existed prior to the construction of the MRGO,8 then the representations of the results as9 being the results without the MRGO are not

10 correct.11 A. Well, you know, I don't know -- I12 know that we put that in there. Absolutely.13 As you know, that's right in the model. I14 don't know what the origin of that is. I know15 that, you know, it existed there in the16 representation of the system as per the 1958

17 aerial photograph. It could have been a18 basin, for example, if you look at the Michoud19 activities, which are all along there. So it20 could have been a basin to put -- to park 21 barges or it could have, you know, have been22 any number of things associated with the23 navigation along that part of the system, and24 in particular when you realize that the25 Michoud facility is there and you look at that

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1 very large arm, you have two Michoud branches2 and that that was a rocket transport facility,3 it wouldn't be unreasonable to expect that4 that had something to do with that. I'm not

5 sure what the origin is.6 Q. And you sit here today, you do not7 know that this is in fact a representation of 8 the GIWW Reach 1 which would be prior to its9 construction as the MRGO?

10 A. Okay. What I can say about this is11 that this is the system as it existed in 1958.12 Q. In this aerial photograph. But you13 don't know if this aerial photograph was taken14 after the initial dredging had commenced of 15 the GIWW.16 A. That --17 Q. You don't know?

18 A. I have to rely on the information19 that was given to me.20 Q. So you don't know that answer?21 A. I wasn't there back then. Actually22 --23 Q. Okay. My question is, this is your24 report.25 A. Yes.

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1 Q. You have made a representation about2 what this is. Now, I am not saying it's your3 fault, I am not saying it's somebody else's

4 fault, but I am just saying that as you sit5 here today, to a reasonable degree of 6 engineering and scientific certainty, you7 can't tell me that that is exactly the8 dimension of the GIWW prior to the9 construction of the MRGO.

10 A. Well, I not an historian. I don't11 know when the construction of the MRGO12 started, although it is certainly my13 understanding that it started post-1958. But14 all I can tell you with certitude is that this15 is an aerial photograph that was the system in16 1958 and that's what we represented in the

17 system.18 Q. But you also represented that that19 was what the GIWW looked like prior to the20 initiation of construction of the MRGO, and21 that part of it you cannot say is true?22 A. Well, I have to look up what --23 Q. Well, isn't that what the scenario 224 is supposed to be depicting?25 MR. SMITH:

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1 Excuse me. You interrupted him.2 He was getting ready to explain.3 MS. GILBERT:4 No, he said he had to look

5 something up.6 THE WITNESS:7 Okay. So it says that it is the8 -- reduced to the approximate9 dimensions of the GIWW in 1958 prior

10 to the construction of the MRGO.11 EXAMINATION BY MS. GILBERT:12 Q. Okay. So if this is actually part13 of the construction of the MRGO, then this is14 not actually -- that portion, just that15 portion of your representation of H-2 and any16 of the scenarios that deal with the17 construction without the MRGO all contain that

18 and if that was actually part of the19 construction of the MRGO then you have not20 taken it down to the original design of the21 GIWW.22 A. Well, I certainly will have to check 23 that very carefully.24 Q. And then would you have to rerun25 your analysis to determine whether or not that

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1 would have an impact on your results?2 A. Well, that would be the way to find3 out.

4 Q. Okay. Well, that would not be the5 way to find out whether that was the GIWW.6 That would just be the way to find out whether7 or not your results are accurate any more.8 Okay.9 A. Well, not accurate. It would be the

10 way to find out what the influence of that11 further construction would be.12 Q. Okay. Then what I am saying is,13 that would be your way to find out whether the14 results of your conclusions based on what you15 characterize as the scenarios that were16 designed to be run without the MRGO are

17 accurate to that scenario.18 A. That would be an accurate19 representation.20 Q. Okay. Thank you.21 VIDEO OPERATOR:22 We're off the record. It is23 3:09.24 (Recess.)25 VIDEO OPERATOR:

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1 Returning to the record, it is2 3:25.3 EXAMINATION BY MS. GILBERT:4 Q. Do you know what the dimensions of

5 the GIWW were that you relied on for Reach 16 in the H-2 scenario?7 A. I would have to look that up.8 Q. Where would you have to look that9 up?

10 A. Well, certainly the -- there are --11 based on the aerial photographs and some of 12 the design memorandums.13 Q. Do you know, as you sit here today,14 what the proportionate difference between the15 GIWW Reach 1, or prior to the -- Withdrawn.16 Do you know what the relative17 proportions of the GIWW was in relation to the

18 MRGO Reach 2? Was it half as wide, a quarter19 as wide?20 A. You know, again, I would have to21 look that information up.22 Q. And that would be in data that's not23 produced anywhere in this report?24 A. I forgot whether we put some of the25 design dimensions -- the dimensions in or

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1 not. I'd have to look through the report.2 Q. Where would you look for that in the3 report; what part of it?

4 A. Probably up in the beginning where5 we describe each of the different6 configurations.7 Q. Before you actually do that, I want8 to ask you a totally unrelated question. In9 looking at your contour maps that have the

10 arrows on them, the wind vector knots or the11 -- yes, the wind vector knots and the arrows12 are in like little cubes. Do you know what I13 am talking about? Not the elevation contour14 maps, but the ones like the figure 77, 78, all15 the ones that have little arrows depicting the16 flow of either wind or water?

17 A. Let's see. 71? Yeah, yeah.18 Q. Any of those ones that have the19 arrows in them.20 A. Yes.21 Q. Now, those arrows show up in little22 squares. And this is a total -- this is23 relating to my question about the grid pattern24 of either a triangular grid or a -- You had25 discussed this yesterday, that there was a

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1 difference between a structured and2 unstructured grid and triangular grid patterns3 and square grids.4 A. Yes.

5 Q. And what I am wondering is, is this6 a -- is the output that's depicted on these7 maps the result of whether or not you were8 dealing with a structured grid, which is a9 square grid, or a triangular grid or are they

10 completely unrelated items?11 A. Well, okay, maybe I can provide a12 little bit of guidance on that. If you were13 to -- The wind fields actually do come from14 structured grids.15 Q. The wind fields are structured?16 Okay.17 A. And for the high resolution

18 structured grids. However, we interpolate19 those obviously on our finite element grid.20 The plots are made from data that has been21 processed through our finite element grid and22 we actually --23 Q. Okay. Keep going.24 A. -- modify the winds within the25 finite element model to account for where

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1 there's land and where there's roughness. So2 we actually -- the winds that are given to us3 are called marine winds. They do not account

4 for the land roughness. And so we have an5 upwind algorithm that's I believe referenced6 in this document that's extensively described7 in the monthly weather review paper that we8 wrote and in other reports. And so these9 winds are modified. And that's in fact

10 reflected on the wind contours that are11 shown. And so these winds are actually the12 winds that the ADCIRC model has gotten and has13 put on each and every node that's associated14 with every triangle, 3 nodes per triangle in15 the computational mesh. However, if you're to16 plot those, you would, every -- a vector at

17 every node, you know, we'd have a black page18 here.19 Q. Right. Okay.20 A. So what the plotting software does,21 it then takes back that information and puts22 it on a rectangular grid so that for23 visualization purposes you can see what's24 going on.25 Q. So it's just the output has it in a

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1 square grid, but it is calculated and figured2 out on the unstructured or the triangular one?3 A. Absolutely.4 Q. That's what I -- And so there isn't

5 one that would have like a pattern of 6 triangles of these grids?7 A. We can certainly make one for you,8 but you wouldn't be able to see it any more.9 Q. I got you.

10 A. I.e., remember, there are hundreds11 of thousands, if not, you know, close to half 12 a million computational points on this portion13 of the grid. So you wouldn't be able to see14 anything.15 Q. I just thought it had to do with the16 cube, the squares as the structured or the17 unstructured. So you basically take the data

18 and you reinterpret it into another program19 that puts it back into squares and then it20 spits it out as squares.21 A. We have a variety of visualization22 programs and plotting programs that manage23 this data. There's massive amounts of data to24 be processed.25 Q. Can you make the grids, the little

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1 grids smaller or bigger based on that2 visualization program?3 A. Absolutely. Yeah. But again, if

4 you make them too tight, you won't be able to5 --6 Q. Read it?7 A. -- see the contour lines or read8 things.9 Q. Got it. On page 56, your narrative

10 says "Air-sea momentum transfer coefficients11 and Manning end bottom friction coefficients12 may not perfectly capture momentum transfer13 process of dissipation processes. All of 14 these uncertainties are actively being15 addressed in the scientific community through16 micro and macro scale measurement as well as

17 through high resolution modeling studies."18 What does that mean?19 A. Well, basically what I -- what I20 wanted to convey in this particular set of 21 paragraphs, this particular one and the22 previous several paragraphs, is that there are23 a variety of uncertainties that all come24 together in these models. Many, many parts,25 many physical processes that are being

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1 modeled. And this particular paragraph2 addresses the fact that the drag coefficient3 --4 Q. The Manning end?

5 A. No, the air-sea drag coefficient.6 Q. Oh, okay.7 A. And that basically transfers -- is8 the amount of momentum that gets transferred9 from the wind into the water column. That's

10 -- That is certainly not perfect.11 Q. Okay.12 A. Also, the Manning end bottom13 friction, for example, if you have a marsh14 that's not overtopped and the water is going15 through the reeds, it's going to see somewhat16 of a different frictional resistance than the17 Manning end, because it's really at that point

18 a very three-dimensional type of resistance.19 So --20 Q. So if, in that scenario then, it21 would have a higher frictional coefficient, or22 a higher friction -- the same way we discussed23 earlier where the number we used was wrong, it24 would slow, or different, it would slow it25 down, the propagation of surge?

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1 A. It might slow it down, but, of 2 course, if you have massive overtopping of the3 marsh, then that is going to be a very

4 different scenario. So for a very low5 intensity storm it may make a difference. A6 high intensity storm, not so much. That being7 said, the total uncertainty that we have in8 our modeling systems is reflected in the9 numbers of the ultimate high water mark

10 measurements to the high water mark 11 predictions. So all of these uncertainties12 that I summarize here and all of these things13 that really need to be improved as we move14 forward towards more and more accurate models,15 those -- those have to be quantified. And16 this is really a summary of a lot of those

17 particular uncertainties. Now, how accurate18 is the Manning end? That's probably best19 reflected in the recession curves that we20 compute and match to measured recession21 curves. And so for the most part we -- we22 think that that prob- -- that is a fairly23 accurate representation.24 Q. Okay. Can you turn to figure 151,25 the difference between the H -- It's on page

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1 175.2 A. I'm there.3 Q. And this is your depiction of the4 difference between the Katrina event and what5

was characterized as H-2, which we understood6 to be the 2005 wetlands with the -- with "no7 MRGO". So you're removing the Reach 2 and8 presumably having constricted the GIWW. Does9 this reflect that the water level,

10 nonetheless, has forgotten deeper at the11 confluence of the IHNC and the GIWW?12 A. Deeper?13 Q. Well, the water level -- it's14 getting darker blue in the -- despite -- Isn't15 that right?16 A. Yes. So it reflects that in H-2,17 when we narrow the GIWW/MRGO Reach 1, that the

18 water level is lowered.19 Q. Oh, I see what you mean. Okay. I'm20 sorry.21 A. May I make a comment on this, by the22 way?23 Q. Okay.24 A. One thing that we did not do is we25 made no effort to see what the configuration

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1 of the -- of the IHNC was in the time of -- in2 1958. So that certainly could have a3 significant effect on the characterization of

4 the water levels within the system as well.5 I.e., if the IHNC at the time had been6 narrower, quite a bit different, then that7 would affect the distribution of the water8 levels between Paris Road and Lake9 Pontchartrain. So if -- In order to improve

10 or to get a more realistic situation of what11 the system might have looked like or what the12 water levels would have been in that part of 13 the system, a more accurate rendition could be14 -- could be obtained by looking at what --15 how the IHNC, particularly the northern16 section of the IHNC, would have been

17 characterized.18 Q. Where the Seabrook lock is?19 A. Well, between Seabrook and the20 confluence of the IHNC and the Reach 1 of the21 MRGO/GIWW.22 Q. But just to clarify my question23 before and your answer to my question, figure24 151 reflects that between your H-1 and H-2,25 which was the actual Katrina configuration and

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1 H-2 being presumably the configuration of the2 wetlands where -- as they were in 2005 without3 the MRGO and with the GIWW constricted, that4 there was approximately, if you look at your

5 scale on the side bar water level, 3 and a6 half feet less water in the confluence of the7 GIWW/IHNC.8 A. Okay. Just a correction to throw in9 on your statement there. No modifications in

10 this particular simulation were made on the11 wetlands.12 Q. That's right. That's what I said.13 A. No, you said that the wetlands had14 been modified.15 Q. No, no modifications of the16 wetlands. 2005 wetlands.17 A. Correct. It's 2005. Okay. So just

18 we're on the same page.19 Q. Okay. So that without the MRGO, and20 the wetlands being what they were, there was 321 and a half feet less water in the IHNC?22 A. Right. And I should -- And really I23 maybe need to modify the report to reflect24 this, no modifications on the IHNC. So it's25 really a 2005 IHNC.

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1 Q. Okay.2 A. And as this example so vividly3 illustrates, the distribution of water level

4 between Paris Road and Seabrook is5 dramatically affected by the width and6 frictional resistance within the system.7 Q. So your model would reflect, if the8 GIWW was narrower, it would have an impact on9 the results? It would be even less?

10 A. That, too, and it would also, for11 example, if the IHNC were narrower at the time12 --13 Q. Okay.14 A. -- it would have an impact.15 Q. Okay. Now, you conclude at page 5816 essentially that there's this additional

17 flooding in English Turn, or an additional18 water level in the English Turn area as a19 result of the absence of the MRGO. Where did20 this water come from that is now increasing --21 I mean, it's only a quarter of a foot, but22 where presumably does this water come from in23 the English Turn area? Isn't the water coming24 from the south?25 A. It's a little bit more than a

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1 quarter of a foot. Right? It looks like it's2 about a foot.3 Q. Okay. But is this water source4 originating from the south when the water is

5 coming up from the hurricane -- being driven6 in by the hurricane?7 A. No, it's coming from the east. If 8 you look at the vector plots of where the9 water was coming, from it's coming from the

10 east and the northeast. If you look carefully11 at the vector plots of the development of the12 storm.13 MR. SMITH:14 What figure is this?15 MS. GILBERT:16 Figure --17 THE WITNESS:

18 Let me see. And again, that19 probably would be a little bit helpful20 to have bigger figures, but if you21 look at the evolution --22 EXAMINATION BY MS. GILBERT:23 Q. From what page? Which ones?24 A. For example, 128.25 Q. This is figure 128 or page?

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1 A. Figure 128, page 162.2 Q. Yes. The water is coming --3 A. These are the water vectors. So

4 looking in around that system, I mean, it's5 stuff -- the vectors are coming pretty much6 from the east and from the northeast.7 Q. From the northeast?8 A. Yeah. Even if you -- I mean, if you9 go a little bit into Lake Pontchartrain.

10 Q. Okay. No. I am talking about the11 area in --12 A. Not Lake Pontchartrain. In Lake13 Borgne.14 Q. They're coming south in Lake Borgne,15 but in the water area of the English Turn,16 they're all coming in from the east and

17 heading north. North and from the east. In18 the English Turn area.19 A. In the English Turn, they're -- so20 -- Okay. So there's hardly any -- So it's21 pretty much all coming from the east. Right?22 Q. Yes. And from the south. Traveling23 with the -- As the hurricane is moving north,24 the water is traveling north with it.25 A. It's very hard to see on these

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1 vector plots.2 Q. Well, all right. Then we'll move3 on.4 A. Actually, I can provide some -- a

5 little bit better plots on all of this stuff,6 but it very clearly shows that --7 Q. They're coming from --8 A. -- the currents are coming from the9 east and the northeast.

10 Q. Into English Turn?11 A. Into the whole LaLoutre Ridge area12 and crossing in that area. And so there's a13 lot of flow that's coming on. Later on, the14 storm surge propagates from the south, but15 that's only much later in the storm.16 Q. Okay. Well, I would like -- You17 know, we have asked in the production, in our

18 requests for production for more better19 resolution maps. So we'll -- I'll let that --20 A. By the way, if you do pull up the21 PDFs, you'll be able to see some of this stuff 22 better.23 Q. Yes. They pixilate a little bit.24 That's okay. We'll get the actual versions.25 A. I'll pull this up.

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1 Q. Page 61. That's okay. We can move2 on to the next.3 In your H-2 scenario, are all the

4 levees still in place? In your H-2 scenario.5 A. The exact same levees, yeah.6 Q. Okay. And the spoil mounds in the7 vicinity, are they calculated at a higher8 elevation than the levees, or do you know?9 A. Well, I made comments on the spoil

10 mounds because it appears to have quite a bit11 of a difference. And so the spoil mounds --12 Q. Do you have an elevation height for13 those?14 A. I'd have to look at the pictures.15 But the spoil mounds -- Let's go look at these16 pictures. So, for example, the H-1 model,

17 looking at figure 4. Right? Are you with me18 on page 92, figure 4?19 Q. Yes.20 A. Okay. So let's follow the MRGO21 Reach 2 to the southwest past the Chalmette22 Extension Levee. I.e., we're leaving the St.23 Bernard polder. You can see that's all kind24 of purplish there? And so that's 5 feet or25 greater spoil mounds right in that region.

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1 Q. Does that mean the spoil mounds are2 higher than the levees?3 A. No. Actually, the levees are, what,4 something like 14, 15 feet in a lot of those

5 areas.6 Q. Are they depicted on the --7 A. No, the levees are not depicted in8 these contours. The levees are sub grid scale9 features.

10 Q. They're topography maps.11 A. Well, they're topography maps and12 they're actually what the NOAA elevation is.13 Not the sub grid scale structure that sits on14 top of the nodes. So there's actually --15 Remember that a levee is a very narrow scaled16 structure, relatively speaking, to the grid17 scales that are in these models. And so you

18 can't -- You would have to have more like19 decimeter to meter, potentially half a meter20 scale grids to capture flow properly going21 over a levee. And so that's why they have to22 be put in bathymetrically with the sub grid23 scale feature. So there's actually -- You can24 extract levee heights and plot them separately25 and see what the levees are, but they're not

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1 reflected in the topography, so -- when we2 have a sub grid scale feature.3 So now you go to figure model H-2

4 and maybe perhaps figure 11 would be a good5 one, you can see that the way we put that6 topography in there -- oh, still maybe a7 little high, but it's more like, you know,8 roughly around a 1 and a half foot range.9 Going from 5 foot or higher. And in a very

10 persistent barrier there. Right? To -- To an11 area -- to elevations that are way below that,12 like 3 or 4 feet below that. Do you see?13 Q. Yes. I follow that.14 A. And, by the way, the rationale15 behind doing that, you know, one could argue,16 well, you're doing many, many things, but, you

17 know, again the idea was to try to recreate18 what would have happened if there weren't an19 MRGO there. And eliminating the MRGO, you20 also would have eliminated the spoil mounds.21 Q. Okay. Now, with regard to the GIWW22 again, Reach 1, how did you calculate the23 depth of the GIWW without --24 A. There's a --25 Q. -- Reach 2 -- Reach 1 of the MRGO?

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1 A. Okay. There was an Army Corps of 2 Engineers design memorandum, and it's3 referenced in the report, that indicated that4 the self scour depth of the GIWW in that

5 section as being, if I recall correctly,6 roughly 24 feet.7 Q. How does the depth affect the flow8 of the water in the area of the GIWW if it's9 narrower, but it's calculated at a deeper than

10 actual amount depth? Would it mean more water11 in the IHNC or less? Or how would it affect12 the result?13 A. It would give you some more water.14 Q. Would it affect the speed at which15 the water would travel through that area?16 A. It would.17 Q. And would it affect the propagation

18 of waves, waves on top of the surge level in19 the GIWW?20 A. Actually, you'd have to talk to21 Resio and Jane Smith on that. But the deeper22 water would actually give you bigger waves.23 Q. Okay. Looking at this topography24 map that you have just drawn our attention to25 where you filled in the MRGO Reach 2 --

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1 A. Which one are we talking about now?2 Q. You just drew my attention to map3 figure 11.

4 A. Okay.5 Q. And maybe it's better to look at6 figure 12, H-2 model topography.7 A. All right.8 Q. How did you calculate -- How did you9 determine what elevation to fill in the MRGO

10 Reach 2 to?11 A. We just tried to get somewhat of a12 Rome approximation to the adjacent -- adjacent13 landscape and figuring, well, we don't quite14 know what was there. We just went a little15 bit conservative, probably a little bit16 higher.

17 Q. So the orangey-yellow is18 approximately how -- It's 2 and a half feet to19 2 feet -- 1 and a half feet?20 A. Rough -- I would say -- I would put21 it at roughly 1 and a half feet.22 Q. And the area right at the second --23 if you look at the comparison of H-1 in that24 area in the topography map for H-1, let's say,25 for example, figure 5, the area that is just

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1 -- the area just out of Bayou Dupre in figure2 5, that red area there, there's a purple line3 on the western, southwestern side of the MRGO4 reach and then on the eastern, northeastern

5 side it's red?6 A. So you're talking really in the --7 Q. Fort Beauregard is there.8 A. Right over here (indicating).9 Q. Yes. That little area.

10 A. Okay.11 Q. That would mean that the land in the12 vicinity was -- in the area that's red, it13 would mean the land in the vicinity is between14 2 and 2 and a half or 3 feet elevation based15 on your calculation there?16 A. Roughly.17 Q. And then to the southern area,

18 southwestern area of the MRGO in that vicinity19 it's purple and is that because it's the spoil20 mounds that you were just describing?21 A. Well, the spoil mounds certainly22 were used to dispose stuff adjacent to the23 MRGO.24 Q. So you would not necessarily have25 brought that area back to the purple color,

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1 with you would you have normally considered2 bringing that area back to the red color which3 is in the vicinity as you described

4 approximating it?5 A. On H-2 because we didn't get rid of 6 the levees, we decided to just keep the levees7 -- levees and the adjacent spoil mounds8 there. But then when we went on to9 configuration H-3, much of that stuff was

10 eliminated.11 Q. Well, in H-2 I'm only really12 concerned about the area that's east and a13 little bit north of the MRGO where there had14 been an elevation of between 2 and 2 and a15 half feet and now it's been reduced down to 116 and 1 and a half feet. And that's the area

17 between --18 A. So you're talking about that little19 peninsula right in the middle of Lake Borgne.20 Q. Well, yeah. Okay. The corner --21 the upper western, northwestern part of the22 peninsula. So this part of the -- If this is23 the peninsula, then there's the west-east --24 the west-north part of that quadrant which was25 red and now has been reduced in --

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1 A. Right.2 Q. -- elevation to a foot.3 A. For the most part, the idea was,4 yeah, those are probably spoil mounds and so

5 we eliminated those.6 Q. So you just eliminated -- You didn't7 check in any way to determine whether those8 were spoil mounds? You just eliminated the9 high ground there down to --

10 A. Well, --11 Q. I mean, because I see -- when you12 were suggesting spoil mounds before were the13 purple, that's on the south side --14 A. Right.15 Q. -- of the MRGO Reach 2. And that's16 -- you indicated you left there. And now on17 the area closer to Lake Borgne, you have

18 eliminated what would have been something that19 could have had an elevation of between 2 and 220 and a half feet that's right at the --21 A. Right, although --22 Q. -- node, I guess the north node? Is23 that how they call it? The northern node of 24 Lake Borgne; correct?25 A. Well, if you refer to figure 18 and

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1 you look at the best approximation of what2 things were like in 1956, you essentially3 don't see any of those features.

4 Q. Well, 18 is also based on the --5 Isn't that -- Isn't that based on the6 topography that you had calculated from your7 Mannings end?8 A. Not our Mannings end. It's based on9 the topography of what we -- what was there in

10 1956.11 Q. Who gave you that topography?12 A. Mr. Baras.13 Q. Okay.14 A. Not topography. He gave us the land15 use classification that the USGS, based on16 their analyses, and you would have to ask him

17 about that, existed in the area in -- in18 1956.19 Q. And would that have been from the20 1956 habitat data summary that he -- that he's21 produced in his report dated December 22nd,22 2008? Is this chart --23 A. Let me see.24 MR. SMITH:25 There's one here. What page are

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1 you looking at?2 MS. GILBERT:3 Yes, why don't we mark it as4 whatever we're up to.

5 EXAMINATION BY MS. GILBERT:6 Q. And, unfortunately, Mr. Baras didn't7 number his pages. So it would be the8 second-to-the-last map in his production or9 his report.

10 MR. SMITH:11 Do you have another one, Elisa?12 MS. GILBERT:13 Of the Baras report?14 MR. SMITH:15 Yes. Do you have a copy?16 MS. GILBERT:17 It's possible. Let me check.

18 MR. SMITH:19 Oh, wait a minute. Here's one.20 Here's one.21 MS. GILBERT:22 See, I brought two. I brought23 one just for you.24 MR. SMITH:25 We've got one. Thanks.

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1 This one is numbered, Elisa.2 MS. GILBERT:3 Where?

4 MR. SMITH:5 (Indicating).6 MS. GILBERT:7 Oh, the report is, but the graph8 is not.9 MR. SMITH:

10 The figures are not. I see what11 you mean.12 THE WITNESS:13 So it looks like there's14 non-fresh marsh in that area. Right?15 EXAMINATION BY MS. GILBERT:16 Q. I am just asking you -- The question

17 that's pending is whether or not this is the18 chart that Baras gave you.19 A. Actually, the chart that we used is20 in the report. Let's see. That is -- But it21 certainly is the same -- in that area. It's22 figure 55.23 Q. Your figure 55. That one based on24 the verbal communication with Rich and Dunbar?25 A. Baras.

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1 Q. Baras. I'm sorry.2 A. So it looks like he's got a few more3 classifications.4 Q. In his report?

5 A. Right.6 Q. All right. Well, as a general7 proposition, as like a general interpretation8 of the effects of the reduction of the land9 elevation in the vicinity when you're

10 calculating your H-1, would having the land11 lower than the vicinity have an impact on the12 results? If it was red and we could13 understand exactly which topography that14 related to, and you turned it yellow, you15 would be reducing the elevation of the16 vicinity -- the wetlands in the vicinity and17 the topography in the vicinity, how would that

18 affect, if at all, the results of your H-219 analysis?20 A. Well, you know, certainly dropping21 something from 5 to 2 feet would have an22 effect and it lets more water through behind23 wherever it's going and it would drop the24 water levels from wherever it's coming from.25 Right? So, you know, you -- it's -- water has

Page 239

1 to go somewhere.2 Q. Okay.3 A. And so if it's not going somewhere,

4 then it's raising somewhere else. So, you5 know, it's -- it's certainly where -- if it6 goes up somewhere, it commonly goes down7 somewhere else. And how much, that depends on8 the exact details of the configuration.9 Q. Can I also draw your attention in

10 figure 12 of the H-2 model topography, along11 the --12 A. Let me get there. Just one sec.13 Q. It's page 97.14 A. Yeah. I'm there.15 Q. Again going along the area of the16 elevation that's been filled in --

17 A. Whoops. Sorry. I'm just trying to18 -- Figure 11, you said?19 Q. I was looking at 12. But probably20 11 is not that much --21 A. Okay.22 Q. I was looking at -- Yes, let's look 23 at 12 because it's a little bit easier to24 see. Because 11 is really small. But in the25 area -- I guess it's not a peninsula, but when

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1 the bump starts to swell up again just, you2 know, where Fort Beauregard is. Do you know3 where Fort Beauregard is? Just at that point4 where Lake Borgne gets really close to --

5 A. Okay.6 Q. -- Bayou Dupre. Okay. Do you see7 along your MRGO Reach 2 yellow swath there,8 there's a blue swath kind of riding along it?9 A. Yeah.

10 Q. What is that?11 MR. SMITH:12 What figure is that?13 THE WITNESS:14 Right here (indicating). That15 might be -- You know, the area's16 crisscrossed with channels.17 EXAMINATION BY MS. GILBERT:

18 Q. Well, it runs all the way up to the19 funnel. So is it possible that that was --20 A. Which blue swath?21 Q. I'm sorry?22 A. Which blue swath are you talking23 about? This one over here (indicating)?24 Q. No, no. I'm sorry. Just running25 parallel along the edge of the yellow, you

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1 have a line of blue that gets wider and gets2 narrower, but it goes all the way up to the3 confluence of the GIWW and then it -- it's a

4 parallel -- it looks as though it may have5 been the widened areas of the MRGO that just6 did not get leveled out in your H-2.7 A. Yeah, it looks like that's it. Just8 probably one little layer of nodes or9 something like that.

10 Q. So from that -- that swath of blue,11 or it's a narrow swath, but was the12 calculation of what you filled in based on a13 number or was it based on, for example, the14 original design dimension of the channel for15 the MRGO Reach 2 portion? Or did somebody16 actually calculate what was bank to bank Reach

17 2?18 A. What we did is try to fill19 everything in and to somewhat try to get a20 representation of what was in and around the21 system. A very coarse approximation.22 Q. Okay. So in your calculation,23 though, did you actually just do it visually24 or did you use a mathematical or engineering25 design standard to calculate exactly what was

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1 the MRGO Reach 2 so that you wouldn't have --2 so that all of Reach 2 would be eliminated?3 Because, you know, it seems to me that as we4 know, Reach 2 eroded in both directions and so

5 the actual design dimension of the Reach 2 is6 not what it was in 2005. And my question7 really is, how precise was the effort to fill8 in Reach 2 in the topography?9 A. In general we were a little bit

10 conservative probably. Right? I mean, if you11 look at, for example, the southeastern portion12 in figure 12, we're roughly at, you know, 113 and a half feet I guess we agreed on.14 Q. I'm not talking about the height.15 I'm talking about the width.16 A. The width, we tried to fill in the17 whole swath.

18 Q. Okay. So that blue area that runs19 along the top, where is that from? Because20 that doesn't exist anywhere other than along21 the MRGO.22 A. All right. So that's just the --23 probably a little ghost of something that was24 there. But you can see that if you look a25 little north, that the whole area was

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1 crisscrossed with channels. So that's2 probably a reflection of keeping a little bit3 of that in somewhere.

4 Q. Well, down by the -- by Lake Borgne5 at Beauregard, at Fort Beauregard it's a6 pretty --7 A. Yeah.8 Q. -- long area of horizontal line9 there that follows, or not horizontal,

10 parallel line that's blue that doesn't have11 any adjoining marshes crisscrossing in there.12 So I am just -- in terms of understanding how13 this was done, was there a precise methodology14 implemented in calculating what you were15 filling in for the width of the MRGO? And16 then I understand that you picked, you know, 1

17 and a half feet as for whatever reason, an18 average or whatever for the depth. Or the19 elevation. But just for the width, did you20 end up leaving some portion of the MRGO in21 your calculation there just by that blue line?22 A. I would be surprised if that's more23 than one node wide, which essentially doesn't24 hardly have any conveyance. So if you filled25 it in, the adjacent node, to a foot and a

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1 half, I can 99.99 percent guarantee you that2 the numbers would change by less than a tenth3 of a centimeter.4 Q. But they would change, and we can't

5 tell what the difference would be right now?6 A. Well, I'm saying they're going to be7 less than a tenth of a centimeter if you8 change those few nodes. It's not -- It9 doesn't have any conveyance. You have 15 feet

10 of water sitting on top of that. You have a11 high level of elevation along that. It is not12 going to -- If you fill those few nodes in,13 it's not going to change anything and that14 certainly is reflected when you grossly change15 the whole system to a representation closer to16 what it might have looked like in 1956 in the17 H-3 model, there were very, very insubstantial

18 differences between these two sets of 19 topography. I.e., those -- that micro level20 of detail is not going to make a difference.21 Q. But it isn't accurate. This is not22 -- It is not -- It is not a scientific or23 mathematical certainty that you have filled in24 the MRGO Reach 2 with whatever elevation you25 have done. And whatever the effect of that is

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1 or whatever your estimation of the effect of 2 that is, I guess we can speculate, but we3 don't have an answer to that because we don't

4 know exactly because you haven't -- because5 this picture reflects that there's still some6 of the MRGO in there.7 A. I disagree with that statement. It8 is an engineering approximation to filling in9 a very large extent of the MRGO and it is --

10 it's a very, very little section that might be11 a little open, but that certainly might12 reflect what's adjacent to there right now and13 a lot of the channels that do exist. I mean,14 just take a look in the central wetlands.15 There's all kinds of little low lands and low16 channels, et cetera. So that would be

17 consistent with trying to get a representation18 of what the area might look like with that in19 there. It's all up and down. You can see20 Bayou Bienvenue. You would have had lots and21 lots of little channels all through there. So22 it's a very reasonable representation of what23 the system might have looked like in those24 days.25 Q. To a reasonable degree of

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1 engineering certainty, do you believe that2 other modelers would agree that that would3 have no effect or an insignificant effect?4 A. I -- I can tell you that with my

5 very, very extensive experience, modeling6 thousands of runs, that if you filled that in7 and brought it to 1 and a half feet, there's a8 couple of nodes and there's probably maybe, I9 don't know, 20 nodes or something, 30 nodes in

10 there, if you filled those in you would have11 less than one-tenth of a centimeter difference12 in the storm surge that you computed.13 Q. So the purposes -- My question was14 to a reasonable degree of engineering15 certainty do you believe that other modelers16 would not find -- would agree with your17 perception?

18 A. Certainly modelers that knew what19 they were doing.20 Q. And they would consider that that21 would be insignificant to that?22 A. Yeah.23 Q. Would it have been better if it24 wasn't there?25 A. Like I said, our purpose was to try

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1 to get somewhat of a conservative2 representation of what was there. For3 example, you could argue, hey, look, you

4 shouldn't have filled it to 1 and a half 5 feet. Stuff adjacent to it is kind of 6 greenish, yellowish, et cetera. So we should7 have filled that in there. So we were being a8 little conservative in filling the MRGO more9 than -- than what we -- what we perhaps should

10 have. We left in -- left in probably more11 spoil mounds than we should have. So in the12 whole section to the south there, you know, if 13 you look at the very large swath that we14 filled in in figure 11, that's probably a15 little bit over-conservative in terms of 16 filling it in. Were we a little

17 under-conservative? I really don't think so.18 Again, if you look at what's there in figure19 12, it's very consistent with the sponginess,20 sponginess, sorry, of this system this exists21 there. And again, I can guarantee you that,22 if anything, we were conservative in terms of 23 our representation of filling in that system.24 I.e., we filled it in higher, packed it down25 more than we -- than would have been probably

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1 the case in 1956. And that certainly is2 reflected when you compare to figure 18, you3 know. You look there and it's -- it's -- yes,4 it's overall just a little bit higher because

5 presumably you had a little bit healthier6 marshes, but in general it's again, a very7 spongy system and the filling in of the MRGO8 that we did is -- was overly conservative, was9 more conservative, over 90 percent of the MRGO

10 than it is -- than it should have been, and11 certainly substantially higher than what it is12 in figure 18.13 By the way, am I loud enough for14 you guys?15 MR. SMITH:16 What?17 (Whereupon a discussion was held

18 off the record.)19 VIDEO OPERATOR:20 Off the record, 4:15.21 (Recess.)22 VIDEO OPERATOR:23 Returning to the record, it's24 4:32.25 EXAMINATION BY MS. GILBERT:

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1 Q. Is there such a field as forensic2 engineering?3 A. There is. I am not tremendously

4 familiar with it. I think it's probably more5 in the structural community.6 Q. Do you know if there was ever an7 analysis, an engineering analysis done of the8 LPV system and/or the MRGO channel after9 Katrina?

10 A. In what context?11 Q. In the context of forensic12 engineering analysis of whether or not it --13 how it failed and why it failed and cause and14 origin analysis?15 A. Well, certainly, you know, in that16 sense, IPET probably could be classified as a

17 forensic study to try and understand what18 happened to the system, why it happened, under19 what conditions it happened, certainly.20 Q. And so your conclusions for IPET21 would be your understanding of the only cause22 and origin investigation of the MRGO and the23 LPV system in relation to Katrina?24 A. Could you repeat that question? My25 conclusions would be --

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1 Q. And so your conclusions for IPET2 would be your understanding of the cause and3 origin investigation of the MRGO and the LPV4 system in relation to Katrina?

5 A. So you're saying my conclusions6 would be the same -- my understanding of the7 failures in the Katrina system would be those8 reached during -- in the IPET?9 Q. Yes. Is that correct?

10 A. Yeah. Well, you know, my11 contribution to IPET, of course, was very12 narrowly focused in the area of my expertise.13 That's long wave modeling. I do circulation,14 surface elevation, current modeling. And15 having -- I have extensive interaction with16 the wave team and the geo -- some with the17 geodetic team, some of the other teams, but

18 certainly what I heard during IPET had -- had19 in my mind very high quality conclusions as to20 what happened. And so I would certainly put21 an extremely high level of credence in the22 IPET conclusions in terms of the various23 failure modes and mechanisms that occurred.24 Even though I, in many portions of that, I was25 a casual observer.

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1 Q. With specific regard to what caused2 the breaches in the levees, do you know if 3 there was ever a forensic cause and origin

4 analysis as to the breaches themselves?5 A. You would have address that with the6 people that looked extensively at the7 breaching.8 Q. Have you heard of the ILIT Team9 Louisiana analysis, investigation of the

10 Katrina event?11 A. I have.12 Q. Would you characterize those as13 forensic investigations of the cause and14 origin also?15 A. I have not looked extensively at16 those. I -- It was a much smaller scale study

17 with much more limited number of people that18 looked at that, so I am not either very19 familiar with the study, nor its conclusions.20 Q. Were you ever asked to determine21 what caused the levee breaches?22 A. I was not, and I am not an expert in23 that particular area.24 Q. Do you know any of the experts who25 would have -- Withdrawn.

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1 Do you know of an expert who was2 asked to evaluate and determine what caused3 the breaching in the levees?4 A. Certainly. There's the whole IPET

5 team that looked into both the geotechnical --6 the geotechnical aspects of it.7 Q. Okay. I'm going to just go back a8 little bit and clean up some of the other9 stuff, and I think we're heading in the home

10 stretch here.11 Does anything that you did in this12 study that was prepared in response to the13 Robinson litigation deal with the effect of 14 waves breaking on levees and dumping water?15 A. In what we did --16 Q. You. Your team.17 A. What we specifically did for DOJ, we

18 did not account for waves breaking on levees.19 That was done downstream. We certainly did20 account for waves breaking in wave breaking21 zones that come before -- in front of the22 levees, away from the levees, that would have23 pushed water levels higher adjacent to in and24 around the whole hurricane protection system.25 Q. And in what part of the report did

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1 we discuss today would reflect that?2 A. Well, wave radiation stresses.3 Q. Did anything in your study that you

4 prepared for the DOJ in response to this5 litigation model incorporate the features of 6 wave setup in with regard to time of 7 regeneration of waves?8 A. So again, what we did is we -- we9 absolutely considered wave radiation

10 stress-induced setup. You can see in various11 documents that we've produced that in our12 estimates, that produces about 1 and a half to13 3 foot lift in and around the hurricane14 protection system. And that is an important15 process to consider. Otherwise, you'd be 116 and a half to 3 feet lower. The regeneration

17 of the waves would be considered in the wave18 models. So if you, for example, had a19 scenario where you were breaking waves and20 then you might have in a back bay that gets,21 or a back bay area or a floodplain that gets22 inundated and you have a significant breaking23 zone between the open water and that flooded24 floodplain, the wave models would certainly25 generate waves in those areas. So there would

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1 be regeneration. Once those waves break again2 at the shorelines of the -- or where the3 topography is such that it gets sufficiently4 shallow, there would again be wave radiation

5 stresses that would be generated and that6 would again give you additional lift of the7 water locally.8 Q. Okay. And that's reflected in the9 analysis, the wave radiation also?

10 A. The wave radiation stresses, it11 certainly is.12 Q. And would the calculations that you13 depicted in your report, if they were -- once14 you checked the data, if you conclude that the15 data that you used for the elevations in the16 Mannings coefficient was off or the topography17 was incorrect and you come back and you advise

18 us of what the data actually reflects, would19 that affect the height of the surge in any way20 that you've calculated in these reports?21 A. Could you be more specific?22 Q. Well, we've talked about the fact23 that there's some -- that you're not -- the24 Manning coefficient numbers are not25 necessarily -- you're not quite -- you're not

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1 aware of which Manning coefficient numbers2 were used.3 A. Actually, that's not correct. I am

4 aware of which Manning because based on the5 Dutch comments on our report, we went back and6 looked up and checked out which Manning7 coefficients we did use, and that's reflected8 in the figures in this report. So I think we9 can provide you with the exact ones that were

10 established and used, and I think that's the11 assertion of that question.12 Q. Okay. And with regard to the swamp13 calculation of wetland forests that we've got14 some ambiguity on whether or not -- what the15 characterization that was used by Baras on16 that report, when you figure out whether --

17 when you get the data on that, that could18 affect the surge elevation, the maximum surge19 elevation rate that you concluded in these20 results?21 A. So in -- in my opinion, it may have22 a small effect in run H-4. In none of the23 other runs.24 Q. Okay.25 A. Because the swamp, that swamp simply

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1 did not extend out beyond there. So certainly2 if Mr. Baras were to say that we did it all3 wrong, that we did it incorrectly, that we had4 too low of a characterization, we could

5 certainly redo that run.6 Q. Can we look and can you show me how7 you can tell that non-fresh marsh was8 calculated in fact at .04 instead of .05 or,9 more specifically -- well, the more relevant

10 section would be forest at .14 instead of 11 .045.12 A. Well, you would have to essentially13 go and look at the different classifications14 on, what was it, figure 55?15 Q. Okay. We'll go to figure 55.16 A. Okay.17 Q. That's the graph that was based on

18 the personal communications with Baras?19 Okay.20 A. Where are we at here? Okie-dokie.21 So I guess probably a decent set of figures to22 look at is figure 21 and figure 55. Right? I23 guess we really should turn these around,24 shouldn't we, Robin?25 Q. What's that?

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1 A. We should probably put one --2 MR. SMITH:3 A larger scale.

4 THE WITNESS:5 One per page.6 MR. SMITH:7 Yes.8 EXAMINATION BY MS. GILBERT:9 Q. Which ones are you at?

10 A. So how about 20 and 21 and 55.11 Q. Okay.12 A. Okay? So how about we look at the13 non-fresh marsh.14 Q. Non-fresh marsh is brown.15 A. And then we can see the ubiquitous16 little channels and sections that break.

17 Right? Within that non-fresh marsh. It looks18 like they're quite low, maybe .035 or19 something like that. And then we notice that20 the areas that are actually brown are probably21 around .045, I am not sure exactly what they22 are. Right? You see that? And again, I'm23 going to have to update this table to get the24 exact value. So it seems like, you know,25 somewhere in the .045 area probably. Maybe

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1 .05. I'm not sure exactly which one of these2 that would be. And then we go to the swamp3 classification, that's roughly .06.4 Q. You have it as .06. Right?

5 A. Right. In the model.6 Q. Yes.7 A. And --8 Q. I see where you've got it light blue9 in your graph.

10 A. Uh-huh (affirmatively).11 Q. So that would be .06. What about in12 your graph, do you reflect -- how do you see13 the tan representing the fresh marsh in your14 graph?15 A. Okay. So that -- there's a very16 little distinction in there. Right? If you17 look really carefully, there's just a little

18 bit lighter -- lighter shade that's adjacent19 to that little bit blue. You can -- It's very20 hard to see in this color. But I think if we21 brought up an electronic version that you22 could probably see that. So there's a23 distinction there. And that that variability24 in shading certainly follows the thin layering25 that you would see in that picture. Now,

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1 don't forget there is grid scale averaging2 done there. So that would certainly blur3 those lines just a little bit.

4 Q. What would be the green in the Baras5 --6 A. Well, I think we're missing that in7 this particular figure, but do you see the red8 there?9 Q. In your graph?

10 A. In figure 20 you see the two11 blotches of red?12 Q. I see two blotches of red at the13 top, yes.14 A. So those seem to correspond pretty15 nicely with that.16 Q. And those would be calculated as

17 what?18 A. Looks like they're forest of some19 sort, or urban. Probably forest.20 Q. And that would be in your graph as21 --22 A. Those red areas. So those are like23 .16 or something like that.24 Q. Okay. And is that green area that25 runs along the -- Because there seems to be

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1 forest in Barris' little map that runs all the2 way beyond that, those two green blotches down3 along the edge of the orange. Orange4 represents swamp. Then there's a bunch of

5 green along the outer edges of swamp. And I6 just don't see that at all depicted --7 A. I don't either.8 Q. -- in your urban map. So there's --9 and then again, under the second --

10 A. Although that might be -- Let's11 see. Is that out of the zone of influence?12 Q. I thought this whole thing was the13 zone of influence.14 A. That's certainly right. Actually,15 it does pick up. Take a look. Follow down16 the LaLoutre Ridge there. You see that those17 are little red zones right along there.

18 They're right there.19 Q. Wait. I'm not really --20 A. So you see the end of -- You know21 where St. Bernard is? The town of St.22 Bernard? Or follow from the Mississippi River23 across the Chalmette Extension Levee. And24 then you'll pick up the LaLoutre ridge and you25 can see there right along those sections of

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1 the LaLoutre ridge. That's where they are.2 See that?3 Q. I think I am beginning to see them.

4 A. Maybe I can come assist you for a5 minute? That'll save us some time. Let's6 see.7 Right over there (indicating).8 See that? So that if you look at that, we're9 right over in here (indicating).

10 Q. That's that section. What about11 this section? Up at the top.12 A. It probably got inverted somehow13 into that (indicating).14 Q. So this is not easy to see at all.15 I guess when we get some better maps. I guess16 we'll have that.

17 A. That's probably right on top of 18 where that Chalmette Extension Levee -- I19 mean, sorry, the 40 Arpent Levee lies. Which,20 if you look at the 40 Arpent Levee, it's21 sitting on top of -- there's trees sitting on22 top of it. Right? So -- which would be23 interesting to see if back in whatever, 1956,24 it actually had trees on it.25 Q. I just want to run through some --

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1 Did either SO-8, ADCIRC SO-8 or SL-15, to your2 knowledge, reflect land loss maps? Like3 Barris' land loss maps?4 A. Well, SO-8 certainly doesn't. Now,

5 SO-8 was a characterization of the system in6 the early '90s. And certainly SO-8 as it is7 run by some people typically does not have8 Manning end characterization. So certainly it9 would not have any --

10 Q. Variable Manning or any Manning end?11 A. Any Manning end. I mean, it was12 typically run with Chezys.13 Q. It was typically run with Chezys,14 but it had capabilities for Manning end?15 A. It has the capability of Manning end16 if you run it with the right code, and17 certainly we provided the code to people, so

18 it could certainly be out there. But within19 the context of does the versions of the SL-1520 have this capability? Well, we're looking at21 some right in this report.22 Q. How do you reflect the levee heights23 in SL-15?24 A. Okay. They are -- And maybe you25 could be more specific on that question.

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1 Q. Well, all of the levee heights, are2 they reflected at all in your calculations of 3 SL-15, of the surge developing?

4 A. Oh, absolutely. If you didn't have5 levee heights in there -- they're integrated6 as the report explains.7 Q. And they're integrated based on the8 numbers that you have described were obtained9 from the Corps calculations of the last survey

10 that you don't know when was taken of the11 levee heights?12 A. They're incorporated as sub grid13 scale features so they would not be reflected14 in the topography, because they make separate15 plots of what the levee heights looked like.16 And again, the scientific reason behind that

17 is in order to have a finite element mesh that18 could actually faithfully compute flow over19 the top of a relative -- a levee that has a20 substantial amount of vertical in a short,21 relatively small horizontal scale on the order22 of 10 meters would require decimeter scale23 grids and we won't see that for another ten or24 fifteen years or so. For a large25 computational mesh such as this.

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1 Q. In developing the SL-15, did you or2 anyone update the survey data to actually3 include the channel dimensions of the MRGO4 Reach 2 from bank to bank? Or was it just the

5 channel as designed, as originally designed?6 A. Run that by me again. What time?7 Are you talking about the H-5 and H-68 scenarios?9 Q. Either of the scenarios in which you

10 were dealing with the Reach 2 calculation --11 A. So we included Reach 2 and -- and12 either totally eliminating it or we included13 it as it is surveyed today, and we have14 incorporated that based on Corps surveys. And15 -- Or we included it as it was designed as16 per Corps of Engineers design memorandums.17 Q. Which did you use for the purposes

18 of this study? What was the calculation of 19 the MRGO Reach 2? The actual design, a20 survey? Which one or --21 A. All three.22 Q. How do you do them?23 A. All three.24 Q. You just combined all three?25 A. No. All three are reflected in

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1 different scenarios.2 Q. In different scenarios?3 A. So in scenario H-1 it is as it was

4 prior to -- just prior to Hurricane Katrina.5 It was the wide width. So it was a very -- it6 was a much widening MRGO.7 In scenario H-2, H-3, and H-4,8 Reach 2 is entirely eliminated and filled in.9 In scenario H-5 and H-6 it was put

10 in as it was designed as per Army Corps of 11 Engineers design memorandums. And there's a12 similar set or -- not entirely the same, but13 similar set of perturbations on each one.14 Q. Do you know how the survey was15 conducted for the MRGO channel for concluding16 what the actual survey width of the MRGO was

17 from the Corps of Engineers?18 A. For the design?19 Q. No. For as it was.20 A. You'd have to ask the Corps of 21 Engineers.22 Q. Who at the Corps of Engineers would23 have the information about how that channel24 was calculated?25 A. Probably Nancy Powell would be a

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1 good person to check with.2 Q. And she was involved in the actual3 most recent survey of the actual MRGO at the4 time -- prior to Katrina?

5 A. Well, again, I would have to go back 6 and look at our notes, et cetera, in terms of 7 specifying exactly how we did it, but we8 certainly were interested in getting the9 correct width. Right? And that was -- would

10 have been based on Corps engineers and have to11 look the exact date up. We had -- certainly12 have aerial photography to establish the width13 and then we, if I am -- memory serves me14 correctly, we put it in as per the operational15 dredged design that had to be maintained. So16 we made sure it was deep enough and wide17 enough as per the design memo -- design, but

18 then we had the width that was present in --19 Q. What about the depth at the banks?20 Do you have any surveys that show you whether21 it was shallow or what the depth level was at22 the banks, at the widened banks?23 A. I would have to check our notes on24 how we did that exactly. But it certainly is25 a wide system that has -- We made sure it had

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1 the right depth.2 Q. You did, but you just don't know how3 you did it at this point?

4 A. I have to check the notes.5 Q. Okay. Does the study that you6 performed for the DOJ calculate or analyze7 water -- water traveling along the levees with8 the discharge of water along the channel?9 A. Could you clarify?

10 Q. In your analysis of surge -- You11 didn't do any analysis of waves on top of the12 surge, but in calculating your -- in13 performing your models, did you model out the14 distinction in the dynamics of water as it's15 traveling along the levees, in front of the16 levees, not over -- and then, of course, over

17 the levees, but as distinguished from when18 it's farther away from the levees and -- for19 your calculation of surge elevation?20 A. I'm sure we go right up to the21 levees, because the levees are incorporated as22 sub grid scale features, so there's actually a23 small wall there. So if the adjacent topo24 which is represented in the elevations of the25 nodes at that wall would have been inundated,

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1 then we certainly would have been -- as well2 as has frictional Manning end3 characterization, there would certainly be4 computing flow along those levees. Now, does

5 the flow go into the walls? Do we have6 breaches? No. But do we represent it in the7 overall modeling effort and allow water to8 come into the floodplain that would be9 situated adjacent to the levees? Absolutely.

10 Q. And you don't -- you in your study11 did not calculate overtopping rates?12 A. We allowed overtopping, but, as I13 mentioned a couple of times previously, that14 overtopping did not account for levee15 degradation and breaches. It did not account16 for the wave overtopping. And further into17 the system it certainly didn't have the

18 details that are necessary to have a full19 inner -- inner polder type of water level20 calculation.21 Q. And because we didn't calculate22 waves over the surges, we don't know what the23 maximum height of the surge with the wave is24 at any specific time in your study?25 A. Well, you just take the data from --

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1 If you get a little bit away from the levee,2 you take the data of Jane Smith, you certainly3 have an idea of what the waves are like. If

4 you want to know what the wave heights were5 right at the levee, you talk to Don Resio and6 he can tell you also what the wave overtopping7 rates were based on the period and the wave8 heights and the wave characterization right in9 front of the levee system. And then, of

10 course, the baton was passed on to Steve11 Fitzgerald who went and looked at the interior12 drainage.13 Q. And all of that data is dependent on14 the accuracy of the surge height.15 A. Yes, but again, as we pointed out,16 there were -- because of the critical nature

17 of all of this, Bruce Ebersole did make18 appropriate adjustments to correctly19 characterize that, given the nature of this20 hindcasting. And also, of course, they21 breached the levees and did all the things22 that happened during the storm in order to23 capture all of those features.24 MS. GILBERT:25 Just teasing, Robin. I have a

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1 across any channels for this study, although2 we have for other studies.3 Q. Which studies did you do it for?4 A. We've done it for a variety of

5 studies throughout time. But it's, you know,6 --7 Q. Associated with the Katrina event?8 A. Associated with the Katrina event,9 sure.

10 Q. Can you identify for me which11 entities studied -- what was the reason that12 you did it in those cases and that you didn't13 do it in this scenario?14 A. It was a generic look at how much15 water might have come through the channels and16 where the water came from. Basically to back 17 up the general velocity vectors and pictures

18 that were shown in the report.19 Q. Who did you do those studies for?20 A. We -- I did them with Bruce21 Ebersole, just our own curiosity and22 interest.23 Q. So those were not sponsored by any24 Army Corps of Engineers inquiry or the DOJ?25 A. I suppose in a broad sense they

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1 were, but, you know, we look at lots and lots2 of things all the time.3 Q. Did they go into a report of any

4 kind?5 A. They have not gone into any kind of 6 Army Corps report. That's to the best of my7 knowledge.8 Q. Did you study how much water was9 flowing over the levees and the speed that it

10 was flowing over the levees?11 A. We certainly have looked at the12 water velocities going over the top of barrier13 islands, but the water flow over the top of 14 levees, in order to get that accurately you15 really need to include the breaching process.16 And again, the size of the breaches is very

17 important in that for that particular18 calculation. So in order to do that in my19 model, you have to have very high resolution20 and, of course, we need to degrade the levee21 as time goes on. In addition, in terms of 22 putting water into the interior drainage23 system, we need to have the wave overtopping24 rates. And we currently don't internally25 compute them. So it's something that as we

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1 get to more and more integrated codes we2 certainly will be doing, but we have not done3 that for any of these studies.4 Q. And would that information affect

5 your conclusions about -- How would that6 information affect the conclusions about surge7 heights and the timing of surge heights?8 A. You know, there's -- these are9 fairly large channels and large water bodies

10 all the way around. So there probably is some11 effect, for example, in the south side of the12 IHNC that, if you look at the data, our water13 levels are probably a little bit higher there14 than they should be and so there might have15 been some level of drawdown there that's not16 reflected in our model in terms of the17 breaches into the Lower Ninth Ward. However,

18 I don't think, given the data, that it's a19 substantial effect. And again, you have to20 look at the total flow rates going through21 there and the width of these channels and how22 much water is available to come to these23 systems.24 Q. And how do you tell how much water25 is available to go into these systems based on

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1 a hurricane?2 A. They're huge. Even though the3 channels look narrow in these calculations,

4 they're fairly wide. Right? So it's just a5 lot of water in the IHNC and -- and so I -- it6 would be my best engineering based judgment7 that the water levels, based on what we have8 seen, would not be substantially affected by9 some of the breaches. Now, the way to find

10 out, of course, is to model that. But based11 on the hydrographs and the information that I12 have seen, it certainly -- it certainly would13 not be a huge factor.14 Q. And what about the water flowing15 over the levees?16 A. Well, a lot of the water flowing

17 over the levees would have been the Chalmette18 levee facing east towards Lake Borgne. A huge19 amount of water s available to flow over the20 top of the levees there. Tremendous21 frictional resistance as it made its way22 there. So again, my -- And again, the levels23 of overtopping were not massive. It wasn't24 like there was 20 foot of overtopping or 1025 foot of overtopping above the crest of the

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1 levee in most places. So again, there was2 plenty of water out there to feed that system3 and spill into it without substantively4 affecting the exterior -- exterior water

5 levels.6 Q. Well, it's not -- is it as much the7 cresting as the volume of water that's going8 over that would make a difference? Or the9 rate at which the water is going over?

10 Because once it goes over, it's not cresting11 any more. So once it's overtopped, it's12 overtopping. So it doesn't need a 20 foot13 crest; it just needs a volume of water that14 continues to flow and require that it15 overtop. Am I correct?16 A. Yeah, but you have a massive amount17 of water in your overtopping, maybe 1 or 2

18 feet.19 Q. For how long?20 A. You have a huge volume of water21 that's still being driven from the exterior,22 so -- and a huge amount of available water23 there. So again, this could be -- these are24 work that could be done in a calculation. And25 plus, of course, we do have some level of

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1 interior water -- water being supplied to the2 interior of those levees. Right? We do allow3 them to overtop if they get crested right

4 now. So it's not like we keep all the water5 in there. We just don't have the breaches and6 the wave -- wave component to that. But7 again, it would be my guess that, or my8 engineering judgment that the water levels9 exterior to that are not going to change

10 tremendously. And that's just like, for11 example, putting a fairly big spigot like the12 -- like the GIWW/MRGO Reach 2 -- Reach 1/IHNC13 in. Right? That really doesn't do much to14 the water levels in the golden triangle. And15 why not? There's simply so much water out16 there to supply that little area that it's

17 hard to basically -- to drain that area. I18 mean, it's kind of like taking a straw and19 trying to suck the water out of a pool. So it20 all depends on how much water is available and21 how much you can remove within a given time.22 Q. And did you calculate that or do we23 have a calculation in the Defendants' expert24 analysis of how much water was overtopping and25 the volume of water and the rate at which it

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1 was overtopping?2 A. Well, you'd have to talk to all the3 people downstream from us.4 Q. Okay. And did you in your analysis

5 study the force of the water against the6 levees at all? You know, the waves, the force7 of the waves against the levees?8 A. In the studies I have been involved9 in, no. Again, there are various people to

10 talk to about that. The specific person to11 talk to about that would be Don Resio.12 Q. Who developed STWAVE?13 A. Don Resio and Jane Smith.14 Q. And did they do that for the Corps15 of Engineers?16 A. You would have to ask them. But I17 presume largely for the Corps of Engineers,

18 although I am not sure when Don started with19 STWAVE.20 Q. Okay. Do you have any -- or have21 you had any business relationship with Mr.22 Luettich?23 A. Yeah.24 Q. And what is the nature of the25 business relationship you have had in the past

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1 with Mr. Luettich?2 A. Luettich.3 Q. Luettich.

4 A. Rick Luettich.5 Q. Rick Luettich.6 A. I've had a lot, a tremendous amount7 of contracts together, of course, as you can8 see in our vitae. Have done some consulting9 together. So I guess technically we -- we are

10 partners in a consulting firm, although I11 guess we -- I would have to look back the last12 time that we actively worked on projects13 together.14 Q. When did you start a partnership --15 What was the name of the consulting firm that16 you were partners with?

17 A. It's Westerink and Luettich18 Consulting.19 MR. SMITH:20 Engineer creativity there.21 MS. GILBERT:22 Yes. Acme.23 MR. WOODCOCK:24 Almost as creative as the25 lawyers' law firms.

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1 THE WITNESS:2 Some day I'll have a company3 called Westerink, Westerink,4 Westerink, Westerink and Luettich.

5 EXAMINATION BY MS. GILBERT:6 Q. Yes, which we would do.7 A. Yes. I guess you have.8 Q. When did you start this consulting9 partnership request Mr. Luettich?

10 A. You know, I would have to look it11 up, but it's over a decade ago. And then I12 guess I should say that we also, of course,13 have a joint copyright in the ADCIRC code. So14 we share in some of the fairly minor royalties15 that are generated off of that through some16 third parties that sell the code.17 Q. Do you happen to know whether STWAVE

18 is widely used outside of the Corps?19 A. You'd have to ask Don Resio and Jane20 Smith. I know it's a very well respected21 code.22 Q. Did you calculate -- Is there -- Did23 you calculate or can you calculate through24 STWAVE how much water is moved -- was moved25 through the channels during the storm? The

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1 volume of water?2 A. Through STWAVE?3 Q. Or was there a program that, or did

4 you study -- did anyone on your team study the5 volume of water that moved through the6 channels during the storm?7 A. Certainly it can be done. ADCIRC8 does it. I mean, it has that information. We9 didn't specifically for this study look very

10 closely at it. And if I recall correctly, we11 have in the past looked at some of those12 details.13 Q. Did you keep a record of it when you14 did?15 A. I'd have to look that up. We might16 have had some internal reports on that.

17 Q. And that would have been within your18 group, or would that have been within a19 different group?20 A. It probably was done partially21 within my group with some Dutch engineer --22 with a Dutch engineer that has worked for me23 in the past. And probably in cooperation with24 Bruce Ebersole.25 Q. Would that have been done with the

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1 Delft studies that you were working on, or did2 he just also happen to be Dutch?3 A. We actually worked with -- well,4 several Dutch companies including Arcadis, but

5 also we've had other Dutch companies send6 people to our lab to help out.7 Q. So, --8 A. Again, --9 Q. -- you have that data, when would

10 you have done that study? Do you recall?11 A. Probably one to two years ago range,12 somewhere like that, to the best of my13 recollection. Again, we're, you know, very14 interested in a lot of these periphery issues15 that never made it to the top of the agenda or16 specific studies, but we casually look at it.17 Q. And I know that you explained that

18 you didn't study the overtopping rates, but19 did you study the flow or the weir over the20 levees, or is that --21 A. Can you clarify?22 Q. The volume of water that went over23 the levees.24 A. No, I think we certainly computed25 the volume of water over the levees, but I

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1 believe I mentioned that that's not correct2 because it doesn't have a breach and wave3 overtopping. So people downstream from us

4 would be doing that much more accurately.5 Q. I'm going to the end of your6 report. Does the report as you produced it7 accurately reflect your opinions as to the8 impact of the MRGO on -- Actually, I am going9 to ask you a little bit about -- of the MRGO

10 on English Turn and Braithwaite? I know I am11 not saying that properly.12 A. Braithwaite.13 Q. Okay.14 A. Sure. I mean, I think there's -- We15 have a lot of experience developing and16 understanding about that.

17 Q. And does the report that you have18 produced, as it's produced today accurately19 reflect your conclusions to a reasonable20 degree of engineering certainty about the21 impact of the MRGO on marshes and waters to22 the east of the St. Bernard polder?23 A. It does.24 Q. And does your report as it's been25 produced today reflect your conclusions to a

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1 reasonable degree of engineering certainty of 2 the impact of the MRGO between Paris Road and3 Seabrook?4 A. It does. I think everything that I

5 say makes sense and has a reasonable -- has a6 -- you know, is basically common scientific7 sense and I think the Delft review certainly8 reflects that as well. I think they9 specifically state that they agree with the

10 opinions in the report.11 Q. I'm going to ask you -- I just want12 to review one last thing with you.13 MS. GILBERT:14 Here you go, Robin.15 MR. SMITH:16 For me?17 MS. GILBERT:

18 A present. (Counsel hands19 document to Counsel.)20 (Whereupon a discussion was held21 off the record.)22 MS. GILBERT:23 Just go off the record a second24 while I look here.25 VIDEO OPERATOR:

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1 Off the record, it is 5:29.2 (Recess.)3 VIDEO OPERATOR:

4 Returning to the record, it is5 5:34.6 EXAMINATION BY MS. GILBERT:7 Q. Did you assist or consult with the8 Fitzgerald in the interior drainage team in9 developing models for the water levels in the

10 Lower Ninth and St. Bernard area?11 A. I did -- would say I did not12 assist. We certainly provided the data for13 his models and we certainly throughout IPET14 communicated and knew what each other was --15 each team was doing, and certainly we have16 tried to keep on the same page at the

17 interfaces for this particular study as well.18 Q. But you did not run any of his other19 modeling for him?20 A. He's not run our models, we haven't21 run his models. However, obviously we both22 have substantial interest in each other's23 models and substantial respect for each24 other's work.25 Q. What is your opinion and conclusion

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1 with regard to the impact of the constructed2 levees in and around the golden triangle with3 regard to topographical features and as4 conduits for storm surge propagation inland?

5 A. Well, I think the broad based answer6 to this is you put a levee in shallow water,7 it's going to collect water, or into a shallow8 coast. So levees are features that stop water9 and allow water to build up. So if you look

10 at a large variety of studies that have been11 done over the last four years, if you12 essentially stick something in the water,13 north, south, east, west, it will absolutely14 collect storm surge. So there can -- these15 can be natural features, i.e., river banks or16 bayous that have been created through nature's17 reworking of sediments in water or they can be

18 man-made features. I think a nice example is19 probably the highest water levels in and20 around Louisiana, or the potential for the21 highest water levels are at English Turn.22 It's a natural trap that in fact focuses very23 heavily, more so than the golden triangle, the24 water levels. So certainly constructing a25 levee puts you in a position that you're

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1 stopping water and obviously you are keeping2 water out of somewhere and so you're building3 it up elsewhere on the outside of the levee.

4 In terms of the specific details5 of the golden triangle area, in regards to6 Katrina I think our simulations nicely show7 that that does lower water levels a little bit8 in some parts of the system, but the water9 levels up on the 40 Arpent Levee were about

10 the same as they were on the -- on the11 Chalmette levee. I.e., you're dealing with12 very, very similar water levels. It makes13 sense. The winds in that part of the system14 in the water was coming out of the northeast,15 so it just happened to travel a little bit16 further before it was stopped.

17 Q. How high are the levees along the18 English Turn area, or the banks of the English19 Turn area?20 A. I would have to look that up, but21 best guess, 18 feet or something, 20 feet.22 Plus or minus. But again, I'd have to check 23 our models.24 Q. Is that like an average, your25 recollection of the average of the banks, or

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1 is that --2 A. I'd have to look that up.3 Q. And what is your opinion with regard4 to wetlands influence on reducing storm surge

5 potential?6 A. Okay. I have some pretty well7 defined opinions on that which have been8 published in Physics Today, which is one of 9 the premier magazines in physics. And that is

10 that generically, depending on the track,11 depending on the geographic configuration,12 there can be some attenuation of storm surge.13 Are you catching what I am saying14 or do I need to stop? I'm hearing a huge15 rustling. But that's probably my volume.16 But anyway, but in regards to17 eastern Louisiana, I think that the

18 configuration of the Continental Shelf, the19 orientation of the levee systems and river20 banks, which are essentially facing east, the21 very sustained easterly winds that you can22 have in that part of the system would suggest23 that the marshes are not effective for most24 storms, for many storms, in attenuating storm25 surge. And the reason is that they tend to

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1 slow water down in getting there, but because2 of the nature of the sustained easterly winds,3 instead of just the fast southerly winds

4 pushing up water into the system, that they5 are not effective in ultimately stopping the6 water from getting there. I.e., you blow the7 water long enough, it's going to get there.8 There's nothing to stop it until it hits a9 levee. And that in combination with there

10 being nice levees to stop things along11 Plaquemines, as well as along -- along New12 Orleans East, as well as along the river,13 would bring me to the conclusion -- would14 suggest that they're not an effective15 mechanism. And I think that's very clear when16 you look at that English Turn and Braithwaite

17 were inundated by roughly 11 feet of water18 during Hurricane Gustave, a Category 2 or19 perhaps a very weak Category 3 storm that20 tracked 75 miles to the west of the area of 21 concern. And so it -- And Caernarvon marsh is22 a -- well, is very clearly a marsh that's out23 there and it did not attenuate the storm24 surge. And I think the example that I give in25 the report in Texas, over the Bolivar

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1 peninsula, again, is a very cautionary note on2 this number that has been floating out there3 for a long time that -- such as attenuating so4 many feet per mile of marsh. So I think

5 that's a very over-simplistic analysis of a6 very complex process, and if you have a7 detailed understanding of the conservation8 momentum equations, you would never draw that9 conclusion.

10 Q. All right. I think we've exhausted11 most of the questions that I have that can be12 answered with the information that we have,13 and we have some questions -- we have some14 outstanding requests for documents that might15 assist us in some revisions.16 A. Okay. You're going to provide those17 to us?

18 Q. They're in the record and I am sure19 it will get -- we'll write it out also. Some20 of them have already been requested. But I'm21 going to thank you for your time.22 A. Okay. And just to put on the record23 that we will provide corrections of -- of 24 things that are either typos or incorrect in25 the report.

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1 Q. All right.2 MR. SMITH:3 I have no questions of the

4 witness.5 VIDEO OPERATOR:6 We're now off the record. It's7 5:46.8 * * *9

10

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1

2 WITNESS'S CERTIFICATE3

4 I, JOANNES WESTERINK, read or have5 had the preceding testimony read to me, and

6 hereby certify that it is a true and correct7 transcription of my testimony, with the8 exception of any attached corrections or9 changes.

10

11

_____________________12 (Witness' Signature)13 ____________

DATE SIGNED14

15 DEPONENT PLEASE INITIAL ONE:16

_____ Read with no corrections17

18 _____ Read and correction sheet attached19

20

DATE TAKEN: JANUARY 28, 200921

22

23

24

25

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1

2 REPORTER'S CERTIFICATE3

4 I, ROGER D. JOHNS, RMR, RDR, CRR,5 Certified Court Reporter, do hereby certify6 that the above-named witness, after having7 been first duly sworn by me to testify to the8 truth, did testify as hereinabove set forth;9 that the testimony was reported by me in

10 shorthand and transcribed under my personal11 direction and supervision, and is a true and12 correct transcript, to the best of my ability13 and understanding; that I am not of counsel,14 not related to counsel or the parties hereto,15 and not in any way interested in the outcome16 of this matter.

1718

1920 ROGER D. JOHNS21 CERTIFIED COURT REPORTER22 STATE OF LOUISIANA23

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