KTR00193

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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

NO. 06-2268
MAG. WILKINSON
VIDEOTAPED DEPOSITION OF
JOHN ASHLEY BARRAS,
5928 River Bend Boulevard, Baton Rouge,
Louisiana 70820, taken in the Offices of the
Department of Justice, 400 Poydras Street,
Suite 900, New Orleans, Louisiana, on Friday,
February 6, 2009.
JOHN BARRAS February 6, 2009
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2 APPEARANCES:
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4 LAW OFFICE OF JOSEPH M. BRUNO
BY: SCOTT JOANEN, ESQ.
5 855 Baronne Street
New Orleans, Louisiana 70113
6 ATTORNEYS FOR PLAINTIFFS LIAISON
COMMITTEE
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8 GILBERT LAW FIRM
BY: ELISA GILBERT, ESQ.
9 325 East 57th Street
New York, New York 10022
10 ATTORNEYS FOR PLAINTIFFS
11
SHER, GARNER, CAHILL, RICHTER, KLEIN &
12 HILBERT
BY: MATTHEW CLARK, ESQ.
13 909 Poydras Street
Suite 2800
14 New Orleans, Louisiana 70112
ATTORNEYS FOR PLAINTIFFS
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16
UNITED STATES DEPARTMENT OF JUSTICE
17 BY: KARA MILLER, ESQ.
SARAH K. SOJA, ESQ.
18 Torts Branch, Civil Division
1331 Pennsylvania Avenue NW
19 Room 8095N
Washington, D.C. 20004
20 ATTORNEYS FOR UNITED STATES OF
AMERICA
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22 UNITED STATES ARMY CORPS OF ENGINEERS
BY: JENNIFER LABOURDETTE, ESQ.
23 7400 Leake Avenue
New Orleans, Louisiana
24 ATTORNEYS FOR USACE
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JOHNS PENDLETON COURT REPORTERS 800 562-1285
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2 APPEARANCES CONTINUED:
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VIDEO BY: Ken Hart
5 Hart Video of Louisiana
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8 REPORTED BY: ROGER D. JOHNS, RMR, CRR, CSR
Certified Court Reporter,
9 State of Louisiana
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1 S T I P U L A T I O N
2
3 It is stipulated and agreed by and between
4 counsel for the parties hereto
5 that the deposition of the aforementioned
6 witness is hereby being taken under the
7 Federal Rules of Civil Procedure, for all
8 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 the
12 form of the question and the responsiveness of
13 the answer, are hereby reserved until such
14 time as this deposition, or any part thereof,
15 may be used or sought to be used in evidence.
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17 * * * *
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19 ROGER D. JOHNS, RDR, CRR Certified Court
20 Reporter, for the State of Louisiana,
21 officiated in administering the oath to the
22 witness.
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1 I N D E X
2 PAGE
3 Exhibit 1.................................. 11
4 XJB-001...50.............................. 100
5 Exhibit 55................................ 130
6 XJB-00127................................. 160
7 XJB-119 through 122....................... 161
8 XJB-033................................... 163
9 XJB-100................................... 165
10 Exhibit Number 2.......................... 174
11 2, 3, 4................................... 175
12 Exhibit 3 and 4........................... 176
13 Exhibit 3 and 4........................... 176
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1 VIDEO OPERATOR:
2 This is the videotaped deposition
3 of John Barras. This deposition is
4 being taken In Re: Katrina Canal
5 Breaches Consolidated Litigation in
6 the Robinson case. We're at 400
7 Poydras Street, Suite 900, in New
8 Orleans, Louisiana. Today's date is
9 February 6, 2009.
10 The Court Reporter is Roger
11 Johns.
12 Would Counsel please introduce
13 themselves.
14 MR. JOANEN:
15 Scott Joanen with the Law Offices
16 of Joseph M. Bruno along with Elisa
17 Gilbert of the Gilbert Law Firm for
18 the Plaintiffs.
19 MS. MILLER:
20 Kara Miller for the United
21 States.
22 MS. SOJA:
23 Sarah Soja for the Department of
24 Army and the United States.
25 MS. LABOURDETTE:

7
1 Jennifer Labourdette for the U.S.
2 Army Corps of Engineers.
3 VIDEO OPERATOR:
4 Thank you. Would the Court
5 Reporter please swear in the witness.
6 JOHN ASHLEY BARRAS,
7 5928 River Bend Boulevard, Baton Rouge,
8 Louisiana 70820, after having been duly sworn
9 by the before-mentioned court reporter, did
10 testify as follows:
11 EXAMINATION BY MR. JOANEN:
12 Q. Good morning, Mr. Barras. My name
13 is Scott Joanen. I'm an attorney for the
14 Plaintiffs. I'm here to ask you questions
15 relating to your involvement with the Corps of
16 Engineers and Department of Justice in
17 producing an expert report which has been
18 provided to us dated December 22nd, 2008.
19 Let me ask you first, have you
20 ever given a deposition before?
21 A. I have, but it was -- I am trying to
22 remember. It was concerning oyster suit
23 litigation with the State. Probably over ten
24 years ago. 1998, say, '97, something like
25 that.

8
1 Q. And what was your involvement with
2 that deposition?
3 A. I was providing geographic
4 information support for the attorney hired by
5 the State to defend the State in the lawsuits.
6 Q. The way a deposition works is it's a
7 pretty informal process where I get to ask you
8 questions and you give answers. The Court
9 Reporter is taking everything down and he's
10 going to produce what's called a deposition
11 transcript. It's a booklet, if you would, of
12 all the things that are said, so the most
13 important thing we want to try to do is to
14 make sure that the Court Reporter is able to
15 get everything down clearly. Do you
16 understand that?
17 A. Yes.
18 Q. One of the things that's important
19 for you to know, of course, is that this
20 deposition transcript may be used at a later
21 date. You have been sworn, so you're under
22 oath. It's as if you were in Court, so you're
23 expected to give honest and accurate answers
24 to the best of your ability. Do you
25 understand that?
9
1 A. I understand.
2 Q. I am going to be asking you
3 questions and I would like you to allow me to
4 let me finish my question before you give me
5 an answer. That way, the Court Reporter gets
6 down the question accurately. Then you give
7 your answer. And then I'll try as best as I
8 can to not talk over you and allow you to give
9 your full answer. Do you understand that?
10 A. Yes.
11 Q. One of the difficulties we have in
12 everyday life, of course, is that we start to
13 anticipate someone's question. You may just
14 be nodding your head as is a "yes" and not
15 actually verbalize the word "yes" if that's
16 what you want your answer to be. So it's
17 important for you not to nod your head or
18 shake your head or shrug your shoulders or say
19 "uh-huh" or "uh-uh", because it's important
20 that the Court Reporter get down accurately
21 what it is. So we don't want there to be
22 confusion in the future that you actually
23 meant "yes" or "no", whatever it would be. So
24 I ask you to verbalize your response. Okay?
25 A. I understand.

10
1 Q. If at some point you -- you know,
2 during the course of the day we may get a
3 little lazy and you maybe talking over me
4 before I finish my question or if I tell you I
5 need an answer, like "yes", I am not trying to
6 berate you. I'm trying to make sure that I
7 keep everything as easy for the Court Reporter
8 as possible. He's the one here doing the
9 hardest amount of work. Okay?
10 A. Okay.
11 Q. This deposition transcript will be
12 made available to you after the deposition, in
13 which you can read and sign it. That's
14 something you will discuss with your
15 attorney. Do you understand that?
16 A. Yes.
17 Q. Okay. Also, too, we are not in a
18 race here. I am not going to try and force
19 you to sit here for extended periods of time
20 without having breaks, so if you feel you need
21 to take a walk, if you need to take a restroom
22 break, get some water, that's fine, for any
23 reason. The one thing I'll ask is that if
24 there's a question pending, you finish the
25 question, or give me the answer before we take
11
1 the break. Can you do that for me?
2 A. Yes.
3 Q. I don't have a curriculum vitae of
4 yours in front of me. Have you obtained a
5 Ph.D.?
6 A. No.
7 Q. So if I refer to you as Mr. Barras,
8 that's appropriate?
9 A. Yeah, that's fine.
10 Q. Okay. I'm going to show you what
11 we've marked as Exhibit 1, which is a Notice
12 of Deposition. Do you have that in front of
13 you?
14 A. Yes, I do.
15 Q. This notice is also an amended
16 notice which we have because the address was
17 changed to here. But I want you to focus on
18 the top document, which is the Notice of
19 Deposition, and look at Exhibit A, which is
20 three pages into that document.
21 Have you ever seen, prior to right
22 now, seen this Notice of Deposition and the
23 attached Exhibit A?
24 A. Yes, I have a copy.
25 Q. Okay. And when did you receive a
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1 copy of your Notice of Deposition with the
2 Exhibit A attached?
3 A. This morning.
4 Q. Have you had a chance to review
5 Exhibit A to determine whether in fact you
6 have any of the documents that have been
7 requested to be produced?
8 A. Yes.
9 Q. Okay. What documents have you
10 produced? And we can start with number 1.
11 A. Well, I have my report.
12 Q. Okay.
13 A. Let's see.
14 MS. MILLER:
15 And I'll object to the extent
16 that many of these things request
17 items protected as privileged pursuant
18 to the agreed protective order in the
19 case.
20 MR. JOANEN:
21 And which ones would those be?
22 MS. MILLER:
23 Communications with Counsel;
24 preliminary drafts; with Mr. Barras,
25 there is no engagement letter. I

13
1 guess that's the primary ones.
2 MR. JOANEN:
3 Okay.
5 Q. So is what Counsel said correct?
6 There's no engagement letter?
7 A. No.
8 Q. Okay. And why would that be?
9 A. I don't -- I don't understand you.
10 Q. How is it that you first became
11 involved in this litigation?
12 A. I was contacted by the Counsel I
13 think approximately a year or so ago, and
14 concerning habitat analysis. I think I was
15 recommended by Corps employees who would do
16 that work for -- the USGS normally does that
17 work for.
18 Q. Do you remember who it was that
19 contacted you?
20 A. It was Kara.
21 Q. And do you remember how it was she
22 contacted you? Was it by written letter or
23 was it by telephone call?
24 A. I think it was telephone call. It
25 was over a year ago. I don't remember well.

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1 Q. Was it less than two years ago?
2 A. Yes.
3 Q. So less than two years ago, but more
4 than one year ago Kara Miller contacted you,
5 correct, for this litigation?
6 A. That's to the best of my
7 recollection.
8 Q. To your knowledge, had you discussed
9 your potential involvement with the Department
10 of Justice in this litigation prior to Kara
11 Miller --
12 A. No, I hadn't heard of this
13 litigation prior to Kara Miller contacting me.
14 Q. When you spoke with Mrs. Miller, and
15 I am not going to ask you what she told you, I
16 would like to know what your understanding of
17 what your job duties and responsibilities were
18 going to be in fulfilling whatever requests
19 Ms. Miller presented to you.
20 A. It was actually very simple. To
21 provide the same type of analysis that I would
22 generally, or my staff would generally provide
23 to the Corps of Engineers with regards to land
24 loss and habitat analysis for wetland
25 restoration project planning.

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1 Q. Regarding land loss analysis, and
2 what was the next one?
3 A. And habitat analysis, just basic
4 marsh types.
5 Q. Had you provided this type of
6 service to the Corps of Engineers prior to
7 Miss Miller contacting you?
8 A. Yes, we had been providing this
9 information to the Corps in the Coastal
10 Wetlands Planning Protection Restoration Act
11 Task Force since 1993, 1994.
12 Q. Did Miss Miller provide you with any
13 documentation resulting from that first
14 telephone conversation you had with her that
15 you would utilize to begin to formulate your
16 opinions?
17 A. No, not really. I was asked to do
18 the habitat, the change analysis and that was
19 about it.
20 Q. Did you know, when she asked you to
21 do a change analysis, what areas of the world
22 you would be examining for change analysis?
23 A. It was in the vicinity of the MRGO.
24 The Mississippi River Gulf Outlet.
25 Q. "Vicinity" can be a pretty ambiguous
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1 term. What was your understanding of the
2 vicinity of the MRGO that you were going to be
3 studying?
4 A. I actually wasn't certain until
5 receiving the expert reports from I think Shea
6 Penland or Duncan Fitzgerald as to the actual
7 area of interest.
8 Q. Prior to receiving Shay Penland's
9 expert report, had you performed any work in
10 preparing your opinion for this litigation?
11 A. No.
12 Q. Prior to receiving Shay Penland's
13 report, did you receive any draft copies of
14 expert reports from Defendants' experts?
15 A. No.
16 Q. Moving on down the list, --
17 A. Sure.
18 MS. MILLER:
19 Just to clarify 1, I said there's
20 no engagement letter, we may have
21 exchanged emails over the course of
22 his work on this litigation, but an
23 official engagement letter --
24 MR. JOANEN:
25 And it's your position you don't

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1 have to produce those?
2 MS. MILLER:
3 Yes.
5 Q. Okay. Number 2, have you brought
6 anything responsive to that request?
7 A. Would you explain what a deponent
8 is?
9 Q. You.
10 A. Okay.
11 Q. You are the deponent.
12 A. Yes, I provided my -- the file, the
13 complete file.
14 Q. And so the information provided to
15 us in the expert report is your complete file?
16 A. That's it.
17 Q. Okay.
18 A. And an accompanying spreadsheet that
19 went with it that contained detailed area
20 table information.
21 Q. Okay. How about number 3?
22 A. I don't have copies of that with
23 me. I would assume that the Department of
24 Justice would keep copies of that.
25 Q. Was the spreadsheet you mentioned,
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1 was that produced to the Plaintiffs?
2 A. I transferred it to the Department
3 of Justice. I assume so.
4 MS. MILLER:
5 It was produced.
6 THE WITNESS:
7 Where are we at?
9 Q. Number 3, copies of correspondence
10 including emails, communications with
11 Counsel.
12 A. I don't have -- I don't have a
13 complete record of that. I would assume it's
14 --
15 MS. MILLER:
16 And again, that's -- copies of
17 correspondence with Counsel are
18 protected.
20 Q. Number 4, copies of preliminary
21 drafts. Have you brought those with you?
22 MS. MILLER:
23 Again, --
24 THE WITNESS:
25 I didn't have preliminary
19
1 drafts. That report is it.
2 MS. MILLER:
3 And also, to the extent there are
4 drafts, those are privileged under the
5 protective order.
7 Q. Number 5, a copy of any and all
8 documents and photographs reviewed and relied
9 upon by the deponent in this case. What
10 documents have you reviewed and relied upon?
11 A. I have reviewed Shea Penland's
12 expert report, Duncan Fitzgerald's amendment I
13 guess or when he took that over after Shay
14 passed.
15 Q. Can you give the dates for those
16 reports, Penland's?
17 A. September -- Well, this is the older
18 one, September 15, 2007. And let's see. The
19 Duncan report's all the way at the bottom
20 here. July 11, 2008 for Duncan Fitzgerald.
21 Let's see. John Day, I have the original 2007
22 -- That's Gary Schafer and John Day. And on
23 the CD I think -- I have a CD that has a
24 complete set of reports. I also have the July
25 11, 2008 John Day and Gary Shafer report. And

20
1 what was this -- Oh, and also their
2 supplemental report dated January 27, 2009.
3 Q. Which one was that?
4 A. Here. (Witness hands document to
5 Counsel.)
6 Q. Okay.
7 A. I do have a copy of Dale Britsch's
8 report. I couldn't haul it in my briefcase
9 over here.
10 Q. I see you have a laptop computer --
11 A. Yes.
12 Q. -- in front of you. What is the
13 purpose for having a laptop computer today?
14 A. It actually allows me --
15 Unfortunately, the reproduction of some of the
16 graphs in my report on the hard copy, I can
17 actually pull them up and look at them if we
18 need to.
19 Q. Are you logged onto the Internet
20 here?
21 A. No. No. No.
22 Q. So there would be no communication
23 going to you from outside?
24 A. No. No wireless. It's a standalone
25 completely.

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1 Q. Moving then to number 6, a list of
2 all depositions and trial testimony. You told
3 me earlier you gave a deposition?
4 A. Yeah. That was over -- That was
5 over five years ago.
6 Q. Have you given any trial testimony
7 in your professional life?
8 A. I was -- I actually investigated a
9 child abuse many, many years ago for a short
10 period of time and I testified before a Judge
11 in Thibodaux then, but that was 20-something
12 years ago related to that particular venue.
13 Nothing with my current professional career.
14 Q. Okay. Then moving down the --
15 A. Uh-huh (affirmatively).
16 Q. A copy of all exhibits, animations
17 and/or demonstrative evidence which may be
18 used or relied upon by the deponent at trial.
19 A. I would assume that's contained in
20 the expert reports that I have.
21 8, I have given a resume. I don't
22 know where that's at. You guys should have
23 gotten a copy.
24 MS. MILLER:
25 Yes, that's included in his

22
1 report.
3 Q. Okay. The next one?
4 A. That's funny. I work for the USGS.
5 I received absolutely zero compensation for my
6 involvement in this. This was done gratis.
7 Q. Okay. The maps identifying the
8 points of measurement by latitude and
9 longitude, are those things that you
10 utilized?
11 A. Well, not for water heights. For
12 land -- I do -- I am not a land elevation
13 expert, but the maps I provided are geo
14 referenced, but I did not put a lat-long grid
15 on them. They're actually geo referenced to
16 the UGM coordinate system. But they don't
17 have a grid plotted on them. I had nothing to
18 do with the water. I did not use the water
19 heights or land heights information.
20 Q. The next one down?
21 A. That doesn't involve the work I did.
22 Q. Okay. Turn the page then, number
23 12. Would that involve the work that you did?
24 A. Copies of the -- Yes. I didn't
25 bring all copies. A lot of the stuff is on

23
1 the Internet. You're talking about the
2 references in my report?
3 Q. Correct.
4 A. No, I didn't bring copies of that.
5 Q. Is there anything that is referenced
6 in your report that is not available on the
7 Internet?
8 A. No. They may have some of the older
9 stuff that may be only hard copy.
10 Q. Number 13?
11 A. Again, I did not use high water mark
12 information.
13 Q. Okay. How about number 14, copies
14 of maps and photographs relied upon by you to
15 determine land classifications of the vicinity
16 of the MRGO in 1956?
17 A. I reviewed some photographs of the
18 1956 data supplied by the Corps of Engineers.
19 I did bring copies -- The copies of the maps
20 themselves are included in the expert report
21 for the 1956 habitat data.
22 Q. And you said that was provided to
23 you by the Corps of Engineers?
24 A. No, the habitat -- The photography
25 was, but the habitat maps are data sets that

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1 have been built over the last 20 years. They
2 were originally built by the National Wetlands
3 Inventory -- NWI, National Wetlands Inventory,
4 for the habitat maps.
5 Q. Okay. Number 15, all documents
6 including the exact times for calculations
7 performed by the deponent for --
8 A. I was not involved in the surge
9 simulations.
10 Q. Okay. How about number 16?
11 A. Not a surge expert. No involvement
12 in that.
13 Q. I take it you went to college;
14 correct?
15 A. Yes.
16 Q. And where did you graduate from
17 college?
18 A. B.S. is from Nicholls State
19 University and the M.S. is from Louisiana
20 State University.
21 Q. The B.S., what was it? Was there a
22 focus?
23 A. Geology. M.S. was -- Actually, it
24 was physical geography, but it would have been
25 focused in coastal morphology and then GIS and

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1 remote sensing.
2 Q. When did you get your B.S. from
3 Nicholls?
4 A. 1984.
5 Q. And how about your M.S.?
6 A. '90, I think, or '91 from LSU.
7 Q. From 1984 to 1990 were you in school
8 or were you in the working world?
9 A. I was in the working world for a
10 short period from -- from 1984 through 1985.
11 I re-entered graduate school in the fall of
12 '86. And after that I worked -- I worked for
13 the State for a year or so. Actually for the
14 Louisiana Geologic Survey. Then I worked for
15 the State. Then I switched over to the
16 Federal government in '92.
17 Q. Was there an application procedure
18 that you had to go through to become employed
19 by the Federal government?
20 A. Yes.
21 Q. And can you describe that process?
22 What did you have to do?
23 A. Geez, I don't remember. It's a
24 standard form. I forgot. I don't even know
25 what the form is. It asks you basically your

26
1 life history. You fill it out.
2 Q. What was the position you were
3 applying for?
4 A. Geographer. And I've been a
5 geographer for the remainder of my employment
6 with the Federal government.
7 Q. When you were hired as a geographer,
8 did you have to take any specialized courses
9 to become qualified for that position?
10 A. It was dependent on your education,
11 which basically fell back on the Master's and
12 undergraduate degrees.
13 Q. And what agencies did you become
14 employed by?
15 A. It was originally U.S. Fish and
16 Wildlife Service research arm and it was
17 converted to the National Biological Survey
18 which had a very short lifespan in the mid
19 '90s and then was subsumed by the USGS about
20 '97 or '98.
21 Q. At any time from the time when you
22 started as a geographer until your agency was
23 subsumed by the USGS in '97 or '98, did your
24 job description change?
25 A. No, it was basically doing --

27
1 providing some geographic information,
2 technology for coastal restoration
3 implementation.
4 Q. And since 1997 or '98 when you
5 became subsumed by the USGS, has your title
6 changed other than geographer?
7 A. No. It's remained a geographer.
8 Q. And what is it that a geographer
9 does, in layman's terms?
10 A. Basically looking at the lay of the
11 land, the -- My involvement is more the
12 physical processes. It's mapping of the
13 changes in the landscape.
14 Q. When you change -- When you do look
15 at the mapping of the physical, is that
16 something as simple as taking an old
17 photograph and then having it overlay and
18 figure out what's no longer there?
19 A. Actually, it's not quite that simple
20 as taking an old photograph and overlaying
21 it. You have to go through multiple
22 procedures to make -- to take that photograph
23 to where you can actually quantify and use it
24 to calculate area measurements. But my
25 background has been predominantly in using

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1 existing data sets and then building newer
2 data sets based on satellite imagery to
3 calculate land loss. It's probably been one
4 of my primary interests.
5 Q. Has your job level or job expertise
6 changed with the increasing --
7 A. Yes.
8 Q. -- abilities of the computer
9 technology?
10 A. Yes. I was -- Yes. Well, it was
11 constantly changing. You have to -- You have
12 to kind of keep up with the technology as it
13 advances.
14 Q. When you say existing data sets,
15 what data sets are you talking about?
16 A. Primarily in -- We, for the -- at
17 least my group within the USGS uses, there's
18 -- It's called habitat data sets. They're
19 National Wetland Inventory maps that are used
20 that were developed by the Fish and Wildlife
21 Service for assessing wetland habitats
22 nationwide. These are older programs that
23 existed before I came on with the Federal
24 government. But they are used to -- to assess
25 wetland trends. And the data sets that are

29
1 available in Louisiana consist of 1956, 1978,
2 and 1988. And they basic- -- Each data set
3 basically surmises wetland habitats, basic
4 wetland habitats across the coast.
5 Q. Have you had a chance to review Dr.
6 Britsch's expert report?
7 A. Yes.
8 Q. He, on page 6 of his report --
9 A. All right.
10 Q. -- and we talked about it in his
11 deposition, talks about land loss mapping
12 being conducted.
14 Q. And it results in T sheets. And he
15 indicates that there were data points that
16 start '32, '56, '74, '83, '90, and '01. Are
17 those the data sets that you're referencing?
18 A. No, I actually have another -- The
19 data sets that I use are different than what
20 Dale uses. He has a different methodology
21 where he actually photo interprets loss
22 directly off the aerial photography. The
23 information that we use, or that the USGS
24 uses, or I use is actually consists of
25 habitats. You'll have -- It's basically a

30
1 land cover assess -- identification of a
2 coast, so you'll have fresh marsh,
3 intermediate marsh, brackish marsh,
4 shrub/scrub, swamp forest, different types of
5 habitats. You take that information and you
6 can simplify it to just land and water just by
7 aggregating that coding scheme to a basic
8 land-water. And then with the GIS software
9 you can actually take that information and run
10 area statistics and subtract it, so it's
11 basically a different methodology than what
12 Dale uses.
13 Q. When you talk about evaluate what
14 the different habitats are, what kind of
15 training do you have to understand what the
16 habitats that you're talking about are?
17 A. Professional or just history?
18 Q. Well, let's start with first
19 educational.
20 A. Educational, I am not a wetland
21 vegetation expert. It was more or less more
22 looking at land. My background is geology, so
23 it's more or less looking at the actual
24 physical habitats and the lay of the land.
25 Not necessarily the vegetation. You know, I

31
1 can't go out and tell you all of these
2 different -- all the different species, but I
3 can at least tell you in the broader
4 categories, fresh, intermediate, and brackish
5 marsh. But the actual habitat data was based
6 on people that were experts in wetland
7 vegetation that photo interpreted this
8 information and it's based on a standardized
9 coding scheme. So they have a very complex
10 scheme to identify the habitats. And then you
11 can use that information to -- to aggregate it
12 up into fresh, brackish, intermediate marsh
13 which most people seem to use rather than the
14 detailed stuff.
15 Q. When you say people photo interpret
16 it, does that mean that there was actual --
17 A. I have --
18 Q. You have to let me finish my
19 question.
20 A. I'm sorry.
21 Q. When you say they photo interpret,
22 do you know whether that includes them
23 actually going out to an area, measuring the
24 area with tape measures and photographing it
25 and then say, "Based upon the photographs I
32
1 have taken and the measurements we have taken
2 from point A to point B, this is this type of
3 habitat"?
4 A. Yes. It's actually a very -- a very
5 detailed investigation scheme and a very
6 laborious task that relies on not just one or
7 two people, but many, many people to do this
8 work. And the National Wetlands Inventory has
9 a standard protocol for doing this.
10 Q. And so those data sets that you're
11 referencing, '56, '78, and '88, those are what
12 the National Wetlands Institute would be
13 involved with collecting, measurement,
14 photographs --
15 A. Yes.
16 Q. -- and evaluation?
17 A. Yes.
18 Q. Do you have the expertise to
19 question what their conclusions are about the
20 type of habitat that it is, or do you take
21 that as -- say, for example, you have a folder
22 and everything is fresh marsh and you put that
23 in this folder and then you may plug that into
24 your computer as you see fit.
25 MS. MILLER:
33
1 Objection.
3 Q. Is that how you do it?
4 MS. MILLER:
5 You can answer.
7 Q. Just to tell you how it works, --
8 A. Yeah.
9 Q. -- when the attorneys object, she's
10 going to object for really two reasons. One,
11 if I am asking you something that is
12 privileged information. If y'all have
13 communications, --
14 A. Okay.
15 Q. -- I am not allowed to ask about
16 what your communications are. If I were to
17 ask you something -- And I try and avoid that
18 as much as I can. But if for some reason I do
19 ask you a question that she believes would be
20 impinging upon her attorney-client
21 communication with you, she'll object and
22 instruct you not to answer.
24 Q. There are other times when she's
25 going to object because this deposition record
34
1 may be used later and she is just preserving
2 her objection, that we may have to discuss
3 with the Judge later to determine --
4 A. Okay.
5 Q. -- whether in fact that information
6 can be used at trial or for some other
7 purpose. But because this is a discovery
8 deposition, in Federal court especially, they
9 allow me to get the information so that we
10 don't have a misunderstanding and then I have
11 to ask you to come back. So basically she'll
12 object, but for the most part you can answer
13 unless she instructs you not to answer. Okay?
14 A. Okay. Could you repeat the
15 question? I have forgotten.
16 Q. I should have told you that in the
17 beginning. I apologize.
18 A. Yes.
19 Q. And again, if you don't understand
20 the question, just ask me to repeat it and I
21 can rephrase it. Part of, as he's getting
22 that, part of what in the beginning of a
23 deposition, also so you understand --
24 MS. MILLER:
25 Did you want him to be taking
35
1 down what you're saying now?
2 MR. JOANEN:
3 Sure.
5 Q. Part of what I am trying to do is to
6 understand your vernacular.
7 A. Sure.
8 Q. Obviously I don't have the expertise
9 and training that you do, so I am trying to
10 learn your vernacular so that we can have a
11 more intellectual discourse.
12 MR. JOANEN:
13 That being said, if you can
14 repeat the question.
15 (Requested question read back.)
16 THE WITNESS:
17 I would not question their
18 expertise. They're expert marsh
19 vegetation interpreters.
21 Q. And so then the quality of your
22 product is relying upon the quality of product
23 that's given to you?
24 A. Correct.
25 Q. Would you agree with that?
36
1 A. For those particular data sets.
2 Q. When you proceed from '56 data set
3 to a '78 data set, why was it, if you know,
4 there was such a long delay between those two
5 data sets?
6 A. That's actually a very easy question
7 to answer. It's back in the 1970s and '80s it
8 was very laborious and time consuming to
9 develop one of these coastwide data sets, so
10 you're talking about probably a three to four
11 year effort to develop one of these. And that
12 -- And at the time they just -- people just
13 didn't have the technology and capability to
14 produce one of these data sets every three or
15 four years. So it's really a time-cost
16 dependent issue.
17 Q. And then, of course, '78 to '88 is a
18 ten year period.
20 Q. And has there been a data set in the
21 last 20 years?
22 A. No. The NWI is -- they have not
23 received funding to do nationwide wetland
24 mapping past that point.
25 Q. The data sets that you rely upon,
37
1 the '56, '78, and '88, are those nationwide or
2 are those just regional to southeastern
3 Louisiana?
4 A. The National Wetlands Inventory
5 develops nationwide data sets, but those are
6 specifically -- the ones that I am referring
7 to are colloquially focused on Louisiana.
8 They were developed specifically for
9 Louisiana.
10 Q. Do you understand the area that the
11 MRGO entails to be part of what's called the
12 Lake Pontchartrain basin?
13 A. I understand what the Lake
14 Pontchartrain basin is.
15 Q. Do the data sets from '56, '78, and
16 '88 include the Lake Pontchartrain basin?
17 A. They do.
18 Q. Can you tell me what the Lake
19 Pontchartrain basin encompasses?
20 A. The Lake Pontchartrain basin would
21 encompass from the Mississippi floodplain on
22 the west to the pleistocene uplands on the
23 north, east of the Mississippi River, and it
24 would -- and remained east of the Mississippi
25 River through the southern course to the

38
1 LaLoutre ridge in the Delacroix area, out to
2 Breton Sound and Chandeleur Islands to the
3 east.
4 Q. And does the data sets that you are
5 referencing, '56, '78, and '88, do those also
6 include the barrier islands in Breton Sound --
7 A. They do.
8 Q. -- and Chandeleur Island?
9 I know you said that when you
10 first started preparing yourself for this
11 opportunity to provide an expert report, you
12 started with reviewing the Plaintiffs' expert
13 reports of Shea Penland and Duncan Fitzgerald,
14 Dr. Day. The Shea Penland report is dated
15 September 15th, '07. That was correct? That
16 was one that you had been able to review prior
17 to producing your expert report of December
18 22nd, 2008; correct?
19 A. Yes.
20 Q. The Duncan Fitzgerald was -- the one
21 you had dated was I believe July 11th of --
22 A. Of 2008. I assume Duncan took over
23 after Shay passed.
24 Q. And you reviewed that report also
25 prior to producing your expert report?
39
1 A. Yes.
2 Q. The Day report you had is a 2007.
3 Did you review that one in preparation for
4 your expert report?
5 A. I probably didn't pay as much
6 attention to the Day report, because I
7 actually wanted to focus on the area defined
8 by Penland and Fitzgerald first so I could do
9 the change analysis.
10 Q. Now, you did say that you read a
11 supplemental report of January 27, 2009.
12 Obviously that could not have been reviewed
13 prior to you producing your expert report.
14 Correct?
15 A. No, that would have been after.
16 Q. Do you anticipate, upon reviewing
17 any of the supplemental reports that were
18 produced or that you have reviewed after your
19 December 22nd, 2008 report was finalized, in
20 updating your opinion?
21 A. No.
22 Q. Have you been requested by the Corps
23 of Engineers to provide any analysis of the
24 expert reports produced by the Plaintiffs?
25 A. No.

40
1 Q. You said that when Miss Miller
2 contacted you, that this was the type of thing
3 that you had done for the Corps, you and your
4 team had done for the Corps --
5 A. Yes.
6 Q. -- prior to this? How often would
7 you be engaged by the Corps? And I mean you,
8 I am meaning you and your team.
9 A. We're engaged on a regular basis
10 during the CWPPRA -- They usually have a
11 yearly project screening process where they
12 nominate potential wetland restoration
13 projects and we are -- we are provided with
14 boundaries. Actually, I don't do that any
15 more. My team does that. And they will go
16 ahead and take the boundary information and
17 develop a standard set of habitat maps and
18 change maps and area statistics similar to
19 what was provided in my expert report.
20 Q. When you talk about your team, is
21 that -- are you a member of the team such that
22 you're an equal player, or are you like a
23 manager or --
24 A. I'm a manager of the team.
25 Q. How many people do you supervise
41
1 currently?
2 A. Right now, about ten. Well, let me
3 correct that. I have several contractors that
4 work for me. As a Federal employee, I can
5 only provide technical guidance for the
6 contractors. I cannot supervise them.
7 Q. In your previous efforts with the
8 Corps of Engineers pursuant to CWPPRA, have
9 you provided any analysis providing wetland
10 loss for the Lake Pontchartrain basin?
11 A. No.
12 Q. So the first time -- Is my
13 understanding correct that the first time you
14 provided any land loss analysis or habitat
15 change analysis for the Pontchartrain basin is
16 for this litigation?
17 A. Actually, let me rephrase that. I
18 have a report that's referenced that was
19 produced for the Fish and Wildlife Service
20 that actually looked at land loss rates
21 between 1978 and '90 for all of the hydrologic
22 basins in Louisiana, which would include the
23 Pontchartrain basin, but that -- I think the
24 funding was provided by the Corps. That was
25 the first task I had as a Federal employee.

42
1 But it was just to provide updated area
2 statistics incorporating the 1988 habitat data
3 for the Fish and Wildlife Service.
4 Q. When you do that type of task, are
5 you evaluating the changes from the '56 to '78
6 to '88?
7 A. Yes. Evaluating basic land area
8 changes, land and water area changes between
9 those dates.
10 Q. When you were asked to do that by
11 the Corps and when you did that task many
12 years ago, did you provide any analysis to why
13 the habitats were changing?
14 A. No, our job was basically to
15 provide, as doing it on the GIS then, it was
16 basically to provide the area statistics.
17 Q. And are you -- when you gave that
18 report, are you including with that the
19 habitat changes if they're transgressing from
20 one type of characteristic to another?
21 A. The habitat changes were included,
22 but again, it was basically numerical changes,
23 and the interpretation of those changes were
24 left to the team of Federal scientists that
25 was working on those particular projects.

43
1 Q. And you weren't drawing any
2 conclusions regarding those issues?
3 A. We try not to, because we don't want
4 to steer the opinions. As a matter of fact,
5 most of the -- I'm going to offer this. Most
6 of the work we do for the wetland restoration
7 -- these analyses, these change analyses that
8 we provide, we don't provide interpretation.
9 We provide that information to a team of
10 Federal employees that are from multiple
11 agencies, including the Corps, and they will
12 have long, drawn out meetings trying to
13 determine the causes of change within the
14 proposed project area.
15 Q. On these types of projects where,
16 say, for example, the Corps is trying to
17 determine the cause for the change, is your
18 team ever brought into the discussions to
19 provide information in realtime?
20 A. We -- You can't really call it
21 realtime, because the data is static. I mean,
22 we'll have somebody go in and flash PowerPoint
23 slides or images up on the screen of the
24 habitat data, or, you know, whatever the Corps
25 has requested, or aerial photos. But it's not

44
1 a dynamic realtime where we're drawing stuff
2 and actually calculating stuff on the fly.
3 Q. Have you at any point decided to get
4 a greater understanding of what this lawsuit
5 is all about?
6 A. Not really. No.
7 Q. If I were to ask you to -- Do you
8 have kids?
9 A. Yes.
10 Q. How old is the youngest one?
11 A. Seven.
12 Q. Perfect age. If you had to explain
13 to your child, your seven year old tonight
14 what daddy did and he said, "Why did you have
15 to do that?" and you'll say, "There's a
16 lawsuit", and he says, "Well, what's the
17 lawsuit about?", how would you describe your
18 understanding as you sit here today what the
19 lawsuit is all about?
20 A. From what I can understand, it's --
21 I would assume it's about the levee breaches
22 during Katrina and the flooding that ensued.
23 Q. Have you ever heard in your
24 experiences in producing the export report
25 that this lawsuit was regarding the effect the
45
1 MRGO had on surge and wave heights and the
2 duration of flooding?
3 A. Yes.
4 Q. Where did you hear that?
5 A. It was actually on one of the --
6 Trying to remember which report.
7 Can I describe phone conferences
8 that we had or that I had to sit in on?
9 I had to provide habitat data to
10 Joannes Westerink. He needed the 1956 habitat
11 data. So I had to sit in on one or two calls
12 so they could get the information for that.
13 Q. Was it 1956 habitat data?
15 Q. Do you remember when that telephone
16 conversation was?
17 A. Not really.
18 Q. Was it before or after you -- First
19 let me finish the question. Was it before or
20 after you started putting pen to paper for
21 this expert report?
22 A. It would have been before.
23 Q. When was it that you first put pen
24 to paper to produce this expert report?
25 A. Probably started on -- started

46
1 fleshing stuff out in October of last year,
2 November. That would have been November,
3 because I was pretty busy in October.
4 Q. Of '08?
5 A. Yes. Well, I had done the habitat
6 -- I had done the change analysis earlier,
7 you know, drawing the boundaries and stuff
8 earlier than that.
9 Q. And why did you do that earlier?
10 A. Just trying to catch up and juggle
11 -- juggle projects. I knew this was coming
12 up and it was coming to a head. Reports were
13 going to be due.
14 Q. The telephone conference you had --
15 conversation you had with Dr. Westerink, do
16 you know whether it was summertime before your
17 October, November, '08 commencement of
18 writing?
19 A. I think it was in the summer or so,
20 something like that.
21 MS. MILLER:
22 I'll object to the extent you're
23 asking him to speculate about dates.
24 THE WITNESS:
25 I don't remember.

47
2 Q. I am just trying to draw
3 parameters. I'm not asking for a date or a
4 time. I'm just trying to get an understanding
5 of how it all plays out.
6 So you believe, and you don't have
7 to be precise, you believe it was probably in
8 the summertime of 2008?
9 A. I assume so. I don't remember.
10 Q. And you live in Baton Rouge?
11 A. Yes.
12 Q. Are you a football fan?
13 A. Yeah, I like the Tigers.
14 Q. Was it after last year's football
15 season, the 2007 into 2008 football season
16 that you had your conversation with Dr.
17 Westerink?
18 A. Yeah, it would had to have been
19 sometime.
20 Q. So you think it would have been
21 either spring or summer 200- --
22 A. Yeah, I'd assume more towards the
23 summer.
24 Q. After basketball season for the
25 Tigers?
48
1 A. Not a basketball fan. Yeah.
2 Q. How about baseball? Was it after
3 baseball season?
4 A. Yeah.
5 Q. So it was likely summertime that you
6 spoke to him?
7 A. Yeah, I would assume it was the
8 summertime. I truly don't remember.
9 Q. In the '56 habitat data that you
10 provided to him, you told me that there is, in
11 your data sets, that is, for the whole coastal
12 region, but that there is limited to
13 Louisiana, --
14 A. Yes.
15 Q. -- those coastal sets, did you give
16 him the entire Louisiana region?
17 A. No. It was just the area that was
18 clipped out for the -- I guess it's the
19 Pontchartrain basin and the Breton Sound basin
20 and the Barataria basin. It's -- You guys
21 were provided the data.
22 Q. The Pontchartrain, Breton, and
23 Terrebonne?
24 A. Yeah. No, no, no, no. Barataria.
25 Not Terrebonne. Barataria. To the west.

49
1 Barataria is the next basin, hydrologic basin
2 to the west.
3 Q. Right. I thought you said three
4 though. The Pontchartrain, Barataria --
5 A. And Breton. Breton Sound.
6 Q. Is the data set for Breton Sound
7 different than the Pontchartrain basin?
8 A. No, all you're doing is just
9 clipping out those areas from the source data.
10 Q. Okay. In the areas that were
11 clipped out, who told you that those are the
12 data sets you needed, that Dr. Westerink
13 needed?
14 A. I actually decided on the boundaries
15 myself just based on the -- on the
16 information.
17 Q. What information?
18 A. Fitzgerald. Pen- -- Not
19 Fitzgerald. The Penland information. The
20 only reason the Barataria was included was
21 just to provide some area over to the west of
22 the river. It wasn't used.
23 Q. Did you give Dr. Westerink anything
24 in writing or electronically on that
25 conversation or in preparation for that
50
1 conversation?
2 A. No.
3 Q. The preparation, the parameters that
4 you picked, those come strictly from Shay
5 Penland's report?
6 A. My interpretation of the area.
7 Yes.
8 Q. And were there other data sets
9 available that you could have provided to Dr.
10 Westerink other than the '56 data set?
11 A. His --
12 MS. MILLER:
13 Objection. Vague. I mean,
14 "other data sets".
16 Q. Did you understand my question?
17 A. No, not really. Historical data
18 sets?
19 Q. Well, you told me that there are
20 three. There's -- I mean, it was not a
21 pointed question.
22 A. No, no.
23 Q. It was a lead-in. There's three.
24 '56, '78, and '88, so I am asking you, there
25 were others; correct?
51
1 A. Actually, we haven't talked about
2 the other data sets yet. What I provided was
3 the standard information provided in Barras
4 and others 2008 to Dr. Wes- -- I mean, I
5 provided every data set I used in that report
6 to him.
7 Q. Okay. So it was -- You gave him the
8 '56?
9 A. It's the same information given to
10 you guys.
11 Q. Okay. I know, but my question is,
12 you gave him the '56 habitat data set for
13 Pontchartrain basin, Barataria, and Breton
14 Sounds; correct?
16 Q. Were there other data sets that were
17 available at the time that you could have
18 given to him?
19 A. I gave him all of the data sets that
20 I had available for that particular area.
21 It's the same information that was given -- It
22 was passed to the Department of Justice, and I
23 guess you guys provided it to whoever needed
24 it, the information.
25 Q. Well, there's currently a dispute in
52
1 Court as to whether they have given us what
2 they were supposed to give us, so that's for a
3 different day.
4 A. Okay.
5 Q. So please, for I guess purposes of
6 our conversation, it's better if you don't
7 assume they gave it to us. So let me ask the
8 questions and let me establish what we believe
9 we have is actually what you are talking about
10 more importantly.
11 A. Sure.
12 Q. So you said that -- I think your
13 previous testimony, as I understood it, was
14 you gave Westerink the '56 habitat data set
15 and then I understand the areas you clipped
16 out were Pontchartrain basin, Barataria, and
17 Breton, instead of giving him the whole
18 Louisiana coastline.
19 A. Correct.
20 Q. That was correct? Were there other
21 data sets that you gave to Dr. Westerink in
22 that conversation you had with him in the
23 summer of '08?
24 A. Honestly, I do not remember. I
25 would assume any data sets that I transferred

53
1 over were provided to all parties.
2 Q. Did you give them directly to Dr.
3 Westerink by email or --
4 A. No, I think that everything had to
5 go through Department of Justice, to the best
6 of my recollection, so I don't believe I
7 transferred anything directly to him.
8 Q. Have you reviewed Dr. Westerink's
9 expert report?
10 A. No, I haven't.
11 Q. Do you know whether his expert
12 report contains the information that you
13 believe would have been provided to him that
14 you produced to the Department of Justice?
15 A. Just in the phone conversation. I
16 knew they were -- I know that the 1956 base
17 was used.
18 Q. And is that the phone conversation
19 you're talking about in the summer of '08?
20 A. Yes.
21 Q. Okay. Have there been any other
22 phone conversations you had with Dr. Westerink
23 after that summer of '08 telephone
24 conversation?
25 A. I had a recent conversation, I just

54
1 attended the conference call, but it was only
2 to discuss the -- actually, the '56 habitat
3 data.
4 MS. MILLER:
5 Can we take a quick break?
6 MR. JOANEN:
7 Sure.
8 VIDEO OPERATOR:
9 Off the record.
10 (Recess.)
11 VIDEO OPERATOR:
12 This is the beginning of tape 2.
13 We're back on the record.
15 Q. Mr. Barras, we were talking about
16 your conversations with Dr. Westerink. I know
17 you said we had one in 2007. You said the
18 summer of 2008. I'm sorry.
19 A. Yes.
20 Q. Then you had another recent
21 conference call; it was a discussion regarding
22 the '56 habitat data. When did that take
23 place? "Recent", do you mean 2009?
24 A. Oh, it was probably one day of this
25 week.

55
1 Q. Other than the conference call you
2 had with Dr. Westerink in 200- -- the summer
3 of 2008 and the one you had this week, were
4 there any other conference calls you've had
5 with Dr. Westerink?
6 A. I attended a few because I was on
7 the CC for the meetings, but my area of
8 expertise really didn't assist them with what
9 they were doing so I kind of just quit
10 attending most of the conference calls unless
11 they specifically requested. And there was
12 very few that I attended after I -- after the
13 information -- the data that was provided to
14 me.
15 Q. And the one in September of '08, do
16 you remember who else was in on that
17 conference call?
18 A. It would have been the ERDC
19 modelers. I'm trying to remember. Bruce -- I
20 don't remember Bruce's last name.
21 Q. Would it be Ebersole?
22 A. Ebersole. That's it. And a couple,
23 I think maybe one or two people from ERDC. I
24 don't remember their names.
25 Q. The name Donald Resio, does that
56
1 ring a bell to you as --
2 A. No.
3 Q. -- being one of the people?
4 A. Uh-uh (negatively).
5 Q. So you know that at least it was Dr.
6 Westerink and Dr. Ebersole; correct?
8 Q. Was there any Department of Justice
9 attorneys involved in that conversation, or
10 was this just the scientists and experts --
11 A. No.
12 Q. -- kicking ideas around?
13 A. No, Kara was on that phone call.
14 Q. And that conversation that you had
15 when you provided the '56 habitat data, we'll
16 just say that was the first telephone
17 conference you were involved with; correct?
18 A. Yes. They contacted me for the
19 landscape information, historical landscape
20 information.
21 Q. Did you participate in any
22 conversations with Dr. Westerink wherein you
23 were describing the information that was
24 provided to him?
25 A. Not particularly with that. The

57
1 last phone call, they just wanted to know what
2 my definition of -- if I considered a swamp
3 forest above a certain height and I told them
4 yes. And that was it. Above 20 feet I think
5 it was considered a forest.
6 Q. The conversation where they asked
7 you was a forest over 20 feet, a swamp forest
8 over 20 feet, when was that conversation?
9 A. That was this Monday.
10 Q. Okay. When you had the
11 conversations with Dr. Westerink when you gave
12 him the information, had you actually already
13 provided the information to him at that first
14 conversation in November of '08?
15 A. No, I think that was to actually
16 provide the information. So --
17 Q. And so the information you were
18 going to provide, how was that transferred?
19 A. I --
20 Q. Was that electronically or was it by
21 paper? I know you said you sent it to DOJ.
22 A. It would have been a digital file
23 that would have gone to DOJ and I assume they
24 transferred it to Dr. Westerink.
25 Q. The digital file that you
58
1 transferred to DOJ, that included you said the
2 habitat loss data?
3 A. No, it does not include the loss
4 data. It would have been the 1956 habitat
5 configuration of -- for those three basins
6 that we mentioned earlier. It's basically the
7 landscape configuration of that period of
8 time.
9 Q. Would that include topography?
10 A. No. It is strictly a themematic
11 classification of habitat types.
12 Q. Do you know whether any of that
13 information would have had any LIDAR elevation
14 information --
15 A. No.
16 Q. -- in any way superimposed or put
17 together in conjunction with that information?
18 A. No. That's outside my area of
19 expertise.
20 Q. Are you, when you are providing that
21 information with just the habitat change, are
22 you also telling Dr. Westerink what the
23 heights of those --
24 A. No, I did not provide that. But one
25 member of -- of our team did based on field

59
1 sampling information of it. Greg Stires
2 developed -- Dr. Greg Stires with the National
3 Wetlands Research Center has developed through
4 the coastal restoration monitoring system and
5 they have gone out and they have gathered a
6 lot of -- they have monitoring sites
7 throughout the coast and I think they provided
8 updated marsh -- you know, just average
9 elevations by marsh type.
10 Q. Do you know whether Mr. Greg Stires
11 was on that telephone conversation --
12 A. No, he wouldn't have been.
13 Q. -- in the summer of '08?
14 A. No.
15 Q. The habitat configuration that you
16 provided, did that include any bathymetry?
17 A. No, it -- No.
18 Q. Did it include areas that would
19 incorporate open water?
20 A. Yes.
21 Q. And so your document, is it -- your
22 information given, is it in the form of a
23 photograph, like an aerial photograph looking
24 -- a computer-generated aerial photograph
25 looking down?
60
1 A. It's in a form of a computer image
2 where each value of the image would correspond
3 to a marsh category or habitat type. So it
4 would identify the extent, the spatial
5 distribution of fresh marsh, intermediate
6 marsh -- Well, you wouldn't have had that in
7 1956. It would have been fresh and non-fresh
8 marsh.
9 Q. Okay.
10 A. You would have also identified the
11 distribution of swamp, bottom land -- or hard
12 forest categories. And other ones. I could
13 actual read it off if you want to go through
14 all of the habitat types.
15 Q. I'm sure we will a little later.
16 And so that included all three of those areas,
17 Breton Sound, Lake Pontchartrain basin, --
18 A. Yes.
19 Q. -- and the Barataria basin?
21 Q. Why is it that they would be
22 interested in the Barataria basin? Do you
23 know?
24 A. They weren't. I just provided it
25 just -- just in case somebody that was looking

61
1 at it was looking at patterns, that was just
2 my personal -- I just added a little extra.
3 There's no reason for it.
4 Q. Was the information that was
5 provided to them through that electronic
6 production, was that able -- were you able to
7 cut out the area that included just the MRGO?
8 A. I -- From my report, I cut out the
9 channel -- Let me rephrase that. They -- I
10 wasn't -- I don't think I was provided at that
11 time a specific area of interest. So I
12 provided them a very large area based on
13 Penland's report so that they could use that
14 to extract whatever information they needed.
15 Q. Okay. And so that would include the
16 entire Lake Pontchartrain basin which also
17 incorporates Breton Sound; correct?
18 A. Yes.
19 Q. That information, was there any
20 charts or graphs available that would tell you
21 what the square acreage or total acreage of
22 certain classifications of vegetation was?
23 For example, cypress tupelo forest?
24 A. The actual -- Well, they would have
25 had a swamp category in 1956, but as

62
1 documented in my report it gives a pretty
2 extensive background on that. It would also
3 have included -- overly generous in that it
4 would have also included willow swamps and
5 swamp maple type of swamps. Not just cypress
6 tupelo. So the swamp category would be a
7 little larger than if it had been strictly
8 cypress tupelo.
9 Q. So someone like Dr. -- So it did
10 include the acreage, the information that was
11 provided to Dr. Westerink did or did not
12 include --
13 A. It includes -- The file itself, the
14 way it is structured, you can calculate -- It
15 calculates acreage. Each component of the
16 file or pixel is 25 meters by 25 meters, so
17 you actually have area values inherent in the
18 file.
19 Q. And so there's a computer program
20 which starts to add up what all of those 25 by
21 25 --
22 A. It's what the GIS -- that's what
23 Geographic Information Software does, it
24 allows you to manipulate that information.
25 Q. Do you know whether there was any
63
1 need for Dr. Westerink to interpret the
2 information that was being provided to him or
3 was it simply -- Let me finish my question --
4 was it simply that you're giving him in
5 essence a map and then on the side, because of
6 the 25 by 25 meter grids, and the computer
7 program runs numbers, it'll tell him what the
8 ranges are of acreage?
9 A. His staff or his programming staff
10 should have easily been able to calculate
11 acreages from that information.
12 Q. So did you calculate that acreage?
13 A. I did not.
14 Q. Or would you have provided it to
15 him?
16 A. No, I just transferred the file. Or
17 provided the file to DOJ to transfer.
18 Q. So the file that you would be
19 transferring, it includes, for the Lake
20 Pontchartrain basin, a whole plethora of 25 by
21 25 meter grids?
22 A. Correct.
23 Q. In each of those grids, you have
24 habitat classification given a value?
25 A. A unique value per cell or per grid.

64
1 Q. And you did not run the mathematical
2 equations to spit out what the total numbers
3 of grids for a certain habitat classification
4 were to come up with a final number for
5 acreage? That was provided to DOJ to provide
6 to the expert for them to run those
7 calculations; is that correct?
8 A. Okay. I am getting a bit confused.
9 I'll step back. What was provided to Dr.
10 Westerink, he was perfectly capable of running
11 acreages himself for whatever he needed for
12 his particular efforts. My report, I actually
13 ran acreage values and looking at forest types
14 and I did all of that, I did that as I would
15 normally provide that information to the Corps
16 of Engineers or other Federal partners, and
17 that's summarized in the report. But the
18 information I use was specifically designed to
19 look at forest type changes and land loss
20 calculations within that area.
21 Q. I understand that that's what you
22 did for your report.
23 A. For my report.
24 Q. I get that. But I am asking more of
25 what you provided to Dr. Westerink. Was it
65
1 given to him with just -- Let's just say a
2 total number is 10 and you have 1 plus 1 plus
3 1 plus 1 plus 1 plus 1, up to 10. Were you
4 just telling him "The numbers you need are 1
5 plus 1 plus 1 plus 1," and then he is going to
6 say "Equals 10" for each of those grids, or
7 did you actually give him the final number for
8 the square acreage?
9 A. No.
10 MS. MILLER:
11 Objection --
12 THE WITNESS:
13 I provided --
14 MS. MILLER:
15 -- to the extent that question
16 is unclear.
18 Q. I am trying to make it as simple as
19 possible.
20 A. I provided the source data to him.
21 I did not calculate this acreage summaries for
22 him.
23 Q. That's the term I needed. The
24 source data. Okay.
25 A. Yeah. The source data. Okay. So

66
1 we're clear now.
2 Q. Each of those -- And again, you
3 know, I am not trying to train myself on the
4 Internet. There's just limitations.
5 So each of those grids is one part
6 of the source data.
7 A. Correct.
8 Q. And then each -- all the grids that
9 are within the Lake Pontchartrain basin area
10 comprised the entire scope of source data
11 that's being presented; correct?
12 A. Yes. But it also included the other
13 two basins. So what you have got is a file
14 that has a bunch of grids. You have got --
15 Q. Fair.
16 A. Okay. All right.
17 Q. With that source data, the way that
18 it is presented, is it possible that Dr.
19 Westerink could cut out certain particular
20 areas of, for example, Lake Pontchartrain
21 basin if he wanted to just figure out the
22 footprint of the MRGO? Could he, in his
23 expertise, to your knowledge, be able to take
24 the source data for that and calculate those
25 numbers?
67
1 A. It's actually speculation on my
2 part. I assume he can based on what he does
3 for a living. But that's -- Yeah.
4 Q. You don't know?
5 A. I don't know.
6 Q. The source data that you transferred
7 to him, were there any -- when you transferred
8 it, was there any evaluation you were making
9 regarding the quality of that information, or
10 is this basically something that's kind of on
11 your shelf that you're providing to him?
12 A. It's all on the shelf.
13 Q. Have you provided any other
14 information to Dr. Westerink or any of the
15 other defense experts other than this source
16 data for that habitat configuration and
17 whatever your interpretation of whether the
18 definition of a swamp forest is above 20 feet,
19 have you provided any other information to
20 those experts?
21 A. No, except -- I just want to be
22 clarifying the data of the source data. I did
23 provide all of the source data used to
24 calculate the numbers for my report. Each of
25 those data sets was provided to DOJ, which I

68
1 don't know if that -- you know, you -- but
2 anyway, that's what I provided. It wasn't
3 just the 1956 data. It was the 1956, 1978 and
4 all of the iterations up to present that I use
5 for calculating trends.
6 Q. And all of that source data was
7 transmitted by you at the same time?
8 A. Yes. It was easier to do that than
9 trying and extract information constantly.
10 Q. So all of the source data that was
11 transferred was transferred resulting from the
12 phone call that you were involved with --
13 A. Yes.
14 Q. -- in the summer of '08?
15 A. Yes.
16 Q. Did you participate in any efforts
17 to modify the interpretation of source data?
18 A. No.
19 Q. And just so I am covering the
20 waterfront on this, the habitat configurations
21 that you would be providing with the source
22 data, that would be from '56, '78, and the '88
23 data sets?
24 A. Correct.
25 Q. Was there any updated data sets that
69
1 you were able to provide to them after 1988?
2 A. There would have been a series of
3 basic configurations, land-water, classified
4 land-water configurations from landsat,
5 thematic map or satellite imagery for a host
6 -- a host of dates that were used in the
7 2008, Barras and others 2008 report.
8 Q. And those are the ones that we will
9 be going through when we go through your
10 report?
11 A. Yes.
12 Q. And those were also transferred to
13 Dr. Westerink as the source data resulting
14 from that telephone conversation in the summer
15 of '08?
16 A. Yes, it's the same information that
17 was transferred to DOJ for use by all parties.
18 Q. And the series of these basic
19 configurations, was that also something that
20 was, to use layman's terms, something on the
21 shelf that you were providing?
22 A. The basin configurations have been
23 standardized since 1994 by the Coastal
24 Wetlands Planning Protection Restoration Act
25 Task Force. So it's basically an

70
1 off-the-shelf product in Louisiana.
2 Q. Let me ask you, have you ever been
3 asked to testify as an expert before by any
4 other Federal agency prior to your engagement
5 in this litigation?
6 A. In trial or --
7 Q. Yes, in preparation for --
8 A. No, not in a trial. No.
9 Q. Have you been involved in any -- not
10 as a testifying expert, but as a consulting
11 expert for any governmental agencies regarding
12 litigation?
13 A. The only litigation that I provided
14 support would have been providing geographic
15 information data set and analysis support,
16 would have been for the oyster -- oyster
17 lawsuits. Avanol and all of that stuff that
18 took place. It was Avanol in the late -- I
19 think mid '90s, '95, '96, somewhere in that
20 neighborhood.
21 Q. And that was for the State of
22 Louisiana?
23 A. State of Louisiana, yes.
24 Q. Nothing with the Federal agencies?
25 A. No, nothing with the Federal

71
1 government.
2 Q. Have you ever prepared any papers to
3 be submitted to what is considered, would be
4 reference literature, professional journals?
5 A. Yes, I have been second author on
6 papers. And I have several USGS
7 publications.
8 Q. Are those provided in your expert
9 report?
10 A. Some of those are, yes.
11 Q. How many have you been -- How many
12 papers have you been a second author on?
13 A. I don't know. I would have to go
14 back and look. I didn't keep track of it.
15 Q. More than 10, less than 10?
16 A. Probably more than 10 I assume.
17 Q. Less than 100?
18 A. Oh, yes. I'm sure. I'm not an
19 academic. I'm not an academic.
20 Q. I'm just trying to get the range.
21 Less than 50?
22 A. Yeah, less, I'm sure.
23 Q. So somewhere between 50 and 10
24 you've had?
25 A. Yes, somewhere in that

72
1 neighborhood.
2 Q. And what were the -- Of these range
3 of papers, what were the focus of them?
4 A. Most of these papers would have been
5 focused on land loss analysis in coastal
6 Louisiana.
7 Q. And were these, when you talk about
8 land loss analysis, are you talking about the
9 procedure by which you come to a conclusion,
10 or are you just presenting information
11 regarding the conclusion?
12 A. The procedure by which you come to a
13 conclusion and presenting information.
14 Q. Have you ever been a primary author
15 on any of these papers?
16 A. Yes.
17 Q. How many have you been a primary
18 author on?
19 A. I'd have to look at the recent. But
20 at least USGS and other stuff, probably five
21 or six that I have got right now.
22 Q. And have these been published, or
23 have they just been submitted?
24 A. Oh, they were peer reviewed and
25 published.

73
1 Q. And those ones that you were primary
2 author and which they were peer reviewed and
3 published, were those also regarding the
4 procedures by which you can reach conclusions
5 regarding land loss analysis?
6 A. Yes. And summary information. Or
7 observations of land loss.
8 Q. In any of these peer reviewed
9 publications in which you were a primary
10 author, you said there were about five or six
11 of them, did you ever get into any analysis
12 regarding the cause for the land loss?
13 A. Yes.
14 Q. And what are some of the causes that
15 you were discussing in these papers?
16 A. My primary research focus right now
17 is looking at the impacts of episodic events
18 on coastal land loss which would be primarily
19 hurricane impacts. I am involved in a large
20 USGS project where we're actually going back
21 from the present to the 1950s looking at
22 historical hurricane impacts on Louisiana and
23 the contribution of coastal land loss.
24 Q. And when did this focus of your
25 study begin, the impact of episodic events?
74
1 A. It started in 2003 after we had
2 finished an update, we -- I provided the
3 source information for the Louisiana coastal
4 area land loss update, and -- that's one of
5 the publications. After that, I was contacted
6 by Dr. Bob Morton, Robert Morton with the
7 USGS. He's a senior USGS geologist and --
8 coastal geologist and he was -- he has been
9 involved in looking at land loss due to fluid
10 extraction, rapid land loss events. So he
11 asked me to start constraining the timing of
12 magnitude of these events.
13 Q. When you mean, fluid extraction,
14 what are you talking about?
15 A. Oil and gas extraction. Or
16 groundwater. But it's not that much in
17 Louisiana.
18 Q. And have you been able to reach any
19 conclusions as to why a hurricane would have
20 an impact on the --
21 A. I have.
22 Q. Okay. And what are those?
23 A. That the hurricanes can cause
24 impacts -- It's actually documented in the
25 2006 report, looks after Katrina, impacts of

75
1 Katrina and Rita, that hurricanes can cause
2 large scale land loss, you know, from small
3 scales, small ponds, enlarging ponds, creating
4 new ponds, up to almost large lakes, up to a
5 hydrologic basin scale, impacts on land loss
6 and contributing to land loss in Louisiana.
7 Q. And what aspect of a hurricane
8 actually causes those types of losses?
9 A. Surge impacts.
10 Q. By "surge impacts", are you talking
11 about the --
12 A. Physical removal of wetlands by
13 water moving across the wetlands.
14 Q. So you're talking about really just
15 the force of the water coming in?
16 A. The force of the water actually
17 physically removing or changing the shape of
18 the -- the wetland topography, the morphology.
19 Q. Do your studies include an analysis
20 of the salinity impacts of this water coming
21 into areas that may not have that high a rate
22 of salinity?
23 A. No, I'm actually doing the initial
24 observations. The study that I did in 2006
25 was the first large scale study that

76
1 documented -- that was able to document these
2 events. The magnitude of the events.
3 Q. And you said that this study is
4 involved with the effects of Hurricane
5 Katrina?
6 A. Right. Katrina and Rita. Not just
7 Katrina.
8 Q. And who are you working in
9 conjunction with other than Dr. Morton on
10 this?
11 A. On that study or currently now? I'm
12 --
13 Q. On the study regarding the physical
14 force of water on the environment.
15 A. I actual haven't -- That's mostly
16 been my own baby right now. So we're trying
17 to expand that out to past the physical, but
18 right now I'm just trying to document the
19 physical observations so we get a better idea
20 of these patterns.
21 Q. Is it within your expertise to opine
22 whether the physical force of the water would
23 be removing a certain amount of the landscape
24 based upon the healthy nature of that
25 landscape? For example, is a healthy marsh
77
1 more likely to withstand a stronger hurricane
2 surge as opposed to an unhealthy marsh?
3 A. I can't answer that yet. We're
4 making the observations and we're still not
5 certain because the impacts are highly
6 variable.
7 Q. When you mean "highly variable",
8 what are the types of things that you would
9 consider to be variable? Locations?
10 A. The variable would be the
11 geomorphous shape of the actual coast, the
12 types of marsh that the hurricane is
13 traversing, the track and magnitude of the
14 hurricane --
15 Q. You have to slow down.
16 A. Sorry.
17 Q. Please. The shape -- The shape of
18 the coast?
19 A. Yeah. The morphology of the actual
20 coastal basins, the track that the hurricane
21 is progressing, its actual heading, the amount
22 of surge that the hurricane related to the
23 wind field -- windshield of the hurricane, the
24 wind swath. The -- The level of the hurricane
25 itself.

78
1 Q. When you study the morphology and
2 its relationship to the surge level, do you
3 take into calculations rates of frictions from
4 the various types of vegetations that the
5 surge would be passing over?
6 A. No, we're actually hoping to get to
7 that point one of these days, but no, right
8 now it's just physical observations. It's
9 just trying to document that these events have
10 actually occurred in the past and to get an
11 idea of how widespread they are throughout the
12 coast.
13 Q. So I guess what I am trying to
14 understand in layman's terms, you're at the
15 very start of this study?
16 A. It's the initial start of this
17 particular venture.
18 Q. So in saying the physical
19 observations, are you taking before and after
20 pictures and putting them together --
21 A. Correct.
22 Q. Is this an over -- Let me finish the
23 question?
24 A. I'm sorry. Yeah.
25 Q. You are taking -- These are layman's
79
1 terms. I know your GIS information is much
2 more complex than this, --
3 A. Yes.
4 Q. -- but basically are you taking
5 before and after pictures, overlaying them and
6 determining what's no longer there?
7 A. It's -- Yes, it's using bracketing
8 photography or imagery depending on what's
9 available to identify the impacts.
10 Q. And the term you used is "bracketing
11 photography"?
12 A. Yes.
13 Q. That's before and after?
14 A. Or satellite imagery.
15 Q. So bracketing photography is
16 actually a type of photography as opposed to
17 just a process of --
18 A. It's a process.
19 Q. And so you could actually have a 35
20 millimeter camera or a satellite image that
21 could be used for bracketing photography;
22 correct?
23 A. It's primarily overhead aerial
24 photography. I mean, it's standard aerial
25 photography or satellite imagery. It's not so

80
1 much the oblique imagery, although you can use
2 it.
3 Q. Have you come to a conclusion yet
4 with this bracketing photography how much land
5 loss was lost due to Katrina and Rita?
6 A. We have an estimate that is based on
7 satellite information of 198 square miles due
8 to Katrina and Rita, but that is only an
9 estimate. It's well cautioned in the report
10 that it could contain ephemeral loss that may
11 vary with time, transitory lost that may vary
12 with time.
13 Q. And the numbers you gave, is that
14 for the entire Gulf Coast region or is that
15 only for the state of Louisiana?
16 A. For the Louisiana coastal area.
17 Q. Have you, with this bracketing
18 photography, been able to determine what the
19 impacts of just Hurricane Katrina were in the
20 Lake Pontchartrain basin?
21 A. You can isolate the impacts of
22 Hurricane Katrina, although Rita caused some
23 minor augmentation of Katrina's physical
24 impacts that I could identify with the
25 satellite imagery, but you get a pretty good

81
1 idea of where the major surge scours were at
2 and removed marsh was at.
3 Q. Have you done that, though?
4 A. Yes. It's already published.
5 Yeah.
6 Q. And where is that published?
7 A. It's on the Internet. USGS
8 publications warehouse.
9 Q. Did you do that or did USGS?
10 A. It's a US -- As a USGS employee I
11 did that.
12 Q. You actually did the interpretation
13 --
14 A. I did a complete analysis.
15 Q. Let me finish my question, please.
16 A. Yes.
17 Q. In fairness to Roger.
18 A. Oh, I'm sorry.
19 Q. You actually looked at the
20 bracketing photography for Hurricane Katrina
21 and were able to calculate the land loss for
22 the Lake Pontchartrain basin; correct?
23 A. It was broken out by physiographic
24 province. It can be calculated for the Lake
25 Pontchartrain basin. And as included in the

82
1 --
2 Q. You used the term "physiographic
3 province"?
4 A. Yeah. I broke out the -- This is
5 part of where the expert report goes into
6 breaking out fast lands, ridges, and marsh
7 areas.
8 Q. And so you actually did, on behalf
9 of the USGS, an interpretation of Hurricane
10 Katrina by using bracketing photography to
11 determine the loss rates through various
12 physiographic provinces?
13 A. Yes. Actually, satellite imagery.
14 Not photography. And the physiographic
15 provinces would have broken the coast into the
16 deltaic plain, the marsh deltaic plain, and
17 the Chenier plain.
18 Q. Are you familiar with the term
19 called by some of the experts as the MRGO
20 assessment unit?
21 A. Is this the assessment unit used by
22 the Corps of Engineers for the modeling
23 effort?
24 Q. Well, my question to you first is
25 have you heard that term before?
83
1 A. Well, I have heard many MRGO's. I
2 mean, several iterations. So I am just trying
3 to verify which one.
4 Q. Okay. Dr. Britsch testified
5 yesterday that he gave you a polygon-shaped
6 image which would -- which was what he defined
7 as the MRGO assessment unit.
8 A. Yes.
9 Q. Do you recall him providing that to
10 you?
11 A. Yes. I do have that. Yes, I know
12 which one you're talking about.
13 Q. In that MRGO assessment unit, were
14 you able to divide the area into distinct
15 areas? For example, one of them would be a
16 coastal wetlands unit. Have you done that?
17 A. Yes. But in my report -- No, not in
18 the MR -- I just calculated the area
19 separately for that particular unit. I used a
20 different designation of units for my report.
21 Q. Have you -- Well, not so much -- I
22 am not thinking so much for your report yet.
23 I am thinking more about the work that you're
24 doing for the Katrina land loss for the USGS.
25 Were you doing any calculations for land loss
84
1 in an area that would be defined as the MRGO
2 assessment unit as has been utilized in the
3 litigation?
4 A. Not for that report, no.
5 Q. And what would have been the purpose
6 for Dr. Britsch to provide you with his
7 interpretation of a study area?
8 A. He wanted the actual habitat acreage
9 for that particular area.
10 Q. And by habitat acreage, are you
11 talking about the entire acreage within his
12 polygon? And just to be fair to you, let me
13 show you what his report is. I'll show you.
14 A. Yeah, that's (indicating) --
15 Q. And for purposes of the record, I am
16 not going the mark this as an exhibit. This
17 is Dr. Britsch's expert report that he
18 testified to yesterday, figure 2, page 4 and
19 show you that.
20 A. Yes.
21 Q. And he referred to that as the
22 polygon. When he's asking for this polygon of
23 information, is he asking for the total number
24 of acres within that polygon or is he asking
25 for breakdowns between the types of vegetation
85
1 within that?
2 A. It would have provided the total
3 number of acres within that polygon and the
4 breakdowns by the habitat types.
5 Q. And do you know what years he was
6 asking -- Obviously I know you have '56, '78
7 and '88, you're going to have different --
8 you're going to have a number of changes
9 taking place --
10 A. Right.
11 Q. -- within this study area over that
12 time period. Do you recall what data sets you
13 were providing to him?
14 A. I provided the 1956, '78, and I
15 think the 1988 statistics for that area,
16 habitat statistics.
17 Q. And when did you provide that
18 information to him?
19 A. Let's see. About two days ago.
20 Q. So you had not provided it to him at
21 any time prior to his production of an expert
22 report, which was produced at or about the
23 same time as yours was?
24 A. No, but I did provide the -- in my
25 report I did use that area to break down the

86
1 habitat information and trend information. So
2 I don't know if -- I'd assume he had it either
3 way.
4 Q. But you don't know for sure?
5 A. I'm not certain.
6 Q. And you didn't give it to him
7 specifically? You had it in your report that
8 he utilized?
9 A. Yes.
10 Q. Do you know whether -- And you said
11 you didn't do a draft report; correct?
12 A. No.
13 Q. You just did one report?
14 A. No, this was the first. Yeah, that
15 would have been.
16 Q. So in preparing his report, if the
17 first time that you had it published to be
18 viewed by anybody is when you turned it in, if
19 y'all turned in separate reports at the same
20 time he wouldn't have had a chance to review
21 your information prior to producing his
22 report?
23 A. I would assume he would have a
24 chance to review it prior to the deposition.
25 Q. But not when he produced his report
87
1 in December?
2 A. No.
3 Q. Okay. And so when you did the total
4 acreage and total -- the total
5 classifications, you were utilizing the three
6 data set points, the first time you provided
7 that to him was two days ago?
8 A. Yes.
9 Q. Had you talked to Dr. Britsch, to
10 your recollection, at any time prior to the
11 date of your production of the report and
12 after Miss Miller contacted you about being an
13 expert?
14 A. Yes, but we were working on a
15 project that had nothing to do with this and
16 he was going to be a co-principal investigator
17 on it. We were probably going to be working
18 closely together so we had several meetings
19 discussing historical land loss.
20 Q. And what project was that?
21 A. That would be for the northern Gulf
22 of Mexico. It's a USGS -- It's a large five
23 year project for the USGS looking at
24 ecological changes of hazards and
25 vulnerabilities for the Gulf Coast.

88
1 Q. And that would be the -- well, this
2 has that y'all were working together, the one
3 I have, it says revised January, 2004, would
4 this be the one you're talking about?
5 A. No, that is a prior project that we
6 worked together on. That was for the
7 Louisiana coastal area effort back in 2002 and
8 2003.
9 Q. And so the project that you were
10 working on with Dr. Britsch after the storm,
11 did that involve an analysis of the loss of
12 land in what he's defined as the MRGO
13 assessment unit resulting from Hurricane
14 Katrina?
15 A. No. It was actually looking at
16 coastal, historical coastal land loss patterns
17 coastwide.
18 Q. By "coastline" are you talking about
19 the coastline of the Gulf of Mexico as opposed
20 to the coastline which is north of the
21 Mississippi River?
22 A. It would have been all of south
23 Louisiana, the coastal area of south
24 Louisiana.
25 MS. MILLER:

89
1 I'm sorry, did you say
2 "coastwide" rather than "coastline"?
3 THE WITNESS:
4 I'm sorry, when I say
5 "coastwide", let me define that.
6 That is the extent of the historical
7 habitat data that I use which is based
8 on a 1978 coastal zone boundary. So
9 it's basically Texas to Louisiana, and
10 south of I-10 and 12.
11 MS. MILLER:
12 Forgive me, I misheard
13 "coastwide" for "coastline". To the
14 extent there's a difference, I just
15 wanted to make sure we all knew what
16 we were talking about.
18 Q. With the MRGO assessment unit or
19 study area that was provided by Dr. Britsch,
20 did you use that information or that outline
21 of polygon in any way in preparing your expert
22 report?
23 A. Not really.
24 Q. And why would that be?
25 A. I had designed my -- The polygons

90
1 are the boundaries used in my report
2 specifically to look at forest type changes
3 and land loss patterns. And I wanted to
4 isolate developed areas from -- or upland
5 areas -- it's not upland, but fast land areas,
6 I had several, and from wetland and from
7 ridges.
8 Q. Do you know what the IPET report is?
9 A. I've heard the term, but I have
10 never read it.
11 Q. My next question was going to be
12 have you been involved in any inputs regarding
13 the IPET report?
14 A. I will have to say that my staff may
15 have provided analyses for the Corps of
16 Engineers. They do a lot. They may have
17 provided some polygon analyses of -- in that
18 particular area. I am not certain if it was
19 for the IPET or not. But I know we have done,
20 you know, internal project requests for the
21 Corps just providing information to them.
22 Q. Okay. You're not an engineer;
23 correct?
24 A. No, I'm not.
25 Q. Is anybody on your staff an
91
1 engineer?
2 A. No.
3 Q. The IPET report has been opined by
4 some to be a forensic engineering report.
6 Q. They're studying the effects of
7 Hurricane Katrina on all the factors involved
8 with Hurricane Katrina flooding. Do you know
9 whether any of your people were involved with
10 providing analyses for that as opposed to,
11 we'll use the layman term before, taking
12 things off the shelf and providing them?
13 A. It would have been taking things off
14 the shelf. They wouldn't have been involved
15 in the analyses.
16 Q. Have you had a chance to review the
17 IPET report?
18 A. No.
19 Q. So my follow-up question would be,
20 do you know where, if any of your people had
21 provided information to the Corps that was
22 utilized, where it would be contained?
23 A. I don't.
24 Q. How about Team Louisiana, which is
25 the hurricane group out of LSU; have you read
92
1 any of their forensic engineering analyses
2 regarding Hurricane Katrina?
3 A. I may have read some of the
4 information on Katrina surge just out of
5 interest back when I was doing -- but I cannot
6 recall specifically sitting down and reading
7 all of their documentation.
8 Q. Any of the documentation that you
9 did read, did you ever question the --
10 MR. JOANEN:
11 I'm sorry, can you read that,
12 what I was reading?
14 Q. Yes. Any of the documentation
15 regarding the Team Louisiana report that you
16 did read, did you ever question the accuracy
17 of the information?
18 A. No. I'm not an engineer, hydrologic
19 engineer.
20 Q. Are you familiar with a group that
21 was with the National Science Foundation that
22 came out of Berkeley that produced a report
23 that had an acronym of ILIT?
24 A. I don't recall hearing the term.
25 Q. Did you review any reports by a Dr.
93
1 Raymond Seed or Dr. Robert Bea prior to your
2 engagement with Ms. Miller?
3 A. No.
4 Q. Have you read any reports that were
5 authored by a Dr. Raymond Seed or Dr. Robert
6 Bea?
7 A. Not that I can recall.
8 Q. Have you been involved in any
9 meetings with Corps of Engineers individuals
10 after the storm to assess the effects of
11 Hurricane Katrina?
12 A. Not specifically with the Corps of
13 Engineers. I gave a presentation on some of
14 the initial findings to the CWPPRA Task Force
15 that were obviously at the Corps headquarters
16 where the Corps was present, but I haven't met
17 one-on-one to go over detailed findings of
18 hurricane-induced land loss, no.
19 Q. Just one second, please.
20 MR. JOANEN:
22 THE WITNESS:
23 Sure.
24 VIDEO OPERATOR:
25 Off the record.
94
1 (Recess.)
2 VIDEO OPERATOR:
3 We are now back on the record.
5 Q. Thank you, Mr. Barras, for your
6 courtesy. Before I get into your report, we
7 definitely want to go through it, so I can
8 understand it, I want to make sure I
9 understand some of the parameters by which you
10 put together your information to develop a
11 report.
13 Q. So I would like to go back to the
14 information that you provided to Dr.
15 Westerink. Your maps which had those 25 by 25
16 grid in it, --
17 A. Correct.
18 Q. -- in those grids, what kind of
19 information would be in a particular grid?
20 A. The grids assign a unique value that
21 would be assigned to a particular habitat type
22 that that grid falls within.
23 Q. And how is that value first
24 assessed?
25 A. From the photo interpreted

95
1 information.
2 Q. And so who would be the people
3 interpreting the photos?
4 A. That would have been the National
5 Wetlands Inventory personnel, the actual photo
6 interpreters that actually did the work.
7 Q. When they give a value, how would
8 that information come to you?
9 A. They assign what is called a
10 Cowardin habitat code. Cowardin is the U.S.
11 Fish and Wildlife Service scientists that
12 design wetlands habitat classifications.
13 Q. Could you spell that, Cowardin?
14 A. C O W A R D I N.
15 Q. So it's Cowardin?
17 Q. What's the rest of the term?
18 A. It was a habitat class. I think
19 it's -- Oh, I don't have the documentation
20 with me, but it's a wetland habitat
21 classification scheme --
22 Q. Okay.
23 A. -- for the U.S. Fish and Wildlife
24 Service.
25 Q. Okay. And so the National Wetland
96
1 Inventory provides it a value and it comes to
2 you as a number, like, say, cypress marsh
3 would be a 1? Or is it given some other type
4 of information -- in some other form or
5 fashion to you?
6 A. The way the data was originally
7 developed, it was interpreted in what was
8 called a vector polygon format.
9 Q. Okay.
10 A. So you had a team of photo
11 interpreters that drew lines around particular
12 habitat types. They then assigned a code, a
13 Cowardin code to that habitat type. You could
14 have over 1,000 plus possible combinations of
15 these codes, so it's very complex.
16 Q. Okay.
17 A. The Louisiana Department of Natural
18 Resources, the Coastal Management Division had
19 developed a scheme to aggregate the habitat
20 information, this Cowardin information, to a
21 more -- a simplified version. This was done
22 by consultants and by coastal management
23 permit experts in the mid 1980s. This scheme
24 would take a certain -- the documentation was
25 attached, but it would have a certain -- say

97
1 certain types of wetland forests were
2 identified as swamp. They would then say
3 this, you know, okay, so we're identifying
4 this as swamp, but it may have 10 or 15
5 Cowardin codes. To convert that to a -- I was
6 actually, as a graduate student back when I
7 was working for the Coastal Management
8 Division, one of the first tasks was to take
9 that information, that simplified information
10 and convert it to these coastwide formats for
11 the Groden Calhoun study in 1990.
12 Q. Okay.
13 A. So we used what is called a look-up
14 table to take all of those complex codes and
15 break it into forest, swamp, fresh marsh,
16 intermediate marsh, and brackish. That is
17 converted into a raster format, which is
18 basically an intelligent image, or a grid file
19 -- I know you guys are loving this, I can see
20 it, but let's make it simple. It's your
21 grids. It takes the lines and it says, okay,
22 we're going to divide this section of lines
23 into a series of 25 meter by 25 meter grids
24 and it assigns a value to it based on that
25 look-up table --

98
1 Q. Okay.
2 A. -- to a simplified value.
3 Q. Were you involved in that
4 simplification that was performed by Louisiana
5 Department of Natural Resources?
6 A. No, I actually came on as a graduate
7 student. At the time it had already been
8 developed internally.
9 Q. So when it comes to you, whatever
10 information that you then receive from the
11 National Wetlands Inventory, what are you
12 seeing when you are looking at a particular --
13 Say if you look at the map and you say, "I
14 want to know exactly what's going on in that
15 25 by 25 meter grid," what do you see? Do you
16 see a number such as a "1" or do you see
17 cypress -- a swamp?
18 A. You're going to see a color value
19 displayed on the monitor that you can then use
20 tools to query that -- any particular location
21 on that color to give you the actual value for
22 that cell. The cursor, the tool that will
23 come up will either be a cursor or a mouse
24 point or something and it'll go to that -- the
25 nearest cell and identify what -- When you

99
1 click on it, it'll say it has a value of 1,
2 which is water or something.
3 Q. Okay. So originally when you look
4 at it, it's a color?
5 A. Yes.
6 Q. And then if you look further into
7 it, you'll then get a value? Is that correct?
8 A. The -- Yes. I know we're having
9 semantic difficulties, but yes.
10 Q. That's part of the process of me
11 learning your vernacular --
12 A. Sure.
13 Q. -- so that I can understand it.
14 The value that you're assessing or
15 is assessed for each one of those, is that in
16 a list somewhere?
17 A. Yes.
18 Q. Okay. And how many classifications
19 would be in that list?
20 A. I would have to -- I think you have
21 14 or 15 categories. It's listed in the
22 report for the '56 and '78 data.
23 Q. And that's in your report?
24 A. Yes.
25 Q. And on what page would that be?
100
1 A. I'll go back and look through it.
2 It's probably going to be in the area tables
3 in the back actually. If you switch -- Let's
4 see. I've got to pull it up. This must be it
5 here. Here we go. I'm just going to grab an
6 example. Here you go. I don't know which
7 page this is, but this is just what you're
8 going to see. These are the categories you're
9 going to have (indicating). So it's actually
10 in a spreadsheet.
11 Q. Okay.
12 A. Yeah, here you go. This is even a
13 better example. It lists all the habitat
14 covered.
15 Q. Okay. And what table was that?
16 A. I just lost the sheet. I apologize.
17 Q. Okay. Can you find it again? I'm
18 sorry.
19 A. I'm just going to grab an example.
20 Let's see. XJB-001 with a bunch of zeros and
21 a 50 on the end. But there were attachments
22 that were provided that should list the
23 aggregation scheme. I don't have that printed
24 out with me.
25 Q. And who would have established the
101
1 value? Where does that --
2 A. It's automatically assigned. You
3 develop a look-up table. Every one agrees
4 that value 1 is always going to be water. So
5 when it converts it to a grid format, it's
6 going to say all of these -- these particular
7 habitat codes we're calling water. The
8 computer automatically assigns a 1 to it and
9 just converts that group of poly -- the vector
10 stuff to a cell grid, a grid value.
11 Q. In the course of your work, do you
12 ever change the values?
13 A. Only if requested to -- Only if
14 requested for an analysis. But for the
15 purposes of this report, it was still left as
16 the same -- same look-up table that was used
17 back in 1988.
18 Q. For purposes of the report that you
19 produced?
20 A. Yes.
21 Q. Okay.
22 A. What has happened, just because of
23 the sheer -- this data has been reused over
24 and over, it's become kind of a standardized
25 commodity for coastal habitats in Louisiana.

102
1 Q. Since Hurricane Katrina, have you
2 ever been involved with changing the value of
3 the -- Have you ever been involved in changing
4 the values of those grids for any of the areas
5 within Lake Pontchartrain?
6 A. No.
7 Q. When you were involved in the -- in
8 providing the grid information to Dr.
9 Westerink, did you make any changes to the
10 values?
11 A. No.
12 Q. The simplifications that occurred by
13 the Louisiana Department of Natural Resources,
14 do you know how many factors were involved in
15 the simplification -- how many -- when it was
16 simplified, how many values were there?
17 A. They are in those look-up -- They're
18 in the look-up tables that were provided. I
19 would have to go through all of that to give
20 you an actual number. But the look-up tables
21 contain that information.
22 Q. Do you know if it's more than 100,
23 less than 100?
24 A. They had several hundred
25 classifications that were -- that are

103
1 aggregated to those types.
2 Q. And so instead of just being swamp,
3 they would specify the types of trees that
4 encompass the swamp?
5 A. Then you get some fairly good
6 confidence.
7 Q. Does this information take into
8 consideration the frictional values that the
9 type of vegetation would provide?
10 A. Not --
11 Q. Frictional values, talking about the
12 way that air or water would be affected as it
13 passed through the grid.
14 A. Not to my knowledge.
15 Q. Other than -- I know you said you
16 had talked with Dr. Westerink in November of
17 -- the summer of '08 and you provided him
18 with the different data sets. And is it true
19 that also, based upon what you just told me,
20 that the data sets that you provided to him,
21 you did not do any evaluations of the values
22 in the grids of those data sets? Is that
23 correct?
24 A. No, I just provided the source
25 information to him.

104
1 Q. And providing the source information
2 is kind of similar to what we talked about
3 earlier, where you went to the shelf, took the
4 information off, and forwarded it to him?
5 A. Correct.
6 Q. And no one on your team looked at
7 the grids to see whether in fact the
8 information there was correct when you
9 provided it to Dr. Westerink, did they?
10 A. No, I actually did the extraction
11 myself and verified the information. I
12 actually pulled up the files as I clipped them
13 out of the data sets and verified that they
14 were the -- you know, they were correctly
15 reporting the information.
16 Q. That it was a '56 data set?
17 A. Yes, a '56, it was a '78, it was an
18 '88.
19 Q. But, for example, you didn't pick a
20 grid in an area that would be, say, in
21 Chalmette, Louisiana and look at to it make
22 sure that that value set was correct? You're
23 going by the information that was provided by
24 the National Wetlands Inventory as it being
25 correct?
105
1 A. Okay. I guess I am missing you now.
2 Q. It might have been a bad question.
3 A. Yes.
4 Q. When you said you verified what you
5 provided to Dr. Westerink, are you verifying
6 that what you're giving him was the '56, the
7 '78, and the '88 data sets as well as the
8 updated series of basic configurations?
9 A. It would have been the clipped or
10 extracted data sets for that area.
11 Q. But you didn't go through and
12 question or evaluate the accuracy of the value
13 that was plugged into any one particular cell;
14 correct?
15 A. No. There should have been no
16 changes unless you would have had a
17 positional, slight positional shift, but it
18 should remain the same as the original source
19 information, the original aggregation back in
20 1988.
21 Q. And what do you mean by a positional
22 shift?
23 A. Sometimes when you extract
24 information with the GIS software and the
25 raster file, which is -- or the grid files,

106
1 there may be a shift of one to a half pixel
2 just depending on how the area is aligned, so,
3 you know, it may shift it 25 meters one way or
4 the other, or 12 meters or something. That's
5 just a feature that happens with the -- you
6 know, that happens with the -- That's
7 automated. I mean, you don't really control
8 that.
9 Q. Is that going to affect the value of
10 any particular grid?
11 A. No. The values will remain the same
12 within a grid. It's just they may -- you
13 know, you may have a slight 10 meter offset or
14 something in some spots.
15 Q. And the values in those grids, does
16 that in any way provide information regarding
17 topography of the region?
18 A. No, again it's the same thematic
19 land cover, basically, habitat classification
20 for that area.
21 Q. If you were to look at one of these
22 grids, pick any one in particular within, say,
23 the Pontchartrain basin Foundation -- the Lake
24 Pontchartrain basin and you clicked on it,
25 you saw that it was brackish marsh, would you
107
1 know the elevation of that vegetation?
2 A. No.
3 Q. That's not something that's within
4 your expertise that you would be --
5 A. No, you would have -- No, it's not.
6 I mean, you would have to actively find
7 literature information as to what that is.
8 Q. And when you click on one particular
9 grid within the Lake Pontchartrain basin,
10 would you be able to evaluate the health or
11 unhealthy nature of the marsh if that's the
12 vegetation within that grid?
13 A. The habitat information is just
14 going to base on a typical classification.
15 They're not going to identify if the marsh is
16 healthy or unhealthy for the most part.
17 That's not part of the classification scheme.
18 Q. Does part of the classification
19 scheme take into consideration whether a delta
20 is in a recessive stage or --
21 A. Transgressive?
22 Q. -- transgression?
23 A. No. It's actually a wetland
24 classification. It's not a geomorphic
25 classification.

108
1 Q. And as this process works down to
2 the roster format, is there anything that
3 you're involved with? Are you like involved
4 in the computer programming of all of that, or
5 is that just something that's working its way
6 down to you?
7 A. Could you reterm the "roster"?
8 Q. Well, the roster format seems to be
9 --
10 A. Raster. I'm sorry.
11 Q. Raster.
12 A. Raster.
13 Q. I'm thinking of reggae.
14 With the raster format, that
15 seemed, as you were explaining it to me, kind
16 of being towards the end of the line as the
17 information is being funneled down.
18 A. The raster format is one -- There's
19 two primary methods and -- to display area
20 information in GIS, either vector or raster.
21 That's one. That's just the standard format.
22 Q. Are you making any interpretations
23 regarding the quality of the raster format or
24 the vector format in your job description?
25 MS. MILLER:
109
1 Objection.
2 THE WITNESS:
3 Actually assess? Explain a
4 little bit more. I'm sorry.
6 Q. Well, when this information is
7 working its way down to this raster format or
8 vector format, are you involved -- is that a
9 computer program that is crunching numbers?
10 A. It's mostly an automated process
11 once the look-up tables -- I mean, I am not
12 sitting there and saying -- You can set the
13 grid cell size, you can define certain
14 parameters, but it's actually the computer
15 program itself that is going in to assign it.
16 Q. Okay. I know you gave that to Dr.
17 -- those data sets to Dr. Westerink. You
18 also said that you were involved in a
19 telephone conversation that included someone
20 you knew to be Bruce, probably Ebersole; do
21 you know whether you provided any information
22 to Mr. Ebersole, or Dr. Ebersole? I'm not
23 sure.
24 A. I would assume that they needed the
25 information that -- Again, I provided that

110
1 suite of data to DOJ and as it wended its way
2 through, I assume -- I don't know. I suspect
3 it was.
4 Q. Do you know whether you gave any
5 specific data to any of the experts for the
6 Department of Justice?
7 A. No. I -- Everything I think went
8 through DOJ.
9 Q. Other than the data set that you
10 gave to DOJ that we have discussed that went
11 to Dr. Westerink, did you give any other
12 information to DOJ other than your report, of
13 course?
14 A. Not that I recall. The only other
15 information probably would be the marsh
16 elevation information that you had mentioned
17 earlier that one my employees had obtained,
18 worked together with Greg Stire to provide.
19 Q. Are you familiar with what LIDAR
20 is?
21 A. Yes, I am.
22 Q. And what is LIDAR?
23 A. Light information range and then
24 detecting.
25 Q. And how is it that someone such as
111
1 yourself would come into a process whereby you
2 would utilize LIDAR information?
3 A. We would use LIDAR information for
4 displaying elevation for -- for approximating
5 elevation of surface.
6 Q. And would that be done to elevate --
7 to consider elevations of topography?
8 A. Correct.
9 Q. Is that utilized, is LIDAR data
10 utilized in developing the information data
11 sets that were provided to Dr. Westerink?
12 A. No, but -- No, it wasn't.
13 Q. And the data sets that Dr. -- Mr.
14 Stire was providing, do you know who that
15 information was given to, for marsh
16 elevations?
17 A. I would assume it went to Dr.
18 Westerink or through -- I am not quite
19 certain. I didn't handle that directly. I
20 just asked him to do it and he sent the stuff
21 over. But I know the -- it went through DOJ
22 to everybody that was on that email.
23 Q. Do you know a guy by the name of Bob
24 Kleiss?
25 A. Bob or Barb? I know a Barb Kleiss

112
1 with ERDC.
2 Q. Okay. Barb Kleiss. Is that a
3 female?
4 A. Yes. Dr. Barb Kleiss.
5 Q. Who is Dr. Kleiss and what is -- how
6 do you know her?
7 A. I know she is the co-chair of the
8 LCA Science and Technology program and she
9 partially funded some of the hurricane
10 analysis work that I did in the post-Katrina
11 and Rita work.
12 Q. Have you been involved in any
13 telephone conversations with her regarding --
14 A. Yes, actually she was on -- That's
15 -- That's one of the -- Besides Bruce, this
16 was one of the other names. She was on one of
17 the conversations.
18 Q. So in that conversation it was
19 yourself, --
20 A. Yes.
21 Q. -- Bruce Ebersole, Barb Kleiss?
22 A. Yes, several of the DOJ folks.
23 Q. Dr. Westerink?
24 A. Yeah. He was.
25 VIDEO OPERATOR:

113
1 Excuse me. Go off the record to
2 change tapes.
3 End of tape 2, we're going off
4 the record.
5 (Whereupon a discussion was held
6 off the record.)
7 VIDEO OPERATOR:
11 Q. Let me make sure I understand. You
12 provided the data sets to Dr. Westerink.
13 A. I didn't provide them directly.
14 Q. But they were provided --
15 A. Yes.
16 Q. -- ultimately. You generated the
17 stream that led to it receiving -- being
18 received by Dr. Westerink, to the best of your
19 knowledge; correct?
20 A. Yes, to the best of my knowledge.
21 Q. And you didn't make any changes to
22 that information based upon any professional
23 opinions that you would have formulated;
24 correct?
25 A. No.

114
1 Q. In the phone conversation that you
2 had with Dr. Westerink, which was in the
3 summer of '08, is that the one we're referring
4 to where Bruce Ebersole and Barb Kleiss and
5 several DOJ individuals were on the phone?
6 A. Yes.
7 Q. Other than the several DOJ
8 individuals, Barb Kleiss and Bruce Ebersole
9 and Dr. Westerink, who else would have been on
10 that phone call?
11 A. I don't remember. Whoever would
12 have been on the meeting circulation for the
13 emails.
14 Q. Was there anyone else from the USGS
15 on that phone call?
16 A. Not that I recall.
17 Q. No one else from your team?
18 A. No.
19 Q. Anyone else that would have the same
20 type of expertise that you would bring to that
21 conversation?
22 A. No.
23 Q. One of the things we have -- To be
24 fair to you, we have already taken the
25 deposition of Dr. Westerink. And his
115
1 statement is, and I will show you this if you
2 like, he said that when they were originally
3 running their models, they had some
4 discrepancies regarding some of the LIDAR
5 information. For example, they would show
6 that some of the marsh would be over 100 feet,
7 so they knew that was just wrong.
9 Q. And so then they tried to figure out
10 ways to make sure they had accurate vegetation
11 elevations. And his statement was "So then we
12 had extensive discussions with USGS and their
13 specialists and they informed us that there's
14 a very good consistency to the elevations of
15 the coastal marshes relative to water levels
16 in this area. That if you know the type of
17 marsh and the type of land cover, then you can
18 actually establish a fairly accurate surface
19 elevation." Then the question was "Who was it
20 that told you this, told you that," and the
21 answer was "Mr. Barras".
22 A. That wouldn't have been me.
23 Q. That would not have been you?
24 A. No.
25 Q. Okay.
116
1 A. I'd assume that probably came from
2 Greg Stire. I don't recall. I -- No, that
3 wouldn't.
4 Q. Do you know whether you were in on
5 any phone conversations in which Greg Stire
6 was also on the phone conversation that
7 involved communications with Dr. Westerink or
8 any of the other defense experts in this case?
9 A. I don't recall Greg being on that
10 particular conversation.
11 Q. If -- If this were not you, you
12 think it would have been Greg Stire?
13 A. It would probably have to be. Yeah,
14 it would have been Greg.
15 Q. How is it that Greg Stire would be
16 involved, if in fact this type of discussion
17 took place, how is it that Greg Stire would
18 have been the person brought in to that
19 discussion?
20 A. Because he has a series of stations
21 that he -- they made -- He's actually a
22 project manager for a coastal restoration
23 monitoring system and they actually develop
24 and gather marsh elevations and record marsh
25 elevation at the station sites.

117
1 Q. Do you ever or does anyone in the
2 USGS ever correlate the information that
3 someone like Greg Stire and the information he
4 has and correlate with your data sets? In
5 particular, the more recent ones where you're
6 saying that you provided them to Dr.
7 Westerink?
8 A. We have -- We do have a study that
9 was published in the S and T program that
10 actually looks at trying to merge high
11 resolution, or more moderate resolution
12 information with some of the information I
13 provided for the hurricane physical loss with
14 the monitoring station information that Greg
15 was the primary author on.
16 Q. And so is that something that's in
17 the works, they're trying to get it to work or
18 --
19 A. Yes.
20 Q. -- something that's actually
21 happening?
22 A. No, some of this is actually
23 happening.
24 MS. MILLER:
25 Can we take a short break?

118
1 MR. JOANEN:
2 Sure.
3 VIDEO OPERATOR:
4 Off the record.
6 off the record.)
7 VIDEO OPERATOR:
9 MS. GILBERT:
10 We're not back on yet.
11 VIDEO OPERATOR:
12 Off the record.
14 off the record.)
15 VIDEO OPERATOR:
16 We're now back on the record.
18 Q. Mr. Barras, on a break you had an
19 opportunity to speak with your attorney, Kara
20 Miller; correct?
21 A. Correct.
22 Q. Would you like to change your
23 testimony in any way as a result of that
24 conversation?
25 A. Yes, I would. I would -- I was

119
1 reminded during the conversation that I
2 actually had an employee, Brady Couvillon,
3 that had been involved with some of the LIDAR
4 information. I think he -- he had provided
5 some of the elevation information with Greg
6 Stire through Barb Kleiss to Dr. Westerink.
7 Q. And you were reminded of that by
8 Miss Miller; correct?
9 A. Yes.
10 Q. Is there any other information that
11 she has been giving you that you need to
12 re-evaluate your previous testimony?
13 A. Not that I recall.
14 Q. So other than failing to mention
15 Brady Couvillon with the LIDAR, do you stand
16 by all of your previous testimony?
17 A. Yes.
18 Q. Did you provide Dr. Westerink with
19 any elevations of vegetation at any time?
20 A. I wouldn't have provided that. That
21 would have either been through -- probably
22 through -- I'm pretty sure that Greg Stire
23 provided elevations from the CRIMS stuff I
24 have already told you. The CRIMS information,
25 the station information, marsh elevation.

120
1 Q. What makes you pretty sure that he
2 would have provided that?
3 A. Because that's what he's been
4 working on for quite a while as part of the
5 data he's been gathering.
6 Q. Do you know what a Manning
7 coefficient is, coefficient of friction?
8 A. I'm heard the term, but I am not
9 that familiar with it.
10 Q. Have you provided any information to
11 Dr. Westerink regarding the Manning
12 coefficient of a particular vegetation within
13 one of your 25 by 25 meter grids?
14 A. The only question that I had
15 regarding a Manning coefficient, which was
16 incidental, was the question of swamp, that
17 conversation we had I think it was this Monday
18 about the swamp type. You know, what do you
19 consider a swamp forest.
20 Q. Would it be above 20 feet?
21 A. Above 20 feet, yeah.
22 Q. Who is John Atkinson? Do you know?
23 A. I've heard the name, but I don't --
24 Q. He's not somebody that works with
25 you --
121
1 A. No.
2 Q. -- or on your team?
3 A. Uh-uh (negatively).
4 Q. Do you know whether you would have
5 had any discussions with a John Atkinson?
6 A. I think he may have been on one of
7 the conference calls. I'm not certain.
8 Q. You want to go discuss that with
9 Miss Miller?
10 MS. MILLER:
11 Objection.
12 MR. JOANEN:
13 I think it's a fair question.
15 Q. You can update your testimony.
16 Maybe you want to talk to her. I want you to
17 be clear.
18 A. No, that is cool.
19 MS. MILLER:
20 The witness doesn't remember
21 exactly who was on the phone call.
22 THE WITNESS:
23 No.
24 MR. JOANEN:
25 You'll straighten him out; right?

122
1 MS. MILLER:
2 To the extent I can, I can try
3 and remind him.
4 MR. JOANEN:
5 Excellent.
7 Q. This guy Brady Couvillon, what's his
8 involvement with you?
9 A. He's been contract -- a contract
10 employee. Actually not employed, but a
11 contractor for I think the last three or four
12 years with the USGS. Through IP -- John- --
13 it used to be Johnson Controls World
14 Services. IPET.
15 Q. Do you know whether he's been
16 associated with a company called 3001, Inc.?
17 A. No.
18 Q. Are you familiar with any of the
19 LIDAR data that was obtained by 3001, Inc.?
20 A. Well, yes, but, I mean, I -- I don't
21 really use LIDAR much myself.
22 Q. And the information that Brady
23 Couvillon was providing on this telephone
24 conversation, what is your understanding of
25 the usefulness of that information?
123
1 A. It is to provide elevation surfaces,
2 kind of a continuous elevation surface across
3 the marsh or landscape.
4 Q. And would that be topography and
5 man-made features such as levees and
6 floodwalls or would that be --
7 A. It would include the elevation
8 features on the landscape.
9 Q. Would it also include elevation
10 features of vegetation?
11 A. Yes. Actually, it would be the bare
12 earth based on the 2000 3001 data. They
13 interpret -- They interpolate what is the --
14 what they think the base elevation is. So I
15 can't -- It really wouldn't be the elevation
16 of vegetation. It would be the bare earth,
17 the final product.
18 Q. So would it be safe to assume, based
19 upon your information, your understanding of
20 the information provided via LIDAR, that the
21 entirety of Dr. Westerink's analysis of the
22 height of vegetation would come from the 25 by
23 25 meter grids?
24 MS. MILLER:
25 Objection.
124
2 Q. Is that correct? Is that correct?
3 A. I can't speculate on that.
4 Q. No, your understanding.
5 MS. MILLER:
6 Objection.
7 THE WITNESS:
8 I -- No. I would agree with
9 that.
11 Q. I couldn't -- Your Counsel was
12 objecting. What was your answer?
13 A. No, the elevation information, I --
14 I don't know what -- how he derived it.
15 That's just one possible source of elevation
16 information.
17 Q. It didn't come from you
18 necessarily? It may have been within the
19 information you provided, but you didn't tell
20 him at any time, other than just telling him
21 this past Monday that swamps are 20 feet, you
22 didn't ever tell him that the vegetation
23 elevations along a particular area within the
24 Lake Pontchartrain basin were at a certain
25 height; correct?
125
1 A. No, --
2 MS. MILLER:
3 Objection.
4 THE WITNESS:
5 -- I wouldn't have provided that
6 information. Could I clarify
7 "provided"? Are you still referring
8 to the information Greg Stire provided
9 or I personally provided?
11 Q. You personally.
12 A. No.
13 Q. Did you ever pick up the phone and
14 say, "Hey, Dr. Westerink, it's marsh, it's a
15 meter"?
16 A. No, I wouldn't have. No.
17 Q. Do you have specific recollection of
18 what information Greg Stire provided to Dr.
19 Westerink?
20 A. What I can recall to the best of my
21 ability was the elevation information from the
22 monitoring stations. The CRIMS monitoring
23 stations.
24 Q. Where are those located?
25 A. Well, they're scattered throughout

126
1 the coast. Across the coast. They sample,
2 they -- They have got several hundred of them
3 that they sample.
4 Q. To your knowledge, do you know how
5 many are in the MRGO assessment area?
6 A. No, I don't.
7 Q. Do you know if there are any within
8 the MRGO assessment area?
9 A. There would be some I'm sure, but I
10 don't know how many.
11 Q. What makes you think that there
12 would be some?
13 A. Because the stations are
14 systematically arrayed by marsh type across
15 the coast. So I would assume the odds are
16 they would have some stations falling within
17 that area.
18 Q. What information -- If I asked you
19 to confirm that, what information would you
20 turn to try and get a conclusive answer?
21 A. The CRIMS monitoring station data
22 set.
23 Q. That's CRIMS?
24 A. Yes.
25 Q. Is that an acronym for something?
127
1 A. Coastal Resource Information
2 Management System.
3 Q. And is the evaluation of the height
4 of vegetation, is that something that's
5 standard or is that something that's evaluated
6 for a particular region?
7 A. That's actually outside of my area
8 of expertise. I don't deal with that
9 generally.
10 Q. Would any of the conversations that
11 Mr. Stire may have been having that you were
12 on discuss the impact of various vegetation on
13 the flow of water passing over an area?
14 A. I don't recall.
15 Q. The same question, any of the
16 information regarding -- that you recall Dr.
17 Stire may have provided to Dr. Westerink that
18 involved the effect or the impact of the
19 vegetation on the wave activity of the water
20 passing over that vegetation?
21 A. I don't recall.
22 Q. If that type of conversation would
23 have been going on, would that have been
24 something that you would have been able to
25 engage in in a meaningful professional way --
128
1 A. No, not --
2 Q. -- such that you were adding --
3 A. Not on the surge height information.
4 Q. How about when we talk about the
5 fetch of an area that allowed for the
6 generation of waves; would that be something
7 that you would be able to engage in a
8 conversation with?
9 A. I am familiar with the term, but I
10 wouldn't -- I couldn't apply myself to -- for
11 hydrologic modeling or surge modeling.
12 Q. Do you recall whether on any of the
13 conversations that you had with -- on
14 telephone conversations, conference calls with
15 -- that involved any of the experts, whether
16 you added anything to any discussions that may
17 have included fetch and its impact on
18 generation of waves?
19 MS. MILLER:
20 Objection.
21 THE WITNESS:
22 I don't recall. It's outside my
23 area of expertise. I don't recall.
25 Q. How about the effect of wind on the
129
1 generation of waves?
2 A. That's something, no, I wouldn't
3 have.
4 Q. How about the bathymetry of a body
5 of water and its effect on wave heights and
6 the types of waves?
7 A. No. No.
8 Q. How about bathymetry of a body of
9 water and its effect on wave periods?
10 A. No.
11 Q. Do you know whether you were on any
12 telephone conversations with any experts in
13 which someone was providing that information
14 to Dr. Westerink?
15 A. That may have been discussed, but
16 usually when they -- if that information was
17 brought up, I have nothing to add and I was --
18 that's not my area of expertise.
19 Q. When -- If in fact any of these
20 conversations would have been taking place,
21 would they have turned to you and asked you to
22 update any of the information that you would
23 have already provided to Dr. Westerink --
24 A. No.
25 Q. -- or to DOJ that was likely
130
1 provided to Dr. Westerink?
2 A. I was not asked to update any
3 information.
4 Q. Okay. In Dr. Westerink's report, he
5 has what's listed as Exhibit 55, and I am not
6 going to mark this as an exhibit, but I'll
7 just show it to you and point it out to you,
8 this is from page 120 of Dr. Westerink's
9 expert report, I'll show you that and give you
10 a chance to look at it. I'll ask you a couple
11 of questions about it.
12 A. Yeah.
13 Q. Okay. Have you seen this polygon
14 before?
15 A. Yes.
16 Q. And just for clarification of the
17 record, this is Exhibit 55. It says "Land use
18 within MRGO region of influence in 1956 across
19 2008"?
20 A. Yes.
21 Q. This would be an area that would
22 indicate that this figure right here is
23 included in a 2008 report that you produced.
24 Is that correct?
25 A. I didn't include the figure. I have

131
1 the statistics for it.
2 Q. Okay. Did you ever provide this
3 polygon to Dr. Westerink in this
4 configuration? With nothing else around it,
5 just the interior of that configuration?
6 A. Well, I would assume either he
7 extracted it or I did. I don't recall if I
8 did that or not. I ran the -- I know I ran
9 the area numbers for him.
10 Q. And what does that mean when you run
11 the area?
12 A. The habitat. It's all the
13 summation. You're basically taking the
14 polygon and -- It's included here in the
15 spreadsheet and stuff.
16 Q. And then he indicates on here brown
17 represents non-fresh marsh.
18 A. Correct.
19 Q. Did you put the colors in here to
20 indicate the types of vegetation?
21 A. That's from the original 1988 coding
22 scheme. That's transferred with the data.
23 Q. Okay. This says land use within
24 MRGO region of influence in 1956. So if I
25 read this, it would tend to lead me to believe
132
1 that this is proposed to be an accurate
2 depiction as best can be done of this area in
3 1956.
4 A. Correct.
5 Q. Okay. Well, when I say here the
6 brown represents non-fresh marsh, you indicate
7 that there were '88 scheme with that. Why
8 would there be information regarding the '88?
9 A. '88? No, that's a 19- -- that would
10 be a 1956 color scheme. Non-fresh was only
11 included in the 1956 category.
12 Q. Okay. So when we say brown
13 represents non-fresh marsh, that statement,
14 was that something that you -- Obviously Dr.
15 Westerink had that typed in here, was that
16 something that you provided to him, that brown
17 would represent non-fresh marsh?
18 A. That's included in the -- That's
19 embedded in the files, those color -- Those
20 files come with standard color scheme and that
21 would be embedded; the pixel, it'll have the
22 value of the -- the grid value. You know, if
23 it's non-fresh marsh and it'll have a red,
24 green, blue value that corresponds to that
25 brown and displayed on a screen.

133
1 Q. Okay. And then tan represents fresh
2 marsh. Is that something that would --
3 A. Well, a lighter tan, yeah, a kind of
4 beige color is fresh marsh.
5 Q. That would indicate that there's in
6 1956 --
7 A. There was fresh marsh.
8 Q. -- what you're saying is there was
9 fresh marsh there?
10 A. Not what I am saying. What the
11 national photo interpreters are saying.
12 Q. You have no input into that?
13 A. No.
14 Q. You don't express an opinion on
15 that? That was something that was provided to
16 Dr. Westerink through you? You pulled that
17 off the shelf and --
18 MS. MILLER:
19 Objection.
20 THE WITNESS:
21 Considering I was a junior in
22 high school when it was interpreted,
23 yes.
25 Q. With the dark brown representing
134
1 agricultural pastoral, was that something,
2 that statement, would that be something that
3 Dr. Westerink would get from you?
4 A. That would have been embedded in the
5 data.
6 Q. And you didn't alter that data in
7 any way?
8 A. That source is the same stuff that
9 was available in 1988.
10 Q. And red represents developed areas?
12 Q. That again is something that was
13 just embedded in the source data?
14 A. Yes.
15 Q. Do you know whether this type of
16 information that was provided to Dr. Westerink
17 was ever run with an additional input of LIDAR
18 data?
19 A. I --
20 MS. MILLER:
21 Objection.
22 THE WITNESS:
23 I don't know.
25 Q. And just so I am clear, your
135
1 testimony is you don't know whether you
2 provided this exact polygon to him or whether
3 you provided the entire region and he would
4 have pulled this polygon out?
5 A. I don't recall. I mean -- I mean, I
6 had the polygon. I ran all the area numbers
7 and stuff, statistics for him.
8 Q. And when you say you ran the numbers
9 and the statistics, is that going to be
10 included in your expert report?
11 A. That's right. It's in the
12 appendix. I mean, I didn't discuss it
13 directly in the report, but it's in the
14 tables.
15 Q. We're going to go through the
16 report. I am thinking it might be a good time
17 to break for lunch. Let me make sure there's
18 nothing else to follow up on this and then
19 maybe we'll take a break for lunch and go
20 through your report.
21 MR. JOANEN:
22 Off the record.
23 VIDEO OPERATOR:
24 Off the record.
25 (Recess.)
136
1 VIDEO OPERATOR:
4 Q. Mr. Barras, one of the things I
5 wanted to cover before we broke for lunch and
6 I just missed it, I wanted to find out your
7 involvement with the other experts. I know
8 you've interacted with Dr. Westerink and some
9 degree Mr. Ebersole. What was your
10 understanding of your role as part of the
11 expert defense team? What would you provide
12 to that team?
13 A. Basically to provide the habitat
14 information that we typically provide to the
15 Corps of Engineers or to other Federal
16 partners for wetland project screening.
17 Q. Was it your understanding that
18 information would be provided to any experts
19 other than Dr. Westerink?
20 A. I understood it would be provided to
21 all experts involved in the litigation.
22 Q. Do you know whether -- I don't know
23 if it's Dr. Resio, Donald Resio or Mr. Resio,
24 do you know whether he relied on your habitat
25 data?
137
1 A. I do not.
2 Q. Do you know whether Dr. Britsch
3 relied upon the information, the habitat
4 information you provided?
5 A. Dale did -- I think he had looked at
6 some of the habitat information.
7 Q. Do you know to what degree he relied
8 upon that in formulating his opinions?
9 A. No, I don't.
10 Q. Do you know as you sit here to what
11 degree Dr. Westerink relied upon the
12 information you provided him in formulating
13 his expert opinion and expert report?
14 A. No, I do not.
15 Q. Mr. Ebersole is another expert. Do
16 you know what degree -- to what degree he
17 would have relied upon the information you
18 provided in formulating his opinion and
19 report?
20 A. No, I do not.
21 What's that? Oh, tables, area
22 tables?
23 Q. No, it's the names of people.
24 A. Oh.
25 Q. I don't know if it's Mr. Wolfe or
138
1 Dr. Wolfe. He's also one of the experts for
2 the defense. Do you know whether he relied
3 upon your information --
4 A. No, I do not.
5 Q. -- for his opinion or expert report?
6 A. I'm sorry. No, I do not.
7 Q. Mr. Jarvinen, he was a hurricane
8 analyst. Do you know whether he relied upon
9 your information in formulating his expert
10 report or expert opinion?
11 A. No, I do not.
12 Q. I don't know, Deloche, I don't know
13 if it's Mr. or Dr. Deloche. He does LIDAR --
15 Q. -- information, as I understand it.
16 Do you know whether he relied upon any of the
17 information that you produced to the
18 government in formulating his expert opinion
19 or report?
20 A. No, I do not.
21 Q. Do you know whether LIDAR, there's a
22 margin of error for LIDAR?
23 MS. MILLER:
24 Objection.
25 THE WITNESS:
139
1 I'm not a LIDAR expert.
3 Q. If I were to tell you that there's a
4 margin of error of 3.3 feet, would you be in a
5 position to agree or disagree with that?
6 A. I would defer to LIDAR experts.
7 Q. There is a -- There's a Steve
8 Fitzgerald who is an expert for the defense.
9 A. This is not Duncan Fitzgerald?
10 Q. No. Correct.
11 A. No.
12 Q. There's a Steve Fitzgerald.
13 A. Okay.
14 Q. Do you know whether Steve Fitzgerald
15 relied upon your information in formulating
16 his expert opinion or expert report?
17 A. No, I do not.
18 Q. And then finally there's an
19 individual by the name, last name Mocher or
20 Mozier. Do you know whether he relied upon
21 your information in formulating his expert
22 opinion or report?
23 A. No, I do not.
24 Q. Of those experts, and I will run
25 through them, it's Westerink, Steve
140
1 Fitzgerald, Jarvinen, Ebersole, Blitsch,
2 Wolfe, Resio, Deloche, and Mocher, have you
3 read their expert reports to determine whether
4 any of the information in their reports
5 contains the information that you had provided
6 to the government?
7 A. I haven't read all of the expert
8 reports, no. I looked, briefly looked at
9 Westerink's. Look's at Dale's, Dale Blitsch's
10 and obviously your expert witnesses.
11 Q. Right.
12 A. I looked through some of the
13 reports.
14 Q. With Dr. Westerink's report, other
15 than that Exhibit 55, or figure 55 that I
16 showed you before the break, do you know of
17 any other information that is contained in his
18 expert report that you would have provided?
19 A. I wouldn't have -- No, not that I
20 would have directly provided.
21 Q. What about indirectly provided?
22 A. Indirectly would have been the
23 information we discussed prior to lunch with
24 the elevation information, which I didn't
25 provide directly, but it was provided by

141
1 colleagues.
2 Q. Okay. Is there a table or a
3 conversion chart that we could reference to
4 know whether, when Dr. Westerink would have
5 looked at the 25 by 25 grid within a
6 particular area, especially the MRGO
7 assessment unit, what information he would
8 have had regarding the elevation of the marsh,
9 or elevation of the vegetation?
10 MS. MILLER:
11 Objection.
12 THE WITNESS:
13 I don't -- Except for the
14 information that I indirectly knew,
15 you know, through the colleagues,
16 that's all I know about.
18 Q. In your testimony, or in -- I
19 believe you said you reviewed Dr. Westerink's
20 testimony?
21 A. Briefly. I didn't look at it in
22 depth.
23 Q. Did you have the opportunity to
24 review it in such a fashion that you would be
25 able to confirm that the information you
142
1 provided to him was used accurately?
2 MS. MILLER:
3 Objection.
4 THE WITNESS:
5 I -- That would be in Dr.
6 Westerink's realm of expertise. I
7 provided the source information that I
8 had to him.
10 Q. In reviewing his expert report, did
11 you go back and look to see whether the source
12 information that you provided is contained in
13 his report in the exact fashion or exact
14 figures that you presented to the Department
15 of Justice that ultimately ended up in Dr.
16 Westerink's report?
17 A. I did not.
18 Q. Have you had a chance to review Dr.
19 Westerink's deposition transcript? His
20 testimony --
21 A. I have not.
22 Q. -- that has been taken in this --
23 A. I have not.
24 Q. Have you had any conversations in
25 preparation for your deposition, other than
143
1 the one with the phone call and they wanted to
2 know what your evaluation of the swamp, would
3 it be higher than 20 feet? Have you had any
4 other conversations regarding the testimony of
5 Dr. Westerink?
6 A. No.
7 Q. What did you do to prepare for your
8 deposition today?
9 A. To prepare for the deposition? I
10 reviewed my report and reviewed Dale Blitsch's
11 report. I went ahead and looked at some of
12 the -- reviewed the figures and the
13 information in the Fitzgerald report, Duncan
14 Fitzgerald's report, or actually Shea
15 Penland's, I guess, whatever, you know. I
16 mostly focused on my area of expertise, which
17 would have been either the land loss or just
18 the habitat summations.
19 Q. If you're presented in Court and the
20 Judge, without -- say your attorney didn't ask
21 you a leading question and prepare you for
22 your testimony, if the Judge says, "You're
23 here before us today to provide an opinion, to
24 give an opinion," you have to be qualified as
25 an expert, what field would you ask the Judge
144
1 to qualify you in as an expert?
2 MS. MILLER:
3 Objection.
4 THE WITNESS:
5 Probably in land loss assessments
6 and measurements.
8 Q. Okay. And your level of expertise,
9 that is developed through your experience
10 obviously in the years of handling the
11 computer programs and the data sets?
12 A. Well, handling the data and
13 interpreting the newer data.
14 Q. And I apologize if I am
15 oversimplifying things, because I do not
16 understand how your computer programs and how
17 you actually do your work, and I go back to
18 the simple thing where you take an overlay
19 from one year, put another overlay and you can
20 tell where things are changing, you can say
21 all right, this particular area, there's a
22 loss. Does a computer program do that in a
23 more specialized format or a better way than
24 the map overlay?
25 MS. MILLER:
145
1 Objection.
2 THE WITNESS:
3 Well, the computer program, it
4 will do it in a more accurate, precise
5 manner than -- When you say map
6 overlay, please explain what you mean.
8 Q. Well, I'll give you a great
9 example.
10 A. Okay.
11 Q. If you look at Duncan Fitzgerald's
12 report, --
13 A. Yeah.
14 Q. -- and he has like this legend which
15 will be on --
16 A. Yeah.
17 Q. -- 3.9, where you have what the
18 island looked like on a certain year and then
19 another year and another year, and you can see
20 by putting the various things in place, --
21 A. Yeah.
22 Q. -- and I can see with the computer
23 you can put it there, but in the old days when
24 you used to have that clear film and you had
25 the overhead projector, you would have a piece
146
1 of clear film with a figure on it and then you
2 had another piece of clear film and then you
3 would see, as it built up, the changes. Now,
4 with the computer obviously you can do it all
5 in one scale. But this is what I am
6 considering an overlay, where you can look at
7 this and say in green it was a certain year,
8 this is where the island was, and then you can
9 see by the different years and the way it's
10 laid that it's migrating in one fashion or
11 another. So by "overlay", that's what I am
12 talking about. Does your computer program,
13 does it generate this type of overlay so that
14 you can understand where the land loss was?
15 A. It's probably exactly the same
16 program, a similar program, either RGIS used
17 by the consultant to generate those particular
18 overlays.
19 Q. So the program that you used would
20 be the same program --
21 A. Well, it would be similar. He may
22 be using RGIS or DOS Match. But it's
23 basically using the software to combine
24 different dates in time to provide a spatial
25 representation of change.

147
1 Q. When you are running the software
2 program, are you doing anything more than
3 altering inputs to see how things go, or are
4 you in any way altering the computer program
5 itself, the code that the computer runs on?
6 A. Do you mean are you actually
7 programming the changes for the analysis or
8 are you just changing the inputs?
9 Q. Yes.
10 A. It's changing the inputs into the
11 analysis.
12 Q. When you're making your mapping data
13 and you're changing the inputs, is there a
14 quality control procedure in place to make
15 sure that what you see on the screen is
16 actually what's happening? Does that get sent
17 out to the people in the field who would say
18 -- Let's say, for example, a certain area of
19 Breton Island has disappeared and you have
20 that computer input and you put the input in
21 there. Do you then have that double-check to
22 make sure that you don't, say, just transpose
23 numbers one day, so instead of being minus,
24 say, .01, it's minus .1?
25 A. You can have errors in transposing

148
1 the area tables, but the actual change
2 analysis, it's -- you're not going to be
3 checking -- you're not checking the accuracy
4 of the change analysis. What you would check
5 is the accuracy of the source data set used to
6 comprise the change analysis, and those are
7 generally checked. Now, with the older data
8 sets that would have been something that the
9 National Wetlands Inventory people did.
10 Q. Okay. And when you say the older
11 data sets, is that --
12 A. 1956, 1978, and then 1988.
13 Q. '88. Okay. But the new ones now,
14 those are the ones that are --
15 A. Satellite generated.
16 Q. Right. Those are not considered the
17 older source data?
18 A. Correct.
19 Q. Older data sets?
20 A. Correct.
21 Q. If, hypothetically, if Dr. Westerink
22 had taken your information and adjusted it in
23 some way to meet his -- Obviously it's a
24 computer model. If he had adjusted the
25 information in some way to fit the outputs of
149
1 the models that he needed, and I will give you
2 an example, I don't know how much you know
3 about the modelings, but you run the computer
4 program and there is a theoretical high water
5 mark pursuant to this model.
7 Q. Then they try and correlate a
8 particular spot in the world where the high
9 water was in the model and compare an actual
10 high water mark that someone in the field
11 saw. And if it's off, there's may be some
12 changes in calculations. The change in those
13 calculations is the thing that's very much
14 part of the inquiry regarding the models.
16 Q. If Dr. Westerink had changed some of
17 the information that you had given to him,
18 would you have been able to, in the limited
19 review you did in his report, figure out what
20 changes he would have made?
21 MS. MILLER:
22 Objection.
23 THE WITNESS:
24 The information -- I provided the
25 source information to him. I had no
150
1 control over what was done to the
2 information after that.
4 Q. Okay. If Dr. Westerink in his
5 models were to evaluate the habitat in a
6 certain spot and give it a coefficient of
7 friction, would you know whether that
8 coefficient of friction would be established
9 by the density or height of the vegetation in
10 the area?
11 A. Not my area of expertise.
12 Q. If Dr. Westerink were to look at
13 your habitat area and equate that as brackish
14 marsh, do you know where he would get the
15 information to say that it had a certain
16 density or a certain height?
17 A. No, I do not.
18 Q. Do you know whether the information
19 that is in one of those 25 by 25 grid pixels
20 has the information contained in that?
21 A. The only information --
22 MS. MILLER:
23 Objection.
24 THE WITNESS:
25 -- that that grid would have

151
1 would be what it's coded as, that
2 pixel is coded as, so in that precise
3 spatial location that you pick, it
4 would be identified as brackish,
5 fresh, intermediate, or saline marsh,
6 period.
8 Q. That's it?
9 A. Yes.
10 Q. Are those the four categories, or
11 are there more?
12 A. There are more categories.
13 Q. And how many categories are there?
14 A. I think 14. I'd have to go back and
15 pull it up off the --
16 Q. Was that the things you showed us
17 before?
18 A. Yes. That table we went through
19 earlier, yes.
20 Q. One of those is cypress forest,
21 cypress swamp; correct?
22 A. Swamp. In the 1956 and 1978 data
23 sets, it's swamp. 1988, it was -- they have a
24 cypress forest identified.
25 Q. In southeastern Louisiana, is it
152
1 within your area of expertise to know that
2 when they're referring to swamp, they're
3 referring to freshwater cypress forests,
4 cypress tupelo forest?
5 A. Not necessarily. Just cypress --
6 That's a generic term. But again, that's also
7 -- 1956 and 1977 habitat data, the way they
8 were coded, also included willow swamps and
9 swamp maple and other types, a little broader
10 characterization of swamp.
11 Q. And as you sit here today, would you
12 know the density of what those tree stands
13 would be or what the heights of a willow or
14 swamp maple --
15 A. You would view aerial photography to
16 identify the density.
17 Q. Is that something that's within your
18 range of expertise, to review aerial
19 photography to determine whether the density
20 or heights of a particular area matches with
21 what your grid may indicate?
22 MS. MILLER:
23 Objection.
24 THE WITNESS:
25 I could -- I -- Most of what the
153
1 aerial photography information I do is
2 actually looking at land-water
3 patterns, although I can -- you know,
4 you can identify cypress, or at least
5 forest from the aerial photography.
7 Q. You say land-water or land border?
8 A. Land and water characterizations.
9 Q. Land and water. Okay. When you say
10 land and water characterizations, you're
11 saying that there is land here and water
12 there, or are you looking at the land in
13 determining what type of habitat it is? Like
14 are you classifying land when you're doing
15 this?
16 A. It's just classifying it as land,
17 yes.
18 Q. Nothing more than it is just land?
19 A. Yeah. Yeah, for the recent -- for
20 the recent work.
21 Q. In your just previous statement you
22 indicated your recent work, land and water.
23 Are you referring to work for this litigation
24 or --
25 A. No, it's -- the work wasn't done for

154
1 this litigation. The data sets were used, but
2 it was for other research projects.
3 Q. When you were tasked to perform your
4 analysis and produce an expert report, other
5 than reading Dr. Shay's and the reports that
6 we have gone through, what was the next step
7 that you did in preparing yourself to produce
8 a report?
9 A. To produce a report? Besides
10 reading those, was actually doing the actual
11 analysis and providing the area summations and
12 change assessments.
13 Q. So when you do your actual analysis,
14 can you just tell me what it is you did?
15 A. What you're doing is are extracting
16 the areas, defining the areas first. You base
17 the areas and then you go ahead and extract
18 the area summations from the source habitat
19 data sets to characterize or to provide areal
20 summaries. Areal, I mean the actual areal --
21 area statistics. Summaries for those
22 particular habitat types based on how you were
23 measuring the configuration on the land, your
24 assessment area on the land.
25 Q. Okay. And what areas did you decide
155
1 that you would evaluate in furtherance of your
2 producing an expert report?
3 A. After reviewing Penland's report and
4 Fitzgerald's report, I looked at the area so I
5 could decide -- I wanted to use exactly the
6 same area that they were using roughly to
7 provide a like comparison.
8 Q. Is that going to be the Lake
9 Pontchartrain basin?
10 A. Well, it includes parts.
11 Technically it includes the Lake Pontchartrain
12 basin, half of the -- not even -- about half
13 of the Lake Pontchartrain basin. The west --
14 the eastern components and the Breton Sound
15 basin, out to the Chandeleur Islands.
16 Q. Okay. And you would have utilized
17 the old data sets which was '56, '78, and '88?
18 A. Yes.
19 Q. Had you performed any of these
20 calculations before this, or was this the
21 first time you were comparing those data sets
22 for that particular area?
23 A. Rephrase. Have I used these data
24 sets in other --
25 Q. Yes.
156
1 A. -- analyses?
2 Q. The analysis that you did to start
3 to come to your conclusions about land loss
4 data, had you utilized the data sets for '56,
5 '78, and '88 in the Lake Pontchartrain basin
6 and come to a conclusion before on a different
7 project? For example, say in 1999, you just
8 had something else going on, you did it and it
9 was there anyway, or was this the first time
10 you were using these data sets?
11 A. No, the data has been -- has been
12 used before. Not all of the -- The latest
13 information was used for this -- As land-water
14 updates are provided to Coast, we go ahead and
15 continue to plug that into the process.
16 Q. And that's why I was kind of
17 focusing just on the older data points.
19 Q. Did you have already an analysis
20 available to you that you could rely on to
21 start and then utilize the new data sets and
22 not have to analyze '56, '78, and '88?
23 A. They had older analyses available,
24 but it wasn't to the specific areas that I
25 wanted to address for this particular study.

157
1 Q. Okay. And not to make it seem
2 overly simple, but I am trying to make sure --
3 you weren't reinventing the wheel? This
4 wasn't already done? Or were you?
5 A. No, the Pontchartrain basin has been
6 summarized before, but not in the manner that
7 was used for the -- for the litigation. This
8 particular litigation.
9 Q. Okay.
10 A. Now, there was the -- the Louisiana
11 coastal area mapping units I think were used
12 by some -- Actually, I know I provided that
13 data to Shea Penland. So I know that was
14 used, utilized in this report. I -- In the
15 beginning of my report I stated why I actually
16 changed the configuration slightly from those
17 units to better isolate forests within fast
18 land areas.
19 Q. To your knowledge, were there any
20 fast land areas in the MRGO assessment unit
21 that was identified by Dale Blitsch?
22 A. Would you mind showing me the
23 picture again?
24 Q. Oh, yes.
25 A. Sure.

158
1 Q. And again, just for clarification of
2 the record, this is the Blitsch report, page
3 4.
4 A. I'm sorry, I've got it --
5 Q. Figure 2.
6 MS. MILLER:
7 And I'll just make an objection
8 to the question being vague as to the
9 time frame you're asking about.
10 THE WITNESS:
11 I would like to go back and check
12 it against the fast land data, but I
13 think it excludes fast lands for the
14 most part.
16 Q. Okay. In the evaluations that you
17 were doing, you said you had to make some
18 adjustments to the Lake Pontchartrain basin
19 information to include the fast lands. That
20 would not have affected the evaluation of the
21 habitat within this study area?
22 A. No. The basin -- The modifications
23 aren't going to affect the source habitat
24 information. It's just where you're
25 measuring.

159
1 Q. And the old data sets from '56, '78,
2 and '88, did they have any quantifications
3 isolating the area that is this study area, or
4 was it just for the whole Lake Pontchartrain
5 basin?
6 A. It would have been -- Older studies
7 would have used the Lake Pontchartrain basin
8 or the Lake Pontchartrain basin excluding fast
9 lands.
10 Q. As you sit here today, can you tell
11 me what the total acreage is within this
12 polygon, this study area?
13 A. Not unless I pull it up off the
14 spreadsheet.
15 Q. And you will have that in your
16 report?
17 A. Yes, all of that information is in
18 the report.
19 Q. Let's talk about your report. You
20 said that the first time that you put pen to
21 paper was in November of '08, October of '08?
22 A. Yes. No, I had actually run the
23 change analysis before that. So it was quite
24 a bit of work to run up the statistics.
25 Q. And how did you go about running the
160
1 change analysis?
2 A. First you had to define the actual
3 area which is defined in the methodology that
4 was used to break out the units. And I think
5 I have -- If you look at my report on -- Let's
6 see where the big maps are. Okay. Let's
7 see. If you look at I guess it would be page
8 23 and it's got XJB-00127.
9 Q. Okay.
10 A. These actually define -- This
11 defines how the basic area of -- how the area
12 was broken down for analysis.
13 Q. You have in that document, you have
14 a yellow dotted line which is the USACE --
15 A. Yes.
16 Q. -- MRGO model?
17 A. It's the same figure you're showing
18 me.
19 Q. Where did you get that layout? Was
20 that from Dale Blitsch?
21 A. Yes.
22 Q. In the first line of that
23 introduction, it says "The purpose of the
24 document is to summarize historical changes in
25 forested habitats and land loss trends."
161
2 Q. What do you mean by land loss
3 trends?
4 A. You look at the figures with the --
5 Trying to see where this is at. If you go to
6 -- Let's see. It would be XJB-120, 121 -- I
7 think 119 through 122, it actually provides
8 recent -- recent annualized rate trends based
9 on regression analyses while the data sets --
10 We talk pretty fast where I am from --
11 analysis of the data sets, of the land-water
12 data sets to provide trends from the 1985
13 through 2006 period. What that does is it
14 just provides you an annualized land loss rate
15 per year for that particular unit, or area of
16 interest.
17 Q. And do your land loss trends include
18 the unit that is defined within the polygon,
19 the MRGO study area?
20 A. MRGO. Yeah. I have that in there.
21 Just have to find out which one it is. It's
22 COE -- It's the last graph. "COE MRGO study
23 area, land area trends. It's page 122, the
24 very last graph.
25 Q. And would that, this polygon, do you
162
1 understand that there are different areas in
2 it, including one being the Central Wetlands
3 Unit?
4 A. Yes. That's the LCA unit.
5 Q. And do your land loss trend graphs
6 indicate the land loss within the Central
7 Wetlands Unit?
8 A. It's actually composed -- The way I
9 broke it down was composed into the Chalmette
10 unit and the Proctor Point to golden triangle
11 unit. So those graphs are there, but it's
12 separating the two different units.
13 Q. And when you say Chalmette unit,
14 you're talking about what is also in Dale
15 Blitsch's report as figure 3, is the Central
16 Wetlands Unit?
17 A. It contains portions of it, but it's
18 not -- It -- His -- That particular unit that
19 he has, the Central Wetlands Unit I actually
20 split into two units.
21 Q. Okay. And what was the line of
22 demarcation that you -- when you decided to
23 split it into two units?
24 A. The line of demarcation was the 1956
25 fresh marsh boundary with a 100 meter buffer

163
1 on it that was designed to basically isolate
2 fresh and swamp categories, forest categories
3 from wetland areas.
4 Q. Was that mark the LaLoutre Ridge?
5 A. No, the LaLoutre -- Well, the
6 LaLoutre Ridge is another assessment unit to
7 isolate the ridges.
8 Q. Okay. That line of demarcation,
9 where did it fall in the map?
10 A. Well, I think it's better to refer
11 to -- These maps are kind of small, but --
12 Actually, this is -- Here you go. This is
13 even better. If you go to 033, XJB-033, if
14 you look at this blue line, that's -- it's --
15 if you can see this lighter color underneath
16 --
17 Q. XJB-033? Where are you? 1930 T
18 sheet?
19 A. Yeah.
20 Q. Okay.
21 A. If you look at the blue line, it
22 actually follows the fresh marsh in 1956,
23 which was prior to the MRGO construction, with
24 a 100 meter buffer on it, and that is what I
25 defined as the Chalmette wetlands.

164
1 MS. GILBERT:
2 Can you cite that exactly for the
3 record?
4 MR. JOANEN:
5 What's that?
6 MS. GILBERT:
7 Can you identify the document,
8 the title of the document for the
9 record?
10 MS. MILLER:
11 I think he listed the Bates
12 number, XJB-001-, the bunch of zeroes
13 in 33.
14 MS. GILBERT:
15 When they were produced, they
16 didn't get those.
17 THE WITNESS:
18 Oh, it's the Hurricane Katrina
19 MRGO assessment units, 1956 habitat
20 data with 1930 T sheet tree area.
21 MS. MILLER:
22 The second-to-last of the big
23 colored pages in his report.
25 Q. And so it's your testimony that the
165
1 1956 data point, the freshwater marsh or
2 cypress freshwater forest -- freshwater --
3 fresh marsh?
4 A. Fresh marsh, yeah.
5 Q. Was on the river side of that light
6 blue line as it snakes through that whole
7 unit?
8 A. The river side. I'm sorry. You
9 lost me.
10 Q. This is the river (indicating).
11 A. Yeah. Okay. It's on the -- No,
12 this is on the east bank of the Mississippi
13 River. Actually past the 40 Arpent Canal, the
14 Chalmette.
15 Q. Okay. Do you have land loss trends
16 data analysis for 1956 to 1978?
17 A. They are included in the
18 spreadsheets. I would have to go through
19 this. It's actually in the area tables. I
20 would have to find it. But it's included in
21 the spreadsheet. Each one of these units was
22 broken out. I am just going to give you an
23 example unit. This would be 100. XJB-100.
24 If you go and look at the bottom table, this
25 will produce actual change, net land area

166
1 change and the period, year period. Some of
2 the table was cut off. There would also be an
3 annual trend rate there. But it's also
4 contained in the spreadsheet.
5 Q. The annual trend rate, is that
6 information taken on each particular year or
7 is it an average of a number of years in
8 between two points?
9 A. There's only two data measurement
10 points separated by 22 years, so it's just an
11 average. By tradition, land loss changes in
12 Louisiana have been represented as a rate per
13 year. And a lot of folks prefer seeing that
14 versus net rates.
15 Q. Well, let me ask you a question on
16 that. Is it possible, if there's changing
17 ecological conditions, that the annualized
18 rate per year would not be an accurate
19 depiction of what actually happens?
20 A. I'm glad you asked me that. That's
21 exactly what I have -- That's some of the
22 major points I have in some of the newer
23 reports I have of the hurricane analyses and
24 the work that I am doing, and that's also
25 exactly what we're looking at with the -- that

167
1 new project, ENGOM project, is to go back in
2 time, since that 22 year interval is a fairly
3 long period of time, just like, say, from 19-
4 -- from the mid 1930s to the mid 1950s, you
5 know, you have got a fairly long period of
6 time and you have had a large amount of loss,
7 and how much of that loss was actual occurring
8 at a linear rate versus occurring due to
9 episodic impacts from other events like the
10 construction of the MRGO.
11 Q. Right. You would agree that if you
12 had 100 trees in an area, if they had 100
13 trees in an area and you lost 100 trees in a
14 ten year period, you would say over a ten year
15 period you lost 100 trees, that would be
16 correct.
17 A. That's not land loss. That's
18 habitat change.
19 Q. Habitat change. Okay. Do you have
20 any such trends for habitat change?
21 A. You can do that, but it becomes more
22 complicated. The information is in there and
23 I actually provided that in some of the tables
24 where it's showing changes, changes between
25 habitat types, and I think the Fitzgerald

168
1 report also provides that information. But
2 usually it's fairly confusing. Most people
3 prefer just for land loss trends at least they
4 want to use -- they want something that's
5 fairly simple.
6 Q. Okay. Going back to my hypothet, if
7 you have 100 trees that disappear within a ten
8 year period, --
10 Q. -- if they're all cut down in the
11 first year, there's not going to be any
12 additional tree loss in years 2 through 10.
13 Correct? Because they're already gone.
14 A. If it's a habitat change, or a man
15 -- anthro -- Correct.
16 Q. If during this time period, the ten
17 year period, you lose your 100 trees, you lose
18 all 100 trees in the first year and, because
19 of the change in the habitat, something else
20 grows up in there, say marsh, --
22 Q. -- would that be something that
23 would be a habitat trend that you would track?
24 A. That would be a habi- -- That would
25 be a habitat change, say if it went from a

169
1 cypress forest to a fresh marsh or an
2 intermediate or a brackish marsh.
3 Q. Okay. If you went very quickly from
4 one habitat, such as trees, to a brackish
5 marsh in a very short period of time --
7 Q. -- and because the brackish marsh
8 would have trouble sustaining itself because
9 of the unnatural progression, instead of it
10 being a natural progression from marsh -- from
11 forest to marsh, and that led to degradation
12 of the marsh and then degradation of the land,
13 would that be something that you could track
14 in your land loss trends?
15 MS. MILLER:
16 Objection.
17 THE WITNESS:
18 I -- You need more data points to
19 be able to verify that. Right now we
20 have the 1956 to '78 information. You
21 would have to have intermittent points
22 to track the degradation to be able to
23 say -- to be actually able to separate
24 that, number one, it's changed -- you
25 know, these trees were taken out by a
170
1 logging episode or event, and then,
2 number two, to see how that transition
3 was actually occurring. Plus you
4 would also need field information,
5 collaborating field information from --
7 Q. For the time period between the '58
8 and '78, are there those individual data
9 points, yearly data points?
10 A. No.
11 Q. So how do you go about figuring out
12 --
13 A. You use what is. It's as is. It's
14 the data that's there.
15 Q. The area that we talked about, the
16 Central Wetlands Unit, I will share with you
17 guys I used to duck hunt out there, and every
18 year I'd go out there, there seemed to be less
19 and less marsh. The same places we were
20 standing one year wouldn't be there the next
21 year. Obviously nobody took pictures of it.
22 But if you go back over ten years, you would
23 see there's a lot of it has been lost.
24 Correct?
25 MS. MILLER:
171
1 Objection.
2 THE WITNESS:
3 How would you know it wasn't due
4 to a flood event or something when you
5 happened to be hunting or it wasn't
6 due to vegetation senescence?
8 Q. I am leading up to that question. I
9 am again trying to learn your vernacular. How
10 is it that you would be able to go through, if
11 you're trying to understand the land loss
12 trend rates, what's causing those trends to
13 take place? Can you do that?
14 A. Can I do that? With a reliable --
15 Q. Can it be done?
16 A. I think you should use the
17 information as is with a good -- with a good
18 grain of salt and then rely on other
19 information to try and ascertain what is
20 occurring.
21 Q. What other information would you
22 need to determine what the land loss trend
23 rates were or the factors influencing --
24 A. It's not land loss trends. It's
25 habitat change. You're not -- You're

172
1 referring to habitat change, not land loss.
2 The actual conversion to open water.
3 Q. That's habitat change, not land
4 loss?
5 A. If it's switching from one habitat
6 type to not -- not to open water, but just
7 from cypress forest to a marsh, that's a
8 habitat change.
9 Q. Okay.
10 A. Yeah, okay.
11 Q. I kind of switched gears a little
12 bit on you. I apologize.
13 A. Yeah.
14 Q. Say there's an area within a marsh
15 that is within a marsh area, an impoundment
16 that has marsh that is so many square meters
17 --
18 A. Yeah.
19 Q. -- one year, and ten years later you
20 go back and it's gone. Now you want to go
21 back and try and figure out why it's just open
22 water, what would have caused it. Can you do
23 that? Can you determine what factors are
24 influencing the land loss trend?
25 A. You can probably make a best

173
1 estimate based on the information. It's going
2 to be very confounding and it's -- it's -- you
3 -- you know, I mean the popular theories of
4 land loss, salinity intrusion, submergence,
5 saltwater intrusion, there's a whole host of
6 factors, so it would -- it would be somewhat
7 hard to make -- you know, to assign one
8 particular cause to that loss of land unless
9 you absolutely knew what -- you know, you had
10 something to track that event.
11 Q. The effect of saltwater intrusion on
12 an area, its impact on habitat change, is that
13 something that falls within your area of
14 expertise?
15 A. The only area I would be -- I
16 wouldn't even be comfortable with measuring
17 that. It would probably just be changes in
18 habitat type. So no, it's not really within
19 that --
20 Q. Is part of your expertise
21 understanding why a certain habitat will
22 change to a different habitat, or are you just
23 looking at it and saying it's no longer
24 cypress, now it's marsh?
25 A. Well, no. No, some -- part of right

174
1 now, part -- I would say long-term habitat
2 trend change is not my area of expertise.
3 Where I am trying just to look at the marsh
4 ecology and figure out why that's particularly
5 changing, no.
6 Q. Have you studied or reviewed the
7 Wicker report that involves the study of the
8 St. Bernard marsh, St. Bernard wetlands?
9 A. What year is that? The Wicker?
10 Q. Well, I will show you the book. I
11 am not going to mark this as an exhibit, but
12 have you read this?
13 A. Oh, John's. No, I don't have this.
14 I have many some older -- I have some of the
15 other people's reports on habitat maps.
16 Q. I'll show you, and the book is
17 here. I made copies. One is going to be
18 figure 213. We went over these yesterday.
19 I'll mark these as an exhibit in globo. This
20 will be Exhibit Number 2.
21 VIDEO OPERATOR:
22 Going off the record. I have to
23 change tapes real quick.
24 This is the end of tape 3. We're
25 going off the record.
175
1 (Recess.)
2 MR. JOANEN:
3 I'll mark these 2, 3, 4.
4 VIDEO OPERATOR:
8 Q. Mr. Barras, I have shown you a book
9 that contains a figure which shows comparisons
10 of pre- and post-MRGO Gulf Outlet conditions.
12 Q. And this is a figure, it's figure
13 213 in this book, in which the title indicates
14 it's the average salinity values recorded in
15 May and October of 1960. Have you ever seen
16 this figure before?
18 Q. Have you ever done any studies
19 regarding the salinity values found in this
20 area which is within the polygon of
21 information that you are utilizing?
22 A. No, I don't do salinity
23 interpretations off of discrete locations.
24 Again, the analysis that we're doing is just
25 actually looking at the habitat changes.

176
1 Q. Do you know whether the salinity
2 values indicated in this are such that cypress
3 forest would be sustainable in these areas?
4 A. No, I do not.
5 Q. I'm going to switch you to figures
6 220 and 221.
7 A. Yes.
8 Q. And these are being marked as
9 Exhibit 3 and 4. And these are, as I
10 understand them, salinity tables for the same
11 area --
13 Q. -- after the MRGO was dredged and
14 the LaLoutre Ridge was cut. Have you ever
15 seen these diagrams before?
17 Q. Do you know whether in fact the
18 salinity rates that are indicated on these
19 charts would exceed the sustainability rates,
20 sustainability of cypress forest?
21 A. Those are pretty high salinity
22 rates. They would likely exceed the
23 sustainability of the forest.
24 Q. Do you know or is it within your
25 area of expertise that you would be able to
177
1 evaluate the intermediate changes of the
2 habitat or would you just simply say --
3 A. I would defer that to a marsh and
4 wetland ecologist.
5 Q. And so the expertise you have is
6 simply whether it's land or water?
7 MS. MILLER:
8 Objection.
10 Q. Is that correct?
11 A. No, I think I can actually at least
12 summarize the changes in habitat type for you.
13 Q. Okay. And how would you go about
14 doing that?
15 A. It's fairly basic GIS analysis.
16 Basically somewhat similar to the information
17 that was provided in the Fitzgerald report.
18 Q. Okay. You need to look at this any
19 more?
20 A. No.
21 Q. And again, you had not seen either
22 of those -- you haven't seen either of those,
23 either of the three of those charts before; is
24 that correct you?
25 A. No, I haven't. That's a pretty old

178
1 report.
2 Q. What's that?
3 A. That's a nice -- That's an old
4 report.
5 MS. GILBERT:
7 MR. JOANEN:
8 Yes.
9 VIDEO OPERATOR:
10 Off the record.
12 off the record.)
13 VIDEO OPERATOR:
16 Q. Getting back to your report, the
17 purpose of the document is to summarize
18 historical changes in forested habitats. That
19 would be considered one purpose. Is that
20 correct?
21 A. Correct.
22 Q. And then a second purpose would be
23 to summarize historical changes in land loss
24 trends? Is that --
25 A. Yes.

179
1 Q. So is my understanding correct that
2 you have two purposes in this document and
3 they're set forth in that sentence?
5 Q. Okay. You used the term "forested
6 habitats". What are the forested habitats
7 that you're interested in?
8 A. It's the swamp based on the 1956 and
9 '78 data sets, would be the swamp category
10 and the forested categories. And I also
11 included some shrub/scrub information.
12 Q. In the second sentence you talk
13 about "The report will focus on identifying
14 changes within the MRGO assessment unit" and
15 then you go down to define what the MRGO
16 assessment unit would be by referencing figure
17 A-1. Is your MRGO assessment unit the same as
18 that which Dale Blitsch classifies?
19 A. No, it's larger.
20 Q. And how is yours different than his?
21 A. It is -- Again, if you -- Let's say
22 if you look at figure zero -- It's on page
23 027, it basically includes the central
24 Pontchartrain basin out to the Chandeleurs and
25 the Breton Sound basin east of the Mississippi

180
1 River. And if you look, you can see the
2 yellow dotted line is the area used by Dale
3 Blitsch.
4 Q. Why is it that you would use a term
5 "MRGO assessment area" to include an area
6 greater than that assessment area which Dale
7 Blitsch was using?
8 A. It was my terminology.
9 Q. You said in your second paragraph
10 that "The habitat land loss impacts resulting
11 from construction and maintenance of the MRGO
12 do not extend to the entire assessment area."
13 And that would be the entire Pontchartrain
14 basin that you just identified in that?
15 A. Right. Right.
16 Q. You say that "The direct impacts
17 from the MRGO are dredging and spoil
18 placement." Is that within only your -- that
19 red dotted -- yellow dotted line?
20 A. No, it's within the green -- what --
21 what was used just to provide an idea of the
22 direct impact since I only -- I have the '56
23 and '78 data, was the spoil area and the
24 channel was digitized from the '78 data just
25 to provide an idea of the change between 1956

181
1 and '78 of the direct impacts --
2 Q. Okay.
3 A. -- within the spoil placement area
4 on the channel area.
5 Q. Were there any other direct impacts
6 from the MRGO other than dredging and spoil
7 placement to that area?
8 A. I am going to keep my responses tied
9 to the -- basically to the information I have
10 here with the data that I am using.
11 Q. When you use the term "direct
12 impacts", are those -- are there any direct
13 impacts that are -- are these direct impacts
14 that you're referencing man-made impacts?
15 A. They would be man-made impacts from
16 the dredging of the channel or -- or placement
17 within the spoil area for -- the spoil
18 retaining area for the channel.
19 Q. If the theory would be that the
20 dredging of the MRGO through the LaLoutre
21 Ridge allowed for saltwater intrusion into an
22 area where it ordinarily wasn't to such a high
23 degree of salinity and then that resulted in
24 some habitat changes, you're not considering
25 that to be a direct impact of the dredging of
182
1 the MRGO?
2 A. Not for the purposes of my report.
3 Q. Would it be within your area of
4 expertise to opine whether that would be a
5 direct impact?
6 A. I'll refrain from opining on that.
7 Q. But that's not within -- is that not
8 within your area of expertise?
9 A. I will -- I can comment only on the
10 direct impacts on the 1978 habitat data set.
11 Q. Just the 1978 habitat data set?
13 MS. MILLER:
14 Objection.
16 Q. Is that what you said?
17 A. Well, no, where I define it. But, I
18 mean, I can -- within the data sets that I am
19 using, that I have used for the report.
20 Q. You then indicate here you have a
21 "reasonably conservative estimate of the area
22 in which habitats may have been impacted
23 indirectly by the MRGO as shown by the area
24 marked as USACE model 1." And that is the
25 yellow dotted area; correct?
183
1 A. Correct.
2 Q. And you indicate on there direct
3 impacts in your footnote are those that may
4 result from changes in land forms and
5 hydrology associated with construction of the
6 channel. A change in hydrology could
7 potentially be the dredging of the MRGO
8 through --
9 A. Yes.
10 Q. -- the LaLoutre Ridge?
11 A. Yes, a physical change.
12 Q. So when I asked you whether saline
13 intrusion would be a direct impact, actually,
14 according to your definition, it would be an
15 indirect impact of the dredging; correct?
16 A. Yes.
17 Q. Okay. That's all I was trying to
18 clarify.
19 Are you able to opine as to what
20 effect these indirect impacts had on the
21 habitat in the USACE model area?
22 A. I can provide the -- I can -- I
23 would prefer to stand by the actual data and
24 with the actual trends being able to show what
25 the trends are on -- the land area change

184
1 trends are within that area.
2 Q. And that's information that's
3 obtained by persons other than yourself;
4 correct?
5 A. No, the land area shown information
6 is generated from the data sets provided on
7 the statistics and what 119 -- 119 through --
8 the trend analyses all the way through 122 and
9 others.
10 Q. I just don't understand your answer
11 then. You don't want to opine on it or you
12 want to rely upon the land --
13 A. I feel comfortable providing the
14 land loss trends and I can -- I feel
15 comfortable saying that the -- you know,
16 showing the changes and the decrease in the
17 forested area, you know, and some of those
18 changes, but I don't feel comfortable opining
19 on hydrologic gradient changes.
20 Q. And are you going to opine as to the
21 cause for the habitat change?
22 A. I can opine as to the cause for the
23 habitat, speculate -- or I have opined
24 somewhat for the cause for the habitat change.
25 Q. When you were looking at the
185
1 original data sets, were you looking at those
2 in an electronic format or were you looking at
3 the original plots and detail?
4 A. It's the electronic format. In
5 combination with some of the photography.
6 Q. In the last sentence of that first
7 page you say "Model areas were selected by
8 experts for the United States."
9 A. Yeah.
10 Q. Which experts do you believe are the
11 ones that are involved in selecting --
12 A. Dale Blitsch and the modelers.
13 Q. Were you involved with them in any
14 way in determining what the USACE model area
15 would be?
16 A. No. No, I wasn't.
17 Q. Would you be able to testify as to
18 the tidal exchange --
19 A. No, I wouldn't.
20 Q. -- between the Breton Sound area and
21 Lake Borgne?
22 A. No, I wouldn't.
23 Q. Would you be able to opine as to the
24 altered tidal exchange between Breton Sound
25 and the MRGO and the bayous along the MRGO
186
1 such as Bayou St. Marlo?
2 A. No, that's the hydrologist's realm.
3 Q. Other than being an expert in GIS
4 and map mapping, would there be anything else
5 that you would be expressing an opinion on as
6 an expert in this litigation?
7 MS. MILLER:
8 Objection.
9 THE WITNESS:
10 Again, probably the land loss
11 trends.
13 Q. Moving to page 2 of your opinions,
14 just kind of start with those, your first
15 opinion, when you indicated there is logical
16 physiographic units consisting of uplands,
17 fast lands, ridges, and wetlands, why do you
18 believe that that is -- those are logical
19 physiologic units?
20 A. The upland areas are actually on the
21 pleistocene upland and within the Coast 2050
22 mapping units. Those areas were included
23 within units so you would be including large
24 areas of pleistocene uplands, forests of
25 pleistocene uplands within the analysis area

187
1 which could skew the interpretation of forest
2 types. The fast land areas were obviously
3 separated to identify areas that were within
4 probable levees at the time period. The
5 ridges were separated to indicate -- or to
6 better isolate forested wetlands and fresh
7 marsh along those ridges to give a better -- a
8 more -- a cleaner composition of the 1956
9 landscape.
10 Q. Okay.
11 A. While isolating the forest types,
12 and obviously the wetland information was a
13 separate unit that does not consist to be with
14 the forested wetland component.
15 Q. Okay. Are there any uplands
16 contained within the USACE model area?
17 A. The uplands, no, there would be --
18 not to my knowledge they're uplands.
19 Q. And we have already established
20 there are no fast lands within the model area?
21 A. I would have to go back and check.
22 But just my cursory glance, it doesn't look
23 like it.
24 Q. Okay. Ridges, we know there is
25 because that's the LaLoutre Ridge; correct?
188
1 A. Yes, the LaLoutre, Delacroix, the
2 Bayou Terrebonne ridges.
3 Q. And the remaining would be wetlands;
4 correct?
5 A. Primarily. Yes. Or open bays.
6 Q. How would you define "wetlands" in
7 your realm of expertise?
8 A. It would be an emergent vegetative
9 wetland. Emergent vegetation above the tidal
10 range.
11 Q. And you indicate here that the
12 dividing of your assessment area, the way I
13 read it is, is that it's a superior way of
14 going about it than with the Coast 2050
15 mapping units.
16 A. It's more logical to separate
17 forest. Otherwise, the Coast 2050 units,
18 you're going to be mixing -- You're going to
19 be including forest areas in areas -- It's
20 actually more confusing to separate the trends
21 on the Coast 2050 units for identifying
22 forested areas and fast lands.
23 Q. How is it that you came about to be
24 knowledgeable of the Coast 2050 efforts?
25 A. I digitized them.

189
1 Q. Have you expressed this opinion,
2 that your way of doing it is more logical than
3 the 2050?
4 A. No, this was done particularly for
5 this particular analysis. The 2050 units were
6 developed specifically for assessing coastal
7 trends ten years, eight -- No, that was back
8 in 1995.
9 Q. Okay. So the first time that you're
10 doing -- I know you said the first time you
11 have done this analysis was for the Lake
12 Pontchartrain --
14 Q. -- basin for this litigation. And
15 you now are using --
16 MS. MILLER:
17 Objection. I'm not sure that's
18 what he's testified to.
19 THE WITNESS:
20 Wait. Okay. Let me -- When you
21 say analysis, it's the first time I
22 have done a change analysis?
24 Q. For the Lake Pontchartrain basin.
25 A. No, the Lake Pontchartrain basin has

190
1 been analyzed -- that was done using
2 standardized hydrologically -- It's back --
3 The first time I did that was back in the
4 early '90s.
5 Q. Okay. That's what I was trying to
6 establish with you. When you came back and
7 starting redoing it --
9 Q. -- again for this litigation, you
10 weren't reinventing the wheel.
11 A. No.
12 Q. If you had done it before, that's
13 what I was trying to determine, what you had
14 done before.
15 A. No, no it's not reinventing --
16 Q. If I misunderstood, I apologize.
17 A. It's not reinventing the wheel.
18 What was done in 2003, they had a better
19 method of separating the wetland areas from
20 fast land areas. So it's been -- it's
21 modified over time. It's incorporating
22 information that's been standardized for many
23 large planning assessments of Louisiana over
24 the last ten or fifteen years where this data
25 has been used.

191
1 Q. Okay. The procedure that you used
2 to -- the logical physiographic units, have
3 you used that type of procedure for analysis
4 before?
5 A. Yes.
6 Q. For the Pontchartrain Basin
7 Foundation? I'm sorry, for the Lake
8 Pontchartrain basin.
9 A. Not for the Lake Pontchartrain --
10 Q. Yes.
11 A. You confused me with the
12 Pontchartrain Basin Foundation versus -- I
13 know Joe Lopez and all of those guys.
14 Q. Well, I am thinking of Carlton
15 Dufrechou and those people. I apologize.
16 A. Yeah, I know Carlton and all of
17 those guys, too. Yeah. No, I mean, repeat it
18 again. I don't want --
19 Q. This procedure you used where you're
20 dividing the MRGO assessment area into logical
21 physiographic units, is this the first time
22 that you're using this procedure for
23 evaluating the Lake Pontchartrain basin?
24 A. Do you mean physical units that I
25 actually designated myself or --

192
1 Q. Yes, this procedure that you're
2 saying is superior to the Coast 2050.
3 A. It's the first time I used it for
4 the Lake Pontchartrain Foundation. I have
5 used it in other areas -- the Lake
6 Pontchartrain area.
7 Q. Right.
8 A. I have used it for other areas in
9 the past.
10 Q. Okay. But I guess that was the
11 question I was trying to build to.
12 A. Sorry.
13 Q. For this litigation is the first
14 time you're actually using the procedure that
15 you --
16 A. Right.
17 Q. -- specified as being superior to
18 the Coast 2050 for the --
19 A. I said logical. More logical. Not
20 superior.
21 Q. More logical for the Lake
22 Pontchartrain basin; correct?
23 A. Uh-huh (affirmatively). Uh-huh
24 (affirmatively). Yes.
25 Q. Okay. That was a hard one. We'll
193
1 get better than that. That's my fault. I
2 apologize.
3 In number 2 you say "The total
4 swamp habitat". What is the total swamp
5 habitat?
6 A. It's the swamp classification, swamp
7 habitat classification in '56 and '78 -- and
8 1978. This is the decrease within the entire
9 area shown on that earlier figure.
10 Q. And your 1,051,217 acres MRGO
11 assessment area, that's the entire study area?
12 A. That's the figure that we showed
13 earlier.
14 Q. Can you, looking at that, figure out
15 what percentage of the 1,051,217 is the USACE
16 model area?
17 A. Yes, but I'd probably have to go
18 back and look at the statistics in the
19 spreadsheets. I can't sit here and run it off
20 the top of my head.
21 Q. Just to make things a little easier,
22 would it be 10 percent, 20 percent, 30
23 percent?
24 A. I'm not going on speculate unless I
25 can go back in the spreadsheets and look at

194
1 it.
2 Q. Why don't you go ahead and do that
3 then.
4 A. Okay.
5 MS. GILBERT:
6 For the record, when you isolate
7 a spreadsheet you're relying on, just
8 identify it for the record.
9 THE WITNESS:
10 Okay. Sorry, I've got to find
11 the right spreadsheet. I've got a
12 bunch of them.
13 Okay. It's 20 percent.
14 Rounding.
15 MS. GILBERT:
16 Based on which?
17 THE WITNESS:
18 It's based on the total acreage
19 given in number 2, divided by the 200
20 -- 212,608.6 acres that I have for
21 that MRGO -- the yellow unit.
22 MS. GILBERT:
23 Which spreadsheet are you
24 referring to in your --
25 THE WITNESS:

195
1 Oh, in here? It would be --
2 Should have told you when I had it.
3 It's -- It's USACE MRGO land water
4 trends. It's about 20 percent, looks
5 like.
7 Q. In that number 2, when you talk
8 about total swamp habitat, are you including
9 marsh in that definition?
10 A. It's just swamp, identified on the
11 '56 and '78 habitat data.
12 Q. And can you, as you sit here today,
13 assess what type of trees were in that fresh
14 water swamp?
15 A. As I defined earlier, I think it's
16 in the -- a little further in the report, the
17 methodology, it defines the '56 and '78 data
18 identified cypress swamp and possibly willow
19 and maple swamp and -- swamps.
20 Q. So the terminology you're using here
21 is simply that which was included in the
22 reports --
23 A. Yes.
24 Q. -- of '56 and '78? And are you're
25 not making any changes to that?
196
1 A. No, it's the exact same information
2 that's included in those tables.
3 Q. And the reason, of course, you
4 exclude the Chandeleur and Lake Borgne
5 assessment units is because that's water;
6 right?
7 A. Well, it's primarily water. I mean,
8 the Chandeleurs got hit pretty hard by the
9 hurricanes, so there's not much land there.
10 Q. In the ridges that you've talked
11 about in your first opinion, do you know how
12 those ridges come about?
13 A. It forms as part of the natural
14 process of delta prodegration and abandonment
15 where you have a ridge that's been on -- the
16 heavier sediments are deposited and forms a
17 natural levee system and graduates, and you
18 have an active delta cycle. This part of the
19 delta is actually in a degradation and
20 transgressive cycle.
21 Q. Do you know whether in the '56 data
22 set that you have that the ridges that you're
23 looking at had cypress in them, or the ridges
24 that are within the USACE study area, did the
25 ridges have cypress in them?
197
1 A. Well, the ridges contained within
2 the USACE study area, the segments contained
3 in there would have had cypress on them,
4 cypress forest on them.
5 Q. Okay.
6 A. That's -- Obviously you can see that
7 on the aerial photography.
8 Q. Number 3 is "Total direct swamp
9 habitat conversion from '56 to '78 within the
10 MRGO channel and spoil disposal area based on
11 the '78 spoil and disposal was 1,398 acres.
12 A. Yeah, that was direct --
13 Q. Where did you get that information?
14 A. From -- Let's go back to our
15 figures. If you go back to figure 027, if you
16 look at the green area on the map legend, it
17 has "MRGO 1978 spoil disposal area". That's
18 the area outlined in green. And then the MRGO
19 1978 canal is that kind of light blue channel
20 and that's where the calculations came from.
21 Q. And again, using the term "direct"
22 is important because we were talking about
23 before --
24 A. It's within the boundaries.
25 Q. And that's the man-made changes to
198
1 the environment based upon them digging up the
2 MRGO and throwing the soil/spoil next to it;
3 correct?
4 A. Based on the 1978 interpretation of
5 those areas.
6 Q. Right. Number 4, the 30,181 acres
7 of episodic land loss caused by Hurricane
8 Katrina within the MRGO assessment unit in
9 2005. Again, the MRGO assessment unit is the
10 whole Lake Pontchartrain basin we talked
11 about; right?
12 A. Yes, defined in that figure, figure
13 027.
14 Q. It is equivalent to the 2,951 acres
15 of net loss that occurred between '78 and
16 2004, a 26 year period. That net loss, is
17 that net loss within the entire MRGO
18 assessment area as you define it?
19 A. Correct.
20 Q. And by episodic net land loss, that
21 is due only to the event of Hurricane Katrina?
22 A. Land loss caused -- Well, Rita. You
23 keep forgetting Rita did a little there. You
24 keep forgetting Rita.
25 Q. So that's what I am asking you.
199
1 Does this statement include Rita, the 30,181
2 acres?
3 A. Yes. That probably -- I should have
4 had Rita on there, too. That was probably --
5 Q. So that includes Rita. And
6 including Rita, is that also within your MRGO
7 assessment area? Is that also the whole
8 coastal Louisiana?
9 A. Yes.
10 Q. Just within your assessment area?
11 A. The numbers would have been gen- --
12 the land-water numbers would have come after
13 both Katrina and Rita, so it's very hard to
14 separate. Even if Rita had very minor impact,
15 it's very hard to separate it out, so to be
16 cautious you need to say it included both.
17 Q. And I think I have already covered
18 this, but just to make sure, you wouldn't be
19 of the expertise to opine whether the
20 unhealthy nature of the wetland would have
21 eroded faster than had it been healthy, if in
22 fact it was unhealthy?
23 MS. MILLER:
24 Objection. Vague question.
25 THE WITNESS:
200
1 We do not have enough information
2 to make those determinations yet. We
3 have observations, but not enough
4 information to actually definitively
5 say that that is occurring.
7 Q. When you say "we", I am talking
8 about you, though. Would you have?
9 A. No, I do not have.
10 Q. That's not your area of expertise;
11 correct?
12 A. No, it is getting into my area of
13 expertise now, but I don't -- based on the
14 newer work I am doing, but I do not have
15 enough historical information in place to
16 publish to definitively make a statement of
17 that kind.
18 Q. When was it you would have first
19 started to understand the health of the marsh
20 or the -- the health of the habitat within the
21 USACE model area?
22 A. The health within the habitat? I
23 was -- Actually, I have been examining
24 episodic events coastwide and looking at
25 fairly healthy contiguous marsh versus marsh

201
1 that has undergone land loss over the --
2 during the historic period, and that's part of
3 the new study that we're doing, is examining
4 some of that information based on some of the
5 findings from the 2004 to 2006 changes -- '05
6 and 2006 changes from the hurricane strikes.
7 Q. Okay. How about from non-hurricane
8 strikes? How about saltwater intrusion for
9 the MRGO?
10 A. Not going to comment. The saltwater
11 intrusion, you can make speculation, but
12 that's not my -- again, that's not my area of
13 expertise. I can look at broad habitat
14 changes and say that it has changed from
15 brackish to intermediate or something, but I
16 would want to go back and look at all the
17 salinity information for that.
18 Q. Would you agree that subsidence in
19 the area of the USACE model area is about .06
20 inches per year?
21 A. I would have to go back and look at
22 the literature on that. It would probably be
23 derived from work that Mark Culp is doing and
24 some of the other scientists.
25 Q. Would that be the type of thing that
202
1 you would be able to base your expert opinion
2 upon?
3 A. I would probably look at long term
4 land loss patterns along -- Actually, some of
5 the work I did for Bob Morton was looking at
6 rapid episodic -- well, not episodic, but very
7 rapid subsidence over short time periods,
8 uplands to where it's subsided up to half a
9 meter within four to five years.
10 Q. Would it be your understanding that
11 the rate of subsidence would be affected by
12 the amount of -- or the holocene layer as
13 opposed to the pleistocene layer?
14 A. There's theories that is that one
15 particular mechanism. There's other compet-
16 -- there's several different competing
17 theories.
18 Q. Do you believe that the holocene
19 layer would compress at a faster rate than the
20 pleistocene layer?
21 A. Based on some of the studies, yes.
22 Q. Do you understand what the
23 difference is between the holocene layer is
24 south of -- on the south shore of Lake Borgne
25 as opposed to further inland where the Central
203
1 Wetlands Unit would be?
2 MS. MILLER:
3 Objection.
4 THE WITNESS:
5 I would defer to geologists on
6 that.
8 Q. Again, number 5, your MRGO
9 assessment area comprises 21.5 percent of the
10 coastal area and 39.4 percent of the deltaic
11 plain. That's the whole Lake Pontchartrain
12 basin?
13 A. Correct. The large area.
14 Q. Your number 6, you indicate that
15 MRGO has caused some direct and indirect land
16 loss.
18 Q. But other causes, including
19 historical hurricane impacts occurring during
20 the '60s may have caused significant loss
21 within the MRGO assessment area. What
22 hurricanes are you referring to?
23 A. Betsy primarily.
24 Q. Other than historical hurricane
25 impacts, what other causes of loss would you
204
1 believe had caused significant loss within the
2 MRGO assessment area?
3 A. The direct dredging of the MRGO.
4 That would be one of the causes. You would
5 also have just normal shoreline erosion and
6 interior marsh submergence, just long-term
7 submergence over the past 25 or 30 years. The
8 area has actually been, as far as the delta
9 plain goes, from looking at land loss from the
10 entire delta plain versus my area, this area
11 has been relatively stable except for the
12 hurricane impacts from -- from the '70s to the
13 present. Well, 2004. Prior to the
14 hurricanes.
15 Q. When you say it's been relatively
16 stable, would that include the USACE model
17 area? Talking about the relatively stable
18 regarding subsidence rates?
19 A. Not subsidence rates. Land loss
20 measurements. Land loss would incorporate
21 subsidence as one of the factors.
22 Q. Dale Britsch testified yesterday
23 that he believes that subsidence in the USACE
24 model area would be approximately a tenth of a
25 foot over 20 years. Would you have any reason
205
1 to disagree with him?
2 A. I would defer to Dale. He's got a
3 lot of cores out there.
4 Q. When you talk about here the
5 indirect loss that the MRGO would have caused,
6 that would be your saltwater intrusion;
7 right?
8 A. Not necess- -- Again, I am not an
9 expert on saltwater intrusion. You know, with
10 habitat change, but it would be again sea
11 level rise. I don't really like commenting on
12 the salinity changes.
13 Q. Well, when I was asking you on page
14 1 about the indirect impacts and changes in
15 hydrology, that was one of the things I asked
16 you about.
17 A. Saltwater intrusion is indirect.
18 You could also have surge from hurricanes or
19 other impacts that could -- that could cause
20 rapid loss. It may not be picked up within an
21 area.
22 Q. Right. And that was my question to
23 you. When you talk about indirect, you're
24 talking about saltwater intrusion; right?
25 What other types -- What else would lead to
206
1 indirect land loss?
2 A. Indirect land loss? Well, long-term
3 subsidence, storm passages and erosion on
4 multiple storm frontal passages and erosion.
5 Nutria eat-outs, vegetative -- you know,
6 muskrat and nutria and stuff eating the marsh.
7 Q. Okay. Have you reviewed the 1949
8 Oneal Louisiana wetland vegetation?
9 A. We digitized the map for the CWPPRA
10 Planning Task Force. And I provided that
11 information to Shea Penland.
12 Q. In your methodology -- Just
13 referring to some of your methodology stuff,
14 why did you see the need to separate out
15 natural ridges when we're dealing with
16 wetlands?
17 A. Because the natural ridges have your
18 remnant cypress forest along the ridge as a
19 natural ridge. There is a little higher
20 elevation marshes and stuff, so you're still
21 going to have that ridge there and the habitat
22 there. So the whole idea was to accurately,
23 instead of including all of the forest within
24 a large wetland unit like the Biloxi wetlands
25 is tens of thousands of acres, and so at least

207
1 you could get a better idea of what's
2 occurring along that ridge.
3 Q. Were you able to evaluate the
4 heights of those ridges as they were in 1956?
5 A. No. We don't have the information
6 for that unless you --
7 Q. The question I believe was were you
8 able to evaluate the heights of those ridges
9 as they were in 1956, and you said "No, we
10 don't have the information for that unless you
11 --"
12 A. I'm sorry, I mean I don't -- I don't
13 have that.
14 Q. Okay. Who would have that?
15 VIDEO OPERATOR:
16 Excuse me. You've got your hand
17 --
19 Q. Who would have that?
20 A. I would imagine you would have to go
21 back and go through the literature to find the
22 information or through -- to the Corps,
23 whoever would have highway surveys along that
24 in the 1950s. You would have to go to various
25 sources.

208
1 Q. Okay. So when you say "We don't
2 have that information unless you", what did
3 you mean by that?
4 A. I meant that I didn't personally
5 have it. That wasn't the purpose of my
6 report, to evaluate elevation heights of
7 habitat data.
8 Q. If I were to tell you that the
9 LaLoutre Ridge in 1956 was 8 feet, would you
10 have any reason to disagree with that?
11 A. I would prefer to read your source
12 information rather than just hearing it from
13 you.
14 Q. Do you have any independent
15 knowledge that it would be -- that that would
16 be incorrect?
17 A. I'm not going to comment unless I
18 get the information for it, historical
19 information for it to make a determination.
20 Q. So if I were to ask you to evaluate
21 what the height of the LaLoutre Ridge in 1956
22 was, what sources would you look to?
23 A. Well, first of all, that's not
24 normally what I would do, but you would start
25 looking for highway surveys trying to find --

209
1 because that's most likely where you would
2 have benchmarks along that area, find out if
3 the Corps of Engineers has anything from any
4 navigation projects and stuff where they have
5 a fix there. You would have some kind of
6 fixed benchmarks in the area to look at and
7 evaluate changes over time.
8 Q. So when you were preparing your MRGO
9 assessment unit, you were not evaluating
10 topography; correct?
11 A. No, it was based basically on the
12 habitat types.
13 Q. In the areas where you indicate
14 there's ridges in your MRGO assessment, in the
15 area where you indicate that there's ridges in
16 the MRGO model area, did you find that there
17 was any marsh on those ridges?
18 A. Again, if you look at the
19 methodology, I actually included within the
20 ridge designation out to the fresh marsh just
21 to be safe on the estimation of forested area
22 and fresh marsh along those ridges, plus it
23 included a 100 meter buffer just to be -- just
24 to include the maximum potential area for --
25 for potential forested area.

210
1 Q. When you include that 100 meter
2 buffer, are you adding marsh to water or are
3 adding water to marsh?
4 MS. MILLER:
5 Objection.
6 THE WITNESS:
7 It's not adding anything. It's
8 increasing the comparison area. All
9 you're going to do is you'll end up
10 getting a little bit -- whatever that
11 runs over, it'll calculate --
12 calculate the habitat statistics under
13 it.
15 Q. And your ridge boundaries, those are
16 based on your '56 map?
17 A. Yes.
18 Q. Do you believe that there is any
19 ridges that are excluded resulting from your
20 land loss data studies?
21 A. There may be -- No, I think I
22 include most of the major ridges.
23 Q. In putting together your expert
24 report, are you supplying any elevations --
25 A. No.

211
1 Q. -- in these things?
2 A. No.
3 Q. Are you able to, in looking at your
4 maps in the vegetation area, are you able to
5 assess the density of forest in certain areas?
6 A. No, the purpose of the report wasn't
7 to actually to assess. I was just using the
8 existing habitat data so it would be typical
9 of the information provided to the Corps of
10 Engineers for a basic analysis.
11 Q. Are you able to assess the
12 frictional capabilities of this vegetation
13 regarding either water passing over it or wind
14 passing over those vegetations?
15 A. Didn't we do this earlier? No.
16 Q. I'm going by my notes.
17 A. I'm sorry. Okay.
18 Q. I think we did, and you said no.
19 A. I was just trying to remember.
20 Wasn't that way back this morning?
21 Q. On page 4 of your report, you talk
22 about the Lake Borgne, the last paragraph, the
23 Lake Borgne assessment unit.
25 Q. The Chandeleur assessment unit.
212
1 Does your wetlands evaluation include the St.
2 Bernard marsh unit? Or is there a St. Bernard
3 marsh unit? I guess that would be the first
4 question to ask you.
5 A. Hold on. Let's see. I think if you
6 look at the opposite page, it has all of the
7 units that I had. So there's a St. Bernard
8 ridge fast land. It would have included all
9 of the marsh. Well, first of all, I have to
10 know what you're defining as the St. Bernard
11 wetlands so I can tell you.
12 Q. Right.
13 A. But the marsh area surrounding that
14 would have been included in the Delacroix east
15 and Delacroix west wetlands.
16 Q. Okay. Your MRGO assessment unit, on
17 page -- referring now to page 5, --
18 A. Okay.
19 Q. -- when you talk about the
20 physiographic units right under table 2, the
21 MRGO AUs were digitized on screen using the
22 '56 habitat data set?
24 Q. There's no topography in this,
25 correct, and doesn't give elevations of that?
213
1 A. No, it's just basically
2 interpretations looking at the habitat types
3 and inferring if that's, you know, the levee
4 structure and wetland information from that.
5 Q. How do you go about getting that
6 digitized, the '56 habitat data set digitized
7 on screen?
8 A. It's basically what's called a
9 heads-up procedure. You can sit there, you
10 pop the information up, you enter into the
11 software and you can start actually digitizing
12 lines. It's a standard GIS terminology.
13 Q. Are there any quality control
14 procedures involved with that digitizing?
15 A. Well, it's based on my expertise of
16 doing this for fifteen years or so, or twenty
17 years now.
18 Q. In providing your report, did you
19 have any input from any of the modelers that
20 are listed as experts in this litigation?
21 A. For my boundaries?
22 Q. Yes.
23 A. No. I actually wanted to be
24 completely independent of anybody's input so I
25 could give a fair comparison.

214
1 Q. Do you know whether swamp willow and
2 black willow grows in areas other than on
3 spoil and new land?
4 A. No, the willow will grow -- you
5 would probably have that included in some of
6 the areas leveed, that were actually
7 partitioned and leveed. Not within the fast
8 land areas, but you can see areas where they
9 had impoundments. New Orleans East was
10 covered with that kind of stuff before it was
11 actually completely drained and converted. So
12 you'll have a transition. You know, the
13 cypress forest were logged at the turn of the
14 century or whatever and then you would end up
15 having something else maybe coming back
16 depending on how they drained the land. You
17 actually have a lot of failed reclamation
18 projects where the levees gave and the people
19 let it go and it might convert depending on
20 the type of water, the salinity of the water.
21 Q. In evaluating or in preparing your
22 report and listing the habitats, did you rely
23 upon on any aerial photographs?
24 A. I spot checked aerial photographs
25 from the '50s just to -- just to see if the

215
1 habitat interpretations made sense, but again
2 I would defer to the habitat interpretations
3 since it's kind of an as-is data so it's been
4 there, been used for 20-something years.
5 Q. So you didn't change the data sets
6 based upon the photographs that you saw, did
7 you?
8 A. No. That's not a good idea if
9 you're trying to give an unbiased comparison.
10 Q. And what were the spot checks? Do
11 you know where those were? Were any of those
12 within the MRGO -- USACE model area?
13 A. Yes, I did look at some of the --
14 oh, Dale Blitsch's information that he had.
15 Q. Did you review any of the
16 photographs that were included in the Day and
17 Schafer reports?
18 A. Yes, I did. They actually had some
19 very nice ones.
20 Q. Did you find that the area had
21 cypress trees and forests and rosocanes
22 throughout the area?
23 MS. MILLER:
24 Objection. I'm not sure what
25 area you're referencing.
216
2 Q. The areas that you were spot
3 checking in the USACE model area.
4 A. They were -- There was cypress
5 forest and bottom land hardwoods on the
6 ridges. Rosocanes, yeah, they had some high
7 stuff that may have had rosocane, but I
8 wouldn't have -- you know, it just depends on
9 where the photo was taken. You've got to be
10 very careful from interpreting the habitat
11 classification for a large area from spot
12 photos.
13 Q. In the bottom land hardwood, what
14 kind of trees would be in that?
15 A. Oaks, you would have sweet gum.
16 Hackberry.
17 Q. And did you find that there were oak
18 trees on some of the higher ridges in that
19 MRGO model area such as along Bayou Bienvenue?
20 A. No, it's kind of hard to tell from
21 the photography that I had. I wouldn't sit
22 there -- You could see a lone oak or something
23 that's out in a pasture, but as soon as you
24 got in a forest it was hard to tell what was
25 what. I wasn't specifically going through it

217
1 to classify the information.
2 Q. And those photographs were 1950s
3 photographs?
4 A. Yes, they would have been -- they
5 were a series of -- It was the information
6 that was in Dale's report. It was also the --
7 the National Historical Archives. I guess
8 that would have also been the Agricultural
9 Commodity Service photography.
10 Q. And when you say the '50s, do you
11 know whether it's the early '50s or late '50s?
12 A. This would have been the earlier
13 '50s.
14 Q. Were these photographs that were
15 taken while the MRGO was being dredged?
16 A. Oh, no, this is prior --
17 Q. Prior to?
18 A. -- to construction. Yeah, I wanted
19 something that was -- because the habitat data
20 was prior, I wanted something to see what it
21 looked like immediately prior or as close to
22 prior as I could get.
23 Q. How would you define the difference
24 between your classifications of shrub/scrub
25 and then cypress forest?
218
1 A. Cypress forest, actually a cypress
2 forest is about 20 feet in height, you know,
3 fairly dense spacing of -- not dense, but at
4 least you would consider it a forest if you
5 looked at it. It looks like enough trees
6 together to call it a forest.
7 A shrub/scrub is usually going to
8 be low growth, it's bushy wax myrtle. I was
9 giving an example. It's Cajun terms, Celia
10 bushes, but whatever. It's good duck blind
11 material.
12 Q. The cypress forest that would have
13 been found in the MRGO model area, would you
14 say that was first growth forest or was that a
15 second growth?
16 A. That's definitely second growth.
17 You can see the logging scars from the old --
18 from the turn of the century or prior to
19 that.
20 Q. And you said that cypress forest is
21 20 feet in height. Is second growth forest
22 that is out there, that's as tall as -- that's
23 your feeling --
24 A. No, let me explain it. I think the
25 NWI classification for a tree or forest is

219
1 above 20 feet. Below that you get the
2 shrub/scrub. So that's what I am just saying,
3 is the -- the interpretation of the habitat
4 data there at least saying that those trees
5 are cypress or swamp above -- you know, it's a
6 forest. It's not shrubbery growth. I can
7 bring you the NWI classification manual if you
8 want to wade through it.
9 MS. GILBERT:
10 You want to take a quick break?
11 VIDEO OPERATOR:
12 I have about five minutes left on
13 tape.
14 THE WITNESS:
15 Let's do it when you have to
16 change tape.
18 Q. What's that?
19 A. He's got to change the tape in five
20 minutes.
21 Q. Okay. We'll just kind of push
22 forward a little bit.
23 A. Which page are you going to?
24 Q. I'm on page 7 now.
25 A. Okay.

220
1 Q. A lot of things I have here that I
2 had questions on we have covered, and so
3 that's one of the reasons I'm a little slow,
4 trying not to repeat things.
5 A. Thank you. Thank you.
6 Q. I was a little confused on page 7 of
7 your statement, after your part where it says
8 "attachment 2". You are talking about the --
9 because this is dealing with the '88
10 aggregated habitat coding scheme. It says
11 "One of the results is that the '56, '78
12 swamp and forest classes are not directly
13 comparable with the '88 habitat categories."
14 And then the next sentence, you talk a little
15 -- the next two sentences you are talking
16 more. What are you talking about there? What
17 do you mean by that?
18 A. Let's see if I can show it to you
19 right here. Okay. If you go to figure 029,
20 this is the 1978 coding scheme which is
21 consistent with the '56 data. So swamp in '56
22 would be the same as swamp in '78.
23 Oh, you don't have it. Okay.
24 Now, I am going to flip to the next page.
25 Unfortunately, this is -- Let's do this.

221
1 MS. MILLER:
2 Also for your reference, I
3 believe the reports were produced
4 without Bates numbers first.
5 MS. GILBERT:
6 That's correct.
7 MS. MILLER:
8 And then produced later with
9 them.
10 MS. GILBERT:
11 We never got the ones with them.
12 THE WITNESS:
13 You need the ones with the page
14 numbers?
15 MS. GILBERT:
16 We have to look at that.
17 MR. JOANEN:
18 I am not going the make any more
19 comments about Kara's people playing
20 hide the ball with this.
21 MS. GILBERT:
22 Give us the title. We can go
23 with that.
24 THE WITNESS:
25 Okay. If you look at this, now

222
1 the orange is what I was using as the
2 color for swamp classification. If
3 you look at the Pearl River area,
4 there's a lot of what would be -- you
5 would have willow and some other
6 categories that aren't cypress forest,
7 but it's still considered kind of a
8 swamp area. Well, because of the way
9 this '88 data was aggregated, we -- I
10 participated in it, but it was a group
11 aggregation scheme and we were
12 overridden on some of the
13 recommendations. So the swamp
14 category was changed to just purely
15 cypress forest. That's why this
16 changed to the green. That would be
17 your bottom land hardwoods. So you've
18 got a fairly large switch there and
19 from -- you are still getting a lot of
20 cypress forest here in the upper basin
21 areas, but some of these areas that
22 had more mixed vegetation, it would
23 flip back to a forest category. So I
24 can't -- unless I go back to the
25 original deca date, recode, you know,

223
1 try to build these up again, it's a
2 lot of work to go back and figure out
3 exactly what was switching to what.
4 And, secondly, the Corps of Engineers
5 is going to get this, or anybody that
6 asks is going to get the same stuff so
7 they got to deal with this. So I felt
8 that I had to cover that issue just to
9 say that there was confusion.
11 Q. The issue with the differences in
12 classification, did any of that take place
13 within the USACE model area?
14 A. I would like to go back and look at
15 it. It's possible they could have a small
16 amount. But most of that area was primarily
17 cypress forest and I think the categorizations
18 were pretty good across there, you know, for
19 the most part. Now, you're going to get a lot
20 of shrub/scrub in there because of the
21 colonization of the spoil disposal area. A
22 huge increase in shrub/scrub. I knew this was
23 going to confuse everyone.
24 Q. Just for clarification of the
25 record, can you identify where the shrub/scrub
224
1 would have been in your --
2 MS. GILBERT:
3 In the USACE --
4 THE WITNESS:
5 Can I -- I wish this was a little
6 bigger, but if you look -- Okay.
7 Unfortunately, this green, it's
8 overlaying the shrub/scrub categories,
9 but can you see a lot of that would
10 have been in the dredge disposal
11 area. You have also got some that
12 would have occurred here.
13 Unfortunately, you really need to blow
14 this up and pull it up on your
15 computer to see it, but it would have
16 occurred within that spoil placement
17 area.
19 Q. And it's all limited to the spoil
20 placement area; correct?
21 A. Well, I think if we go back to the
22 area table, I think it was like 40-something
23 acres of non-spoil deposited, shrub/scrub are
24 grown or somewhere in there, but we would have
25 to go back and look at it.

225
1 Q. And that would just be 40 acres?
2 A. Yes. Within the '78 channel and
3 spoil disposal area. Not within Dale's -- I
4 mean, not within the working unit. I am just
5 going to say, that information should be in
6 the tables, somewhere in these -- in the
7 tables.
8 Q. And that shrub/scrub, that would be
9 under 20 feet; correct?
10 A. Yeah. It's just a shrub growth.
11 It's not a forested growth.
12 Q. It's less than 20 feet; right?
13 A. Yeah. And don't quote me. I would
14 really like to go back to the NWI. I think
15 it's 18 or 20 feet. I don't remember what in
16 the coding. But it's definitely pretty tall
17 stuff. It's not short.
18 Q. The shrub/scrub you're talking
19 about?
20 A. Yeah, the shrub/scrub, it's
21 definitely below 20 feet.
22 VIDEO OPERATOR:
23 We need to go off the record to
24 change tapes.
25 This is the end of tape 4. We're

226
2 (Recess.)
3 VIDEO OPERATOR:
7 Q. Moving to page 8, please, of your
8 report.
9 A. Sure. Okay.
10 Q. The top of it says "In 1988 the
11 habitat data does identify very limited areas
12 of dead forests." Dale Blitsch was using a
13 term yesterday, ghost forest. Would that be
14 the same thing?
15 A. Yes. It's --
16 Q. Dead forest and ghost forest of
17 cypress?
19 Q. Was any of those ghost forests in
20 the USACE model area?
21 A. Not within the habitat data that I
22 have.
23 Q. Okay. Moving down to the second
24 paragraph, the second-to-last line, talking
25 about the presence of '32 marsh with scattered
227
1 cypress trees class.
2 A. Okay. The '32 T sheet? Yeah.
3 Q. Right. You're talking about the
4 difference between the '32 T sheet swamp class
5 and the '56 habitat swamp class indicates the
6 swamp forest area was transitioning to a marsh
7 environment prior to the construction of the
8 MRGO.
10 Q. Does any of that area include the 20
11 percent of your model which is the MRGO --
12 USACE model area, the transitioning area?
13 A. Yes, actually, if you look at figure
14 -- Oh, heck I have got a binder. 032. I
15 have a binder over here. If you look at this
16 yellow line, that is the USACE MRGO model
17 area.
18 Q. The '32 T sheet?
19 A. Yeah, T sheet, yeah. It's on both
20 figures actually. '32 and 33.
21 Q. Okay. Why is it called a T sheet?
22 A. I assume that was what the
23 oceanographic survey used to refer to. I have
24 just heard the term commonly used for
25 navigation charts.

228
1 Q. T sheets?
2 A. T sheets, yes, just a common phrase.
3 Q. Does the T stand for anything you
4 know of?
5 A. No, I would have to go back and
6 look. I assume it does, but I am not familiar
7 with it.
8 Q. Okay. What were you pointing out to
9 me?
10 A. Oh, the yellow line is the actual
11 model area. What I call the USACE MRGO model
12 is the area that Dale Blitsch used.
13 Q. Right. Okay. And in what areas are
14 you seeing that there's a transitioning to
15 marsh prior to the construction?
16 A. Actually, it's outlined on figure
17 '32 and figure 33. If you look at the orange
18 area, it's kind of a dull orange. You can see
19 it on either particular model.
20 Q. Okay.
21 A. I mean particular figure. That
22 would be the extent of what is classified as
23 swamp forest in 1956. If you look at the T
24 sheet data, which is in '32, you would see
25 that's where you have identified some area of

229
1 swamp and then they also have their scattered
2 marsh swamp and marsh category.
3 Q. I'm still not --
4 A. Trees and scattered tree category.
5 So if you look -- okay. Let's try this. Try
6 category 33. You see the orange, you have
7 multiple figures overlaid on top of it. But
8 if you look at the bottom figure, it's -- it
9 is the 19 -- it is orange, it's -- although
10 it's shaded a slight blue tint because of the
11 overlay, it is the 1956 swamp line.
12 Q. Okay.
13 A. And then if you look, you can see
14 kind of -- well, it's kind of a bluish-tannish
15 color out to that blue line that I was using
16 for my Chalmette wetlands unit, that is your
17 fresh marsh area.
18 Q. Okay.
19 A. And within that, you'd have to go
20 back on the T -- well, you have got it here,
21 too. But it would be their mark -- it would
22 be the interpretation of the 1930 trees and
23 the 1930 scattered trees.
24 Q. Okay.
25 A. Yellow. The blue and -- It's kind

230
1 of hard to interpret because it's multiple
2 overlays on top of each other. But the whole
3 purpose was just to juxtapose the 1956
4 configuration versus -- which is immediately
5 before the MRGO construction versus the older,
6 20-something years prior information.
7 Q. In those areas where it says
8 transitioning, can you describe or can you
9 quantify the amount of transition? Was it
10 50/50 of forest to marsh? And once it gets to
11 51/49 it's classified marsh as opposed to
12 swamp?
13 A. I don't know. It's a classification
14 that was used on the T sheet, whenever the
15 people -- the guys did back in 1932 or 1930 to
16 interpret it.
17 Q. So you're not making any evaluation
18 of what it is?
19 A. No. This is an actual --
20 Q. Just whatever is in the --
21 A. Yes.
22 Q. -- 25 by 25 grid is what you're
23 saying it was? Is that correct?
24 MS. MILLER:
25 Objection. I think you're
231
1 confusing the '56 and '32.
2 THE WITNESS:
3 Yeah. I did not interpret the
4 '32 area. That was interpreted by
5 Fitzgerald, Duncan. The blue area is
6 what is -- was interpreted not by me,
7 but by the NWI interpret- -- it's
8 cypress -- I mean the orange area as
9 cypress forest in 1956.
11 Q. Okay. And so let me ask you, on
12 this are you actually formulating an opinion
13 as to what the habitat and vegetation was
14 there, or are you simply recounting what is in
15 the '32 and '56?
16 A. It would be recounting or deferring
17 to the NWI interpretation since, again, that
18 is the standard that's used for this period.
19 Q. Now, when you say it's converting to
20 fresh marsh, do you know what kind of
21 vegetation is in there? Would it be like
22 rosocanes or giant cut grass which can be 10
23 to 14 feet high, or would it be something --
24 A. No, that was actually the conversion
25 to fresh. Just whatever the fresh marsh

232
1 categorization is on the habitat data.
2 Q. So you wouldn't be discussing anyway
3 the heights of the vegetation; right?
4 A. No, I was using this based on the
5 habitat information.
6 Q. Okay.
7 A. Now, I did go back and look at the
8 photography from the '50s, at least to see
9 what the trees looked like, and Karen Wicker
10 is who actually interpreted some of this
11 information on the '56 data, and it -- she did
12 a fairly good estimate of the actual forest
13 type based on the photography. I mean, you
14 can clearly see on the photography some
15 scattered, you know, very scattered cypress
16 trees.
17 Q. Would you be able to make an
18 evaluation of the health of those cypress
19 trees or cypress stands?
20 A. I can tell you if they were dead or
21 not, but that's --
22 Q. Do you know whether -- Have you seen
23 those photographs? Did you look at those
24 photographs?
25 A. I didn't look at every photograph.

233
1 I looked at a series -- you know, through this
2 area I spot checked.
3 Q. And you did see that the trees were
4 generally alive or dead?
5 A. Once you got within the -- the -- I
6 think this was the '52 photography. Once you
7 got within the '56 zone, they were generally
8 alive. Once you got outside of that, they
9 were dead ones. They had a few -- They may
10 have had one or two scattered that I saw that
11 were alive, but for the most part they were
12 what you -- I hate call it a ghost forest. A
13 few dead trees. It's not a forest.
14 Q. Okay. In that model area, can you
15 give a percentage of the amount of swamp
16 forest that had transitioned to marsh
17 environment?
18 A. I would have to go back and rerun
19 the statistics and stuff on it. It would
20 probably be in some of the area tables. But
21 off the top of my head, no.
22 Q. As you sit here, you don't know it?
23 A. No. I'd have to actually fire up
24 the GIS software and start doing stuff and I
25 really haven't done that.

234
1 Q. Have you done that for this report?
2 A. No. What the -- No. We measured
3 changes, net changes in habitat type between
4 the years.
5 Q. In here, the final sentence of that
6 -- And that would be for the entire MRGO
7 assessment unit or the USACE model area?
8 A. The entire MRGO assessment unit.
9 Q. You indicate in the last sentence of
10 the paragraph "The 1956 habitat data is likely
11 a more reliable indicator of the MRGO --"
12 A. Yes. Preconstruction --
13 Q. Preconstruction?
14 A. -- conditions.
15 Q. When you say "indicator of MRGO",
16 are you talking about the USACE model area or
17 are you talking about the channel itself?
18 A. The actual construction of the canal
19 itself. And the immediate vicinity. Not, you
20 know, --
21 Q. That habitat data, is there an
22 indication of how far away from the MRGO you
23 would spread your habitat conditions?
24 MS. MILLER:
25 Objection.
235
1 THE WITNESS:
2 I can't spread the habitat
3 conditions. The habitat conditions
4 are mapped and embedded in the '56
5 data, so it's actually based on the
6 intersection of the canal with the
7 existing data set. The
8 interpretation.
10 Q. Okay.
11 MS. MILLER:
12 Scott, before the break, you
13 didn't go back to this right after the
14 break, but you were asking about
15 number 7, the distinction between the
16 '88, '56, and '78 data sets that are
17 described there. And there's a
18 reference to attachment 2 on page 7
19 that you I think were asking about at
20 one point. And I discussed that with
21 Mr. Barras on the break and I think
22 that attachment 2 did not end up
23 getting included in what's produced in
24 this group. So we will provide that
25 to you. I only just realized that at
236
1 the break with Mr. Barras, and I
2 apologize for that.
3 MR. JOANEN:
4 Do you know when it is that you
5 will produce that?
6 MS. MILLER:
7 I would think we ought to be able
8 to produce it pretty quickly.
9 MS. GILBERT:
10 Just out of curiosity, is it in
11 one of the binders that you actually
12 have with you? Or is it not even in
13 what you have?
14 MS. MILLER:
15 No. I don't have it. I think
16 that Mr. Barras has it on his
17 computer. I know that we would want
18 to produce it.
19 MS. GILBERT:
20 I was hoping that maybe we could
21 just mark one of your --
22 THE WITNESS:
23 No, it's about 15 pages of codes
24 and de-aggregated codes. It's the
25 original Cowardin codes I told you
237
1 about aggregated up to swamp forest
2 for the '56 and '76 and '88 data
3 sets.
4 MS. GILBERT:
5 That would be why we couldn't
6 find it.
7 MS. MILLER:
8 So anyway, obviously we'll get
9 that to you as quickly as we can.
10 THE WITNESS:
11 Kara pointed that out.
12 MS. GILBERT:
13 Did you have a chance to look
14 through and see if there was anything
15 else that wasn't produced from this
16 report?
17 MS. MILLER:
18 That was the only thing that I am
19 aware of, except for the -- we were
20 also talking at a break, but you have
21 asked about the area, the polygon
22 identified by Dale Blitsch, and that
23 obviously has been produced in a
24 number of reports, but to the extent
25 that there's a particular type of
238
1 software image of that polygon that
2 you all need, I am not certain whether
3 that -- what format it was provided.
4 You know, what digital format that was
5 provided in other than in the expert
6 report.
7 MS. GILBERT:
8 Okay.
9 MS. MILLER:
10 But this attachment to -- That's
11 the only thing I am aware of that
12 wasn't included in all the different
13 figures and attachments. I think it
14 just was a mistake that that one got
15 missed.
17 Q. Do you have any understanding of
18 what the salinity rates in Lake Borgne are?
19 A. I know it's brackish, but no, I
20 don't have -- I don't have an understanding.
21 I would have to go back and look at salinity
22 information.
23 Q. Would that be something that you
24 would be interested in knowing about when you
25 discussed the habitat changes in your expert
239
1 report?
2 A. In this particular report?
3 Q. The one you did for this litigation,
4 yes.
5 A. No. I was looking at long-term
6 changes in habitats.
7 Q. If we were to discuss the relative
8 salinity of Lake Borgne, the southern shore of
9 Lake Borgne prior to the MRGO being put in and
10 the salinity rates of the southern shore of
11 Lake Borgne now, would that be anything that
12 you would be interested in formulating your
13 opinion in the expert report as?
14 A. All I can tell you is just looking
15 at the -- Let's see. The '56, it was
16 non-fresh in '56 and it's -- I guess it looks
17 like it's -- you know, it's going to the
18 brackish category in '78. So you had a shift,
19 some -- possibly a shift, but not that much of
20 a change. Based on vegetation types.
21 Q. Going to page 11 of your --
22 A. Sure.
23 Q. -- report, you talk about forested
24 area changes, discussions focused on
25 identifying changes in the forest class and
240
1 the swamp class.
3 Q. Are those only to forested change
4 discussions that you're dealing with in the
5 area or are there other classes besides forest
6 in the swamp class?
7 A. The only other class I included was
8 shrub/scrub just as an addition to
9 discriminate that between the forested and
10 swamp classes.
11 Q. And why would you do that?
12 A. Because I was asked to look at
13 changes in the cypress forest or swamp forest
14 extent.
15 Q. Who asked you to do that?
16 A. The Department of Justice.
17 Q. Did any of the experts ask you to do
18 that?
19 A. No.
20 Q. Are there any forest class, When you
21 talk about forested change areas to the forest
22 class, in the USACE model area? And, if so,
23 where would that be indicated?
24 A. They would have some forested class
25 and swamp class along the ridges, but it's

241
1 hard -- this scale is too small to see this.
2 It needs to be blown up. But you can see it
3 clearly within that. Also on the area
4 statistics it should list the forested
5 categories within that area.
6 Q. And you are of the ability to
7 evaluate the loss of a forest and swamp class
8 within that assessment, that test area from
9 '56 to '78. Is that correct?
10 A. I can show you --
11 MS. MILLER:
12 Objection.
13 THE WITNESS:
14 Wait. The test areas? Is that
15 Dale's --
17 Q. The polygon. Yes. Let's -- How
18 about if we do this. Because I keep switching
19 back and forth, --
20 A. Yes.
21 Q. -- too. As we sit here right now, I
22 am not going to ask you any questions about
23 your whole Lake Pontchartrain basin.
24 A. Okay.
25 Q. The questions I want to ask you
242
1 about are only within that polygon which has
2 been referred to in your report as the USACE
3 model area.
4 A. Okay.
5 Q. So if we can focus on that for
6 this. When I ask the questions, I am really
7 focusing more on the area in the polygon.
8 A. Unfortunately, I can't provide you
9 all the information you need because most of
10 my area was structured for my units and not
11 for that particular unit, most of my analysis.
12 Q. Does anywhere in your spreadsheets
13 or your attachments or your report indicate
14 what the conversion from forest and swamp
15 class was to other habitats in the polygon?
16 A. Would -- Within the Corps of
17 Engineers -- I mean, Dale Britsch's polygon.
18 I want to make sure. I have the area tables,
19 but I didn't specifically address it in the
20 report. They would be attached in the
21 spreadsheet.
22 Q. I want to show you what has been --
23 I think it's the only one I have. I used the
24 other one today. This is a Corps of Engineers
25 document. It's called "Habitat impacts of the
243
1 construction of the MRGO".
2 A. Okay.
3 Q. Dated December, 1999, prepared by
4 the District Corps of Engineers. Do you need
5 to get that?
6 A. No, I was just checking.
7 Q. And I talked to Dale Blitsch about
8 this yesterday. I'll show your attorney. But
9 this talks about the Central Wetlands Unit
10 which was, as he indicated, the same as his
11 Central Wetlands Unit which was this exhibit 5
12 that he has in his report. Hold on. Which we
13 established yesterday this Central Wetlands
14 Unit is the same as his (indicating).
15 A. Yes.
16 Q. And in this, it indicates that there
17 was cypress forest in this Central Wetlands
18 Unit of 10,200 acres in 1956. Do you have any
19 information which would refute that finding?
20 A. No. They shouldn't refute. I mean,
21 the area is slightly different than the -- I
22 used the Chalmette wetland for my areas. The
23 Chalmette wetland assessment unit, the golden
24 triangle unit to Proctor's Point would kind of
25 contain that same area, and it was basically

244
1 in the same range for the reduction of swamp
2 forest.
3 Q. In this table it indicates that from
4 1956 where you had 10,200 acres of cypress
5 forest to 1978 you had zero acres.
6 A. Uh-huh (affirmatively), that's
7 correct for the Chalmette wetlands.
8 Q. Okay. Do you know what the cause
9 for that conversion from cypress forest from
10 10,200 to zero would be, or the complete
11 eradication of the cypress forest in that
12 Central Wetland Unit?
13 A. I do not -- Go ahead.
14 MS. MILLER:
15 I object to the term "complete
16 eradication". I'm not sure exactly
17 what that means.
19 Q. Well, you had 10,200 --
20 A. Actually, --
21 Q. -- and you wiped it clean, that's
22 why I am defining it as eradication.
23 A. Actually, within the Violet unit in
24 1988 they had about 90 acres or 40 acres. It
25 was hit with that same area near the Violet

245
1 site classified as swamp.
2 Q. Yes. Right, in 1990, again they had
3 90 acres.
4 A. Yeah.
5 Q. Right. But from what they're saying
6 is '56 to '78 --
7 A. Yeah, I agree. That's what my data
8 shows. The same thing.
9 Q. So my question to you was, do you
10 have an opinion as to why that cypress forest
11 would have gone from 10,200 acres in '56 to
12 zip in 1978?
13 A. Well, in reviewing the photography
14 and looking at the spoil deposition after the
15 dredging, you would have actually removed,
16 direct removal from the MRGO and loss of marsh
17 from the spoil deposition.
18 Q. Okay. So you believe that the
19 entirety of the --
20 A. Not the entirety. There's probably
21 other conflicting -- There are obviously
22 salinity increases that have been cited as a
23 possible cause. Increased water logging has
24 been cited as a cause. Since the area is
25 basically impounded.

246
1 Q. Well, okay. First off, let's say
2 that you have already told us that you define
3 a direct removal being --
4 A. The dredging of the spoil.
5 Q. Of the spoil. Do you know what the
6 percentage or the square acres of removal of
7 cypress forest would be due to that direct
8 man-made activity?
9 A. Yes. Actually, if you go to page 5,
10 table 1, that's for the entire area.
11 Q. Okay.
12 A. I mean, -- Wait. I have got it
13 covered. I actually have a discussion in my
14 report. It's table 3, page 16, lists the
15 changes.
16 Q. Okay. And so what amount or what
17 percentage of forest was removed from the
18 Central Wetlands Unit from '56 to '78 due to
19 the direct impact of man of dredging the
20 channel?
21 A. Looks like it's approximately 12
22 percent from direct impacts.
23 Q. Okay.
24 A. I would have to go back and run the
25 numbers, but it's 13 divided whatever, 11,000

247
1 acres or so.
2 Q. You talked also about impoundment.
3 A. Yes.
4 Q. You talked about in your chart there
5 was some impoundment of the cypress forest.
6 A. Yes.
7 Q. Now, Dale Blitsch yesterday talked
8 about the impoundment for that. He indicated
9 that the impoundment was in the '40s.
10 MS. MILLER:
11 Objection.
12 THE WITNESS:
13 Oh, you're confused. Which
14 impoundment? There's -- Okay. Show
15 me what you're defining as the
16 impounded area in the '40s.
18 Q. Okay. For the record, --
19 A. Yes.
20 Q. -- we're talking about figure 6 on
21 page 10 of his report. And he actually has in
22 yellow, has the words "Impounded area"?
23 A. Yeah, I agree with him.
24 Q. Okay. And so the impoundment would
25 have occurred prior to 1942?
248
1 A. Correct.
2 Q. But land loss didn't occur until the
3 '58 to '74 period?
4 A. Let me see.
5 Q. Do you agree with that?
6 A. Correct, but I know actually if you
7 look at 1960, there's some '65, '66, '68
8 photography after Hurricane Betsy; those were
9 impounded areas that were flooded after
10 Hurricane Betsy.
11 Q. Right. That was all after the
12 cutting of the LaLoutre Ridge, too, by the
13 MRGO; correct?
14 A. Well, it would have been after.
15 Yeah, it would have been after the MRGO's
16 construction.
17 Q. Right. Now, is it within your
18 expertise to opine whether cypress forests in
19 this impounded area could have survived had
20 there not been salinity intrusion into that
21 impounded area?
22 A. Yeah, there's a possibility the
23 cypress would have survived. It would have
24 been like any other natural distributary ridge
25 system in coastal Louisiana, but slowly

249
1 submerging and becoming inundated, so it's
2 likely you would have had some cypress forest
3 remaining in the area.
4 Q. As part of your expertise or as part
5 of your formulating your opinion regarding the
6 land loss rate within an area that was
7 impounded, are you familiar with the average
8 rainfall amounts from 1942 to 1958?
9 A. No, I would have to look at the
10 climatological records for that.
11 MS. MILLER:
12 Objection.
14 Q. And the same question, your
15 knowledge of the average rainfall rates from
16 '58 to the '74 period?
17 A. Again, that's -- you would have to
18 look at the records.
19 Q. In your opinion, would it be the
20 same after 1974? You don't know whether that
21 area was having average rainfall or drought
22 periods or anything of that --
23 A. No.
24 Q. -- nature; right?
25 A. No.

250
1 Q. In your investigations leading to
2 your opinions regarding this impounded area,
3 have you been able to find any tables, charts,
4 graphs, or studies which evaluated the
5 salinity level within that impounded area
6 that's identified in figure 6 of Dale
7 Blitsch's report?
8 A. Again, --
9 Q. From 1958 to '74?
10 A. -- the impounded area is only the
11 small orange rectangles that you're referring
12 to?
13 Q. That's where he has it. That's
14 where he has it.
15 A. Again, I'll refer again you to that,
16 you know, after looking at photography after
17 Hurricane Betsy the area was flooded.
18 Q. Right.
19 A. So --
20 Q. And so was the Lower Ninth Ward;
21 right?
22 A. Yeah, but that remained flooded and
23 they didn't repair the levees and pump it
24 out.
25 Q. Some people -- Well, --
251
1 A. What?
2 Q. Like they were blowing the levee,
3 were they?
4 A. I remember Betsy. I was three years
5 old. It wasn't fun.
6 Q. Also, too, we have in this chart,
7 which is part of this 1999 report from the
8 Corps of Engineers, it indicates that the
9 amount of fresh to intermediate marsh went
10 from 11,600 acres down to 1,520 acres.
11 A. What years?
12 Q. From '56 to '78.
13 A. Okay. Yeah, I would agree with
14 that.
15 Q. Okay. However, we see that the
16 amount of brackish marsh went from 13,490 to
17 21,710 in that same time period.
18 A. I agree. We probably ran the
19 numbers for the Corps for that.
20 Q. Okay. Is there -- Now, also, too,
21 we have in the Central Wetlands Unit that
22 there is an increase of water from 4,020 acres
23 to 6,800 acres, so there's definitely an
24 increase in land loss rate during that time
25 period; correct.
252
1 A. Yes. And actually if you examine
2 the high density landsat data on an annual
3 basis from 1983 to the present, you can see
4 that that area continuously begins to impound
5 water. There was also expansion of ponds in
6 the south caused by Hurricane Katrina's
7 surge. And these particular ponds to the
8 north are actually probably not the impounded
9 areas that flooded after Betsy, but these were
10 probably from the 1947 or '48 hurricane which
11 has caused fairly massive land loss within the
12 area based on looking at bracketing the 1940s
13 photography and the early '50s.
14 Q. Okay. Have you looked at any aerial
15 photography for the area that is near the
16 fresh water pumping station and the sewage
17 treatment plants that pump fresh water and
18 then treated sewage over the 40 Arpent Canal?
19 A. I have looked at the Violet site and
20 again looking at the landsat data, you can see
21 -- Actually, you can see it here. When you
22 start seeing the bluish purple areas, that's
23 actually an area of total water and over time
24 those areas have increased in size.
25 Q. The area of water or the area of
253
1 cypress?
2 A. The area is wetter. It's not the
3 area of cypress. It's got to be some stuff,
4 marsh converting to water.
5 Q. Okay. But you would agree that near
6 the fresh water pumping station and the sewage
7 treatment plant that's pumping those effluents
8 over the 40 Arpent Canal levee, that in that
9 area there is still viable cypress?
10 A. In 1988 there was. I don't know if
11 it's still viable. I mean, I haven't looked
12 at any recent photography or driven there.
13 But I know it was a very small area.
14 Q. Is it within your area of expertise
15 that you would be able to evaluate why there
16 is a reduction of freshwater intermediate
17 marsh and cypress forest from 1956 to 1978 as
18 set forth by the Corps of Engineers in this
19 report?
20 A. It would have been a conver- -- you
21 would have to look at the long-term conversion
22 of habitat types.
23 Q. Now, do you know what the average
24 lifespan of a cypress, bald cypress tree is?
25 A. Actually, I don't. I imagine it's

254
1 quite a long time from the first growth
2 forest. Several hundred years.
3 Q. And we have already established that
4 you wouldn't know what the viability of a
5 cypress tree is relative to the parts per
6 thousands of saline in the water?
7 A. Yeah, the lower, you know, the lower
8 salinities, definitely it wouldn't survive the
9 -- what was this, Exhibit 3, the --
10 Q. When it got higher; right?
11 A. These are actually fairly low. But
12 then once you got up to the very high
13 salinities, no, it wouldn't survive that.
14 That's a salt -- getting from brackish to salt
15 marsh.
16 Q. So is it within your area of
17 expertise to testify that cypress trees are
18 viable when the salinity levels of the water
19 that affects it is less than or equal to 5
20 parts per thousand?
21 MS. MILLER:
22 Objection.
23 THE WITNESS:
24 If I have researched the
25 literature I would feel more
255
1 comfortable with it. But I know
2 you're not going to have cypress trees
3 in a brackish marsh.
5 Q. Okay.
6 A. Matter of fact, most of the habitat
7 data shows they had some intermediate marsh
8 linges by '78, but the cypress was gone then.
9 Q. But you're also indicating here that
10 there's a loss of nearly 10,000 acres of fresh
11 and intermediate marsh --
12 A. Yes.
13 Q. -- in that same time period, that 20
14 year time period.
15 A. I'm not disputing that the marsh
16 converted. No. It's obvious.
17 Q. Now, in this same page 11 you talk
18 about the total forest class area remained
19 essentially the same for all physiographic
20 classes between 1956 and 1970. What do you
21 mean by that, physiographic classes?
22 A. It's the entire area. If you go
23 back to -- what was my first figure -- 027,
24 this entire -- the entire area that I was
25 analyzing, excluding the Lake Borgne and

256
1 Chandeleur areas.
2 Q. Okay. If we utilize this data from
3 the 1999 report, which indicates that you lose
4 10,200 acres of cypress forest and then
5 forest, you lose 200- --
6 A. You're comparing apples and
7 oranges. This is for a smaller area.
8 Q. That's what I was going to say. Let
9 me ask the question first. I know that you're
10 talking about the total forest area in your
11 whole Lake Pontchartrain basin. If you have
12 this loss here of 10,200 acres of cypress
13 forest in the Central Wetland Unit and a loss
14 of approximately 2,100 acres of forest in the
15 Central Wetlands Unit and you make a statement
16 here that the forest class area remained
17 essentially the same, would that mean when
18 they lose 12,000 acres in this area, that it
19 was made up somewhere else?
20 A. Yes. You have changes occurring
21 within the overall area.
22 Q. And so the numbers that you're
23 running here, you're running numbers for the
24 whole basin?
25 A. Yeah, the report was designed to

257
1 summarize the entire basin. The actual
2 changed numbers per units are included in the
3 spreadsheets, so you can go through any of the
4 spreadsheets and find the change per unit.
5 Q. But when you make these statements,
6 you're not saying that these areas or the
7 events that you're discussing here are
8 necessarily affected by the influence of the
9 MRGO; correct?
10 A. No, I am not. I am saying it's
11 within the entire -- the entire area that was
12 used for the study.
13 Q. Now, you do indicate that the
14 wetland physiographic unit lost 7,600 acres of
15 swamp between '56 and '78.
17 Q. Other than the swamp that is in the
18 model area, what other areas of swamp?
19 A. Which? I'm sorry, I just want to
20 check which page.
21 Q. That's on 11 still.
22 A. Okay.
23 Q. That same paragraph.
24 A. Okay.
25 Q. The wetland physiographic unit lost
258
1 7,600 acres of swamp between '56 and '78. Do
2 you know where the LaBranche Wetlands are?
3 A. Yes, I do, but they weren't included
4 in this analysis.
5 Q. Okay. The 7,600 acres of swamp that
6 were lost between '56 and '78, do you know
7 where those were located?
8 A. I would have to actually go
9 specifically back to the map and look at the
10 changes, but that was just the summation for
11 the entire area.
12 Q. So as you sit here right now, you
13 can't tell us what amount -- how many acres of
14 swamp were lost in the study area from 1956 to
15 '78?
16 A. I would have to go back to the
17 spreadsheets and look at the information for
18 that particular area.
19 Q. And the DOJ attorneys never asked
20 you to do that?
21 A. I was not --
22 MS. MILLER:
23 Objection. He testified that
24 it's in the spreadsheets attached to
25 his report.

259
2 Q. They didn't ask you to put it in
3 your report?
4 A. No, it was the -- The report, I was
5 asked to summarize the changes over the large
6 area. But I included the subunits if they
7 were needed for analysis.
8 MS. MILLER:
9 And the spreadsheet has --
10 THE WITNESS:
11 Yes, the spreadsheet has all of
12 that in it.
14 Q. When you talk about the shrub/scrub
15 wetland physiographic area increasing
16 dramatically between '56 to '78 by 22,023
17 acres, would that be within the scope of your
18 expertise to say that that is a natural
19 progression when you lose swamp?
20 A. That was not a natural progression.
21 Most of -- Most of that particular change
22 occurred within the MRGO spoil area, which is
23 -- there was probably some natural
24 progression, but the large majority of the --
25 the majority of it occurred within that spoil

260
1 disposal unit for 1978.
2 Q. And which you classified as direct
3 change as opposed to indirect; correct?
4 A. That wouldn't -- That would just
5 have been an area summary. I mean, I consider
6 that more of a habitat change than a direct --
7 The direct changes are more or less land loss
8 changes.
9 Q. Okay. Fair enough.
10 A. Actually, figure 6 shows most of
11 those. On page 12.
12 Q. Figure 6. You on figure 6? Okay.
13 In your -- You have the four physiographic
14 units. You have upland and fast land which we
15 know upland doesn't -- isn't included in our
16 study area. Fast land you said might not be,
17 but you wanted to double-check on that.
19 Q. So what about a ridge, though?
20 Ridge is included in your --
21 A. Yes.
22 Q. -- study area. And I see that you
23 have swamp from 1956 at about maybe 3,000.
25 Q. Those are acres on the left I am
261
1 assuming; right?
2 A. Yes.
3 Q. And then you have no swamp from '78
4 and no swamp to '88.
6 Q. Obviously there was a certain
7 percentage of the land that encompassed
8 swamp. What was on that land when there was
9 no longer swamp there?
10 A. Most of that had transitioned to
11 intermediate marsh if you look -- Actually,
12 you can see it on -- Well, you can't. It's
13 kind of hard to see it on the smaller
14 figures. But you have the data, you can pull
15 it up. Along those ridges, a lot of that,
16 except for the Bayou Savage Ridge which was
17 located kind of in New Orleans East where they
18 had a lot of development from the '50s to the
19 '70s.
20 Q. But in your -- in the study area,
21 really it's just the LaLoutre Ridge; right?
22 A. It's LaLoutre. Well, LaLoutre and
23 Delacroix Ridge. The ridge complexes. It
24 does include -- It does include some of the
25 Bayou Savage. They did have some cyp- -- or

262
1 at least swamp forest identified along Bayou
2 Savage, too. It's a very tiny area. If you
3 look at figure -- Bayou Savage. It's figure
4 027. It's that orange area that would have
5 been considered part of the Bayou Savage
6 Ridge.
7 Q. But that's outside the yellow dotted
8 line, isn't it?
9 A. Okay. Again, I forgot we're only
10 dealing with the yellow dotted line.
11 Q. I apologize. I'm trying to focus
12 just on our little --
13 A. You're not going to get that from
14 this, because this includes the entire area.
15 Q. Okay.
16 A. This chart.
17 Q. Okay. So can you quantify the
18 amount of swamp lost to the ridge that is
19 within the study area?
20 A. Yes, but I'd have to go back and
21 reanalyze it.
22 Q. And so that swamp became
23 intermediate marsh?
24 A. Yeah. You can just look at the
25 information, pull it right up and there's a

263
1 lot of intermediate marsh in that area.
2 Q. And would it be your belief that
3 intermediate marsh -- Dale Blitsch yesterday
4 testified that he believes generally
5 intermediate marsh is about a meter high. Do
6 you have anything --
7 A. I defer to Dale on that. But it's
8 obviously increasing in salinity contents. It
9 transitioned from what was a fresher
10 environment in the '50s to a higher salinity
11 environment.
12 Q. In the wetland part, you have
13 obviously again forest and there's a
14 tremendous increase in forest from '56 to
15 '88.
17 Q. Based upon the questions I had
18 before with this '99 report, it would be your
19 opinion that that increase in forest in '88
20 occurred in areas outside of the study area;
21 correct?
22 A. Yes. Again, the study area, I want
23 to make sure --
24 Q. The yellow dotted line.
25 A. -- is the yellow dotted line.

264
1 Okay. Yes.
2 Q. The polygon as Mr. Blitsch referred
3 to it.
4 A. Yes, polygon.
5 Q. You want to refer to it as the
6 polygon?
7 A. Yes.
8 Q. As long as you and I are
9 communicating, we're doing all right.
10 A. Yes.
11 Q. Okay. We have swamp from '56 to
12 '88.
13 A. Uh-huh (affirmatively). We're on
14 the wetland category; right?
15 Q. Right.
16 A. Okay.
17 Q. We do see a tremendous decrease in
18 swamp from '56 all the way down to '88. Is
19 that correct?
20 A. Yes.
21 Q. And if we look at that '99 report,
22 which indicates that -- Well, they don't list
23 swamp here in the Central Wetlands Unit. They
24 list cypress forest. Would that be --
25 A. The same thing. That's from the '88

265
1 classification. That's why you have got
2 actually that little yellow blips where you're
3 getting the cypress forest. That's probably
4 where that is -- I just called everything
5 swamp across the board on it.
6 Q. And this would include the areas
7 both within the polygon and throughout the
8 whole Lake Pontchartrain basin; correct?
9 A. Within the wetland areas, yes.
10 Which would have been your Chalmette wetlands.
11 Q. And then finally we get to the last
12 three categories, which is shrub/scrub from
13 '56, '78, and '88. Why is it that you have
14 the same colors for '56 and '88 shrub/scrub?
15 A. Probably an error on my part when I
16 was making the graph.
17 Q. Okay.
18 A. I meant to use a different color
19 blue and I probably didn't catch it.
20 Q. We see a tremendous increase in
21 shrub/scrub from '56 to '78.
22 A. Again, that is primarily from the
23 spoil deposition area colonized by
24 shrub/scrub.
25 Q. Okay. And so then on 12 you say,
266
1 when you compare the data from '56, '78, and
2 '88 in the switching patterns from swamp and
3 forest class within the fast land wetland
4 physiographic units, the only one of those two
5 physiographic units that we would be concerned
6 about as it affected the polygon would be the
7 wetland unit; correct?
8 A. Correct. Yes.
9 Q. And the predominant change on that
10 is the loss of the swamp from '56 through '88
11 and then the tremendous increase in
12 shrub/scrub --
14 Q. -- due to the spoil channel being
15 placed there.
16 A. Yes.
17 Q. Let me ask you just a few
18 questions. Yesterday I was asking Dale
19 Blitsch about an article that he had added his
20 name to. It was an article that was written
21 by a Dr. Day, Dr. Schafer, and Dr. Blitsch.
22 And I am not asking you to opine as to whether
23 what he says is right or wrong. I want to ask
24 you if this comment that he made would be
25 something within your area of expertise,
267
1 something that you could comment upon. "The
2 construction of the MRGO Gulf Outlet led to
3 saltwater intrusion and caused the death of
4 almost all of the taxodium --" Do you know
5 that taxodium swamps are?
6 A. It's --
7 Q. Bald cypress?
8 A. Yeah. Taxodium.
9 Q. "-- and caused almost all of the
10 taxodium swamps which formerly occurred east
11 of the Mississippi River between New Orleans."
12 Would that be something you could comment on
13 as an expert?
14 A. All of the cypress swamps east of
15 New Orleans?
16 Q. I am reading it verbatim.
17 A. I think they're probably --
18 Q. Almost all. Almost all.
19 A. That wouldn't include the Pearl
20 River swamps, I'd assume. That's east of New
21 Orleans. I would assume that within the
22 localized Chalmette area, the wetlands, the
23 Central Wetlands Unit, that's probably a
24 somewhat true statement. I would agree.
25 Q. Would that be the kind of thing that
268
1 you would defer to the expertise of Dr. Day,
2 Dr. Schaefer and Dr. Blitsch?
3 A. For the ecology components, yes.
4 The habitat, I mean it's pretty clear it's
5 what's occurring.
6 Q. And that would be somewhat
7 consistent if you do believe the graphs I have
8 shown you?
9 A. Of course, it would be nicer to have
10 multi-year data, multi-seasonal data rather
11 than a couple of snapshots in time.
12 Q. Like my five year old step-neice
13 said after the storm, "You get what you get
14 and don't pitch a fit."
15 A. The same way with the habitat data.
16 Q. The next sentence of that says "Some
17 of this area is now open water, but much of
18 the swamp is converted to Spartina marsh
19 scattered with ghost cypress trunks." Do you
20 know what Spartina marsh is?
21 A. Yes, it's the brackish marsh.
22 Actually, you can still see the logging scars
23 in the marsh within the Chalmette unit on the
24 photography, on the modern photography quite
25 clearly.

269
1 Q. Now, those logging scars, that
2 indicates that cypress trees were removed.
3 A. Yes, it was close to New Orleans, a
4 cheap source of lumber, railroad ties and
5 stuff, so it would have come out quickly.
6 Q. Is it your belief that that --
7 although the cypress forests of the first
8 growth were reduced, cut down, that a second
9 growth forest came over, came back and --
10 A. Obviously. Most of Louisiana, it
11 occurred the same.
12 Q. So is there -- when you see logging
13 scars, what's the big deal?
14 MS. MILLER:
15 I object.
17 Q. If the second growth forest, second
18 growth cypress comes back right over where it
19 as?
20 A. It's just indicating it's not virgin
21 cypress forest. I mean, it's probably just an
22 indicator that it's just not a first growth
23 forest.
24 Q. Would it be within your area of
25 expertise to evaluate the frictional
270
1 capabilities of first growth forest versus
2 second growth cypress forest?
3 A. No, that's not my area of expertise.
4 MS. MILLER:
5 Objection to form. He's already
6 answered that.
8 Q. During any of the discussions you
9 had with the experts for this litigation, was
10 there any discussion that you overheard in
11 which they were opining that second growth
12 cypress forest would have a reduced frictional
13 capability relative to Mannings coefficient of
14 frictions than original cypress forest?
15 A. No. The only question I received
16 was the question on Monday about what a
17 cypress forest of height -- what I considered
18 a cypress forest based on the habitat data.
19 Q. And you would have told them above
20 20 feet?
21 A. Yeah. 20, around 20 feet or so.
22 Q. There's also a question I asked Dr.
23 Blitsch yesterday, and this is from a report
24 that is listed in Science Magazine.
25 A. Is this Turner's?

271
1 Q. This is the only copy, so I'll show
2 it to you, but I need to get it back so I can
3 ask you the question.
4 A. Yeah. Yeah, that was --
5 MS. MILLER:
6 If you want to take a look at
7 that in more detail, you can.
8 THE WITNESS:
9 That's all right.
11 Q. I'm just asking mostly if this type
12 of information I'm asking you is within the
13 area of your expertise. And in here it says
14 "Deep straight navigation canals cause
15 saltwater intrusion and the death of
16 freshwater plant communities". Is that
17 something you could opine?
18 A. I could opine on land loss patterns
19 occurring within fresh marsh or conversion of
20 fresh marsh due to the brackish over -- over
21 periods based on the habitat information.
22 Q. And would that also include the
23 conversion of the habitat?
24 A. You would have habitat conversion,
25 but it's actually more complicated than

272
1 saltwater intrusion. Again based on work I
2 have done with Bob Morton with rapid
3 submergence of land loss, Bob, Robert Morton,
4 some of these areas in fresh marshes that were
5 once considered caused by saltwater intrusion
6 actually submerged quite rapidly and there's
7 alternative theories as to what actually
8 caused that land loss. Fluid extraction. So
9 there's just one theory. There's actually
10 multiple processes causing this.
11 Q. Sure.
12 A. So I am not going to dispute that --
13 you know, I agree that saltwater intrusion
14 causes conversion, but it's not the only
15 process.
16 Q. I don't think they're saying it's
17 the sole cause. They're just saying --
18 A. No. But it's just one of the
19 causes, yes.
20 Q. And then the statement goes on to
21 say that "One of the most notable of these
22 deep straight navigation canals is the
23 Mississippi River Gulf Outlet, a 12 by 300
24 meter canal dredged through the Breton Sound
25 basin in 1963. That's just -- It says what it
273
1 says.
2 A. Yeah.
3 Q. But then the next sentence says
4 "Saltwater intrusion via the MRGO killed
5 thousands of hectares of freshwater wetland
6 forest.". Would that particular sentence,
7 that statement be something that you could
8 opine upon within your area of expertise?
9 A. Based on the habitat changes, I
10 would agree that there was some changes that
11 -- you obviously have already documented the
12 direct impacts from this, but again, you would
13 have in the spoil bank areas the changes there
14 that obviously increased in salinity. The
15 vegetation shifted somewhat on the ridges.
16 Q. Okay. Can you, in your scope of
17 expertise, testify to the percentages that
18 saltwater intrusion would have had in
19 affecting the habitat changes?
20 A. I actually --
21 MS. MILLER:
22 Objection.
23 THE WITNESS:
24 No, I wouldn't. I think it's
25 fairly complicated to go into that.

274
1 And again, I think there's other
2 processes that are causing changes
3 that may have once been thought to be
4 due to saltwater intrusion, but could
5 be from other processes.
7 Q. When you say "could be", is that
8 something that is within your scope of
9 expertise to testify to?
10 A. I am comfortable documenting direct
11 physical removal from hurricane impacts. As
12 far as other causes, you get into very
13 complicated factors and I would defer that to
14 experts in those -- in each of those
15 particular areas.
16 Q. Okay. And in none of the papers
17 that you submitted for peer review
18 publications have you forwarded your opinion
19 that impacts that at one point may have been
20 saltwater intrusion could be related to some
21 other type of impact?
22 A. Actually, I stated fairly directly
23 that hurricane impacts probably caused much
24 more land loss than what was originally
25 anticipated.

275
1 Where are we going now?
2 Q. Moving to page 18, we're kind of
3 rolling along now.
4 A. Okay.
5 Q. I'm sorry. Go back to page 17,
6 please.
7 A. Okay. Sure. Where at?
8 Q. It's the bottom of the first
9 paragraph. It starts off "Large staggered
10 east, northeast and west trending ponds".
11 A. Yes.
12 Q. That's in the Chalmette wetland
13 unit. When you talk about the Chalmette
14 wetland unit, is that similar to the Central
15 Wetland Unit that Dale Blitsch is referring to
16 in his figure 4?
17 A. Yes, but it's actually a
18 subcomponent. You would have to include my
19 golden -- If you go to figure 033, you would
20 actually have to include the golden triangle
21 to Proctor Point wetland and the Chalmette
22 wetland together to get Dale's -- I think to
23 be equivalent to Dale's Central Wetland Unit.
24 You would have to include portions of it.
25 It's not all together. The Chalmette unit

276
1 doesn't completely encompass the Central
2 Wetlands Unit. I think the Central Wetlands
3 Unit uses the MRGO boundary. So I don't have
4 it -- It's not an exact. There's a slight
5 overlap between the two units.
6 Q. Okay. The final sentence of that
7 paragraph says "The detailed examination of
8 the study area using historical aerial
9 photography and/or historical maps --" What's
10 that?
11 A. I forgot what page we were on.
12 Q. Okay. 17. "-- will likely reveal
13 additional causes of land loss."
14 A. Yes.
15 Q. Does that mean that you haven't
16 looked into that?
17 A. I have looked into it. Some of the
18 information -- I mean, it's stuff that I
19 observed, like I was showing you with this,
20 just based on the photography. When you start
21 finding enough bracketing photography, you can
22 identify when these impoundments basically
23 failed, what caused the formation of these
24 long scars in this particular area. This is
25 pre-MRGO. This is from probably from one of

277
1 the hurricanes in the '40s. Actually, Shea
2 Penland agreed with me on that. We had
3 discussions on that before he passed. And I
4 think Dale's of the same opinion. But there's
5 -- it's not just one particular factor
6 causing. There's other factors causing loss
7 within that unit.
8 Q. Can you identify the historical
9 aerial photography and historical maps that
10 you would rely upon to reveal additional
11 causes of land loss in that area?
12 A. Yes.
13 Q. And what would that be?
14 A. Let's see. It would be the 1940s
15 ACS photography provided by the Department of
16 Justice, the photography that Dale Blitsch
17 used in his report, some of the obliques to --
18 By photography, I also, I prefer the old --
19 the vertical photography where the planes fly
20 straight over. But the oblique information is
21 useful, too, for assessing changes.
22 Q. I don't know what an oblique --
23 A. Oblique, you're flying in a plane,
24 it's a low angle shoot, less than 90 degrees.
25 You're flying a plane and just looking out.

278
1 It's an oblique shot. Sorry.
2 And also any -- I think we have
3 '68, '69 photography. 1965 photography for
4 the coast. There may be some '6- -- small
5 pieces of USGS '65, '63, '66. There's several
6 different sources.
7 Q. Would it be within the scope of your
8 expertise to opine whether these trending
9 ponds that you're equating to --
11 Q. -- hurricane events were exacerbated
12 or enlarged by the death of the marsh due to
13 saltwater intrusion which then led to land
14 loss changes?
15 A. Within that particular unit, those
16 features performed sometime in the 1940s which
17 pre-dated the development of the MRGO. Now,
18 the other features that we found, modern
19 features from Hurricanes Katrina and Rita were
20 actually further and more of the fresh and
21 intermediate marshes in upper Breton Sound.
22 So they weren't particularly -- this area
23 actually weathered the hurricane fairly well
24 as far as forming large new physical scars
25 from the surge. Although in this particular

279
1 spot there was some scouring and increase of
2 pond size from the surge, or at least from the
3 hurricanes. From Katrina.
4 Q. And would that be -- That scour,
5 would that be from winds?
6 A. I would assume it's from water. The
7 wind probably wouldn't have enough force to do
8 that type of damage.
9 Q. The wind would not?
10 A. It's surge, surge scour.
11 Q. Well, my understanding of the
12 dynamics of what happened here, this levee
13 failed and the water was rushing through
14 here.
15 A. Yeah. Or it would have been -- it
16 would have been as water, but it's water. It
17 would have been caused by natural movement of
18 the water in that area.
19 Q. And so water is moving through, it
20 has enough energy, it just digs it up? Is
21 that what they're saying?
22 A. Yes. I mean, we have numerous
23 examples across the coast of that. I mean, I
24 have got a report online that shows picture
25 after picture of similar types of damage in

280
1 different marsh types from Katrina and Rita.
2 Q. Getting back to the question I had
3 when we were talking about the '47 scour
4 marks, is there a way that you can go through
5 your mapping and outline what the open water
6 would be --
7 A. You could. We don't -- That data
8 again --
9 Q. -- and then watch how it grows, and
10 is there an exponential change on certain
11 times?
12 A. Yes. Yes, and that's the whole
13 purpose of some of the research of hurricane
14 impacts, to see if you have a sudden, quick
15 increase in land loss, it really doesn't fend
16 for this nice linear -- People assume you're
17 losing X number of acres per year. It just
18 doesn't always happen that way.
19 Q. And has that type of study been done
20 in the, what you have classified as the
21 Chalmette wetland unit and then also in the
22 golden triangle?
23 A. I did not do it specifically. I did
24 it for the entire coast. Basically the 2006
25 report I had on Katrina and Rita and then the

281
1 2008 report documented impacts, plus I had
2 another report that just showed that there's
3 -- There's about three of them that
4 illustrate hurricane impacts and cite land
5 loss numbers across the coast after the storm.
6 Q. Okay. On page 18 I was a little
7 confused more than anything else. You have
8 the first sentence, you have under the
9 "Chalmette wetland" title, it says "Land loss
10 trend within Chalmette wetland unit and the
11 golden triangle to Proctor Point wetland was
12 physically examined to determine the possible
13 MRGO land loss impacts". And you say
14 "Together, these units comprise the area
15 commonly referred to as the Central Wetlands
16 Unit." And so my question to you was where
17 did you come up with the combination of those
18 two areas to be the Central Wetlands Unit?
19 A. It's actually not -- Again, it's
20 close to it. It doesn't -- The Central
21 Wetlands Unit is a slight overlap. I probably
22 should have clarified that in the report. But
23 this Chalmette unit is probably closer to the
24 Central Wetlands Unit. Including the Proctor
25 Point unit. There's a slight overlap with the

282
1 Proctor Point unit. It's not -- Because it
2 was based on a 1956 fresh marsh swamp
3 boundary, that 100 meter buffer, it doesn't
4 exactly match.
5 Q. Okay. The study area that you're
6 referring to here, does that include the
7 Central Wetland Unit which starts up north of
8 Chalmette going along the GIWW area?
9 A. This down here (indicating).
10 Q. And then passes down, going in a
11 southeasterly fashion to past Fort Beauregard
12 up to Proctor Point?
13 A. If you combine both of those units,
14 both of the units that I have, the Chalmette
15 and the golden triangle of Proctor Point, it
16 would probably include this, this particular
17 area here (indicating).
18 Q. Right.
19 A. So it pretty much gets both areas.
20 Q. So when you're specifying the
21 Central Wetlands Unit, your Central Wetlands
22 Unit is different than --
23 A. It's slightly --
24 Q. -- than the one that is specified by
25 Dr. Blitsch in figure 3?
283
1 A. Right. That's the LCA center and I
2 probably should have clarified that a little
3 more.
4 Q. When you talk about the net loss
5 from '56 to '78 --
7 Q. -- of golden triangle to Proctor
8 Point wetland unit being 5,431 acres, is that
9 going to be the area that is north of the MRGO
10 along the shoreline of --
11 A. Yeah, it would be --
12 Q. -- Breton Sound?
13 A. Yeah, it's actually northeast.
14 Q. And then the total net loss from
15 1978 to 2006 indicates 1,691 acres.
17 Q. Indicating MRGO did cause
18 significant loss in the area.
19 A. There should have been an addition
20 of the sentence "during the 1956 to 1978
21 period". I was reading that and it didn't
22 make sense. It wasn't clear to me either.
23 Q. Okay.
24 MS. MILLER:
25 I'm sorry, what are you -- what's
284
1 your --
2 MR. JOANEN:
3 The first paragraph under
4 "Chalmette wetland, golden triangle".
5 MS. MILLER:
6 Total net loss from '78 and 2006,
7 you're saying that should be '56 to
8 '78?
9 THE WITNESS:
10 No, no, no. It's correct. It's
11 just I should have added a qualifier.
12 The 1,691 acres as compared to the
13 5,400 acres from '56 to '78, it
14 clearly shows that the MRGO impacted
15 the area.
16 MS. MILLER:
17 Okay.
19 Q. Now, would that be for only land
20 loss or --
21 A. This is land loss. Land-water.
22 Yeah.
23 Q. And are there -- Can you calculate
24 the number of acres -- Well, let me ask you,
25 when they dug up the MRGO, does the channel of
285
1 the MRGO fall within what you're defining as
2 the golden triangle to Proctor Point --
3 A. Yes.
4 Q. -- such that the direct removal of
5 soil is part of the 5,431 acres?
6 A. Yes, it does. Actually, if you
7 refer to table 3, it includes the entire
8 channel width. I didn't bisect it by those
9 units, so where I would just identify the
10 direct loss caused in spoil disposal there
11 within the golden triangle unit. I didn't do
12 that.
13 Q. What page is that on?
14 A. I'm sorry. Page 16. And if you go
15 to -- Anyway, -- Well, actually, this last
16 land loss figure is a little better. Oh,
17 great, no number. 034.
18 MS. MILLER:
19 I think it's cut off by the green
20 --
21 THE WITNESS:
22 Yeah, it got cut off on the
23 binding. It's actually easy to see.
24 The green and blue area is the area I
25 was using as this direct impact area.

286
1 So it's a little easier to see on this
2 figure.
4 Q. And let me see the title.
5 A. Yes. Yes. It's much easier to
6 see. And what -- Although also it does follow
7 the unit you're interested in. Actually gives
8 you a pretty good idea. It basically falls
9 within the modeling unit, whatever you want to
10 say, the unit.
11 Q. So just so I understand, when you
12 talk about the direct removal of soils, that
13 wouldn't be in what would be the Chalmette
14 wetland unit. That would be in the golden
15 triangle to Proctor Point wetland unit;
16 correct?
17 A. Yeah, it would kind of share the
18 boundary because of where the boundaries of
19 the unit are, but I would have to actually
20 reanalyze it to specifically extract that
21 information within those two units.
22 Q. Okay. Now, are you aware of what
23 the --
24 VIDEO OPERATOR:
25 Change tapes.
287
1 That's the end of tape 5. We're
3 (Recess.)
4 VIDEO OPERATOR:
8 Q. On page 18 of the report you're
9 talking about net losses of land from '78 to
10 2006 and also net loss from '56 to '78 in the
11 area that you are describing as the golden
12 triangle to Proctor Point --
13 A. Uh-huh (affirmatively.)
14 Q. -- wetland assessment unit.
15 Correct?
16 A. Yes.
17 Q. And you said that a lot of this net
18 loss from '56 to '78 was due to the direct
19 impact of the dredging of the MRGO; correct?
20 A. Yes.
21 Q. Are you familiar with the fact that
22 the -- and that was the original dredging?
23 Would that be the case?
24 A. Yes.
25 Q. Are you familiar with the opinions
288
1 of some that wave wash from vessels traversing
2 the MRGO led to erosion of the banks of the
3 MRGO?
4 A. Yes.
5 Q. Are you aware that over the course
6 of the many, many, many, many years that the
7 MRGO was in operation, that the Corps of
8 Engineers had ongoing dredging operations
9 throughout the MRGO?
10 A. Yes.
11 Q. And is it within the scope of your
12 opinion to testify how that dredging would
13 have affected the bathymetry of the channel?
14 A. No, not the bathymetry.
15 Q. Is it within the scope of your
16 expertise to determine the amount of land loss
17 in this area, the golden triangle to Proctor
18 Point wetland, due to the original dredging of
19 the MRGO, the loss of the banks due the wave
20 wash, and then the subsequent dredging of the
21 MRGO channel to keep the channel within the
22 500 foot wide, 36 foot depth?
23 A. No, it is not. I am limited by the
24 source data that I had to work with.
25 Q. And the source data that you're
289
1 talking about, which would have been talking
2 about net land loss from '78 to 2006, what was
3 that source data?
4 A. For the historical period which
5 would include the 1956 and '78 data, it would
6 obviously be the habitat data sets. Past that
7 point, I have numerous landsat -- land-water
8 updates of that area where you can actually
9 see dredge disposal from the MRGO placed in
10 the Proctor Point wetlands which actually
11 probably offset some of the land loss.
12 Q. So that was going to be my question
13 I was building to. Is it possible to, when
14 you talk about net loss, is it possible to
15 quantify the amount that was removed through
16 dredging and then placed somewhere else?
17 A. Net loss includes loss and gain.
18 And all we can provide is -- that I could
19 provide is an estimate as of a certain date
20 and time. You would have to go back to the
21 Corps records to find out then when the
22 material was actually placed, but say the
23 imagery is acquired one year, you have a
24 follow-up image the following year, all of a
25 sudden you have a nice new spoil beneficial

290
1 use of dredged material spoil placement
2 project that can be identified, the area can
3 be identified, but that will fluctuate
4 depending on the elevation that they put that
5 information in and local, what I call image
6 acquisition conditions, which would be
7 prevailing tides, winds and whatnot that will
8 affect the classified land area at that time.
9 Q. That's one of the things I was going
10 the talk to you about. When you're talking
11 about the imagery that's taken, are there
12 certain quality assurances that you would rely
13 upon to make sure that the prevailing winds at
14 the time the photographs were taken did not
15 push water into the marsh and obscure certain
16 areas that would not be covered with water if
17 it were, say, a low tide with low wind, low
18 prevailing wind type characteristics?
19 A. Actually, the whole purpose, if you
20 look at the linear regressions on figure --
21 pages 119 through 122, is to provide all
22 available data points and that will include
23 data points that are acquired at high and low
24 water levels and the purpose of the trim line
25 is to average that variation out over time and

291
1 provide the best, most robust estimate and
2 with air estimates of the land-water trends.
3 Q. Okay.
4 A. So it's actually trying to address
5 this. A lot of the old -- I'm going to opine
6 here a little bit. Expound a little slight
7 bit. But a lot of older land loss studies
8 were only based on one point in time and the
9 data was taken as is. So people didn't pay --
10 people say, well, we think it may have high
11 water, may have been low water, but nobody
12 really knew what the actual conditions were
13 unless they went out and gathered the
14 information. This includes all of the data
15 sets we have been discussing today, the
16 historical information.
17 Q. Right. Is there a margin of error
18 that people in your field build into those
19 data sets, the older data sets to take into
20 consideration the possibility that it was high
21 tide when that photo was taken or the wind was
22 pushing the water up over the marsh?
23 A. Most of the older photography was
24 acquired in the fall at vegetation senescence,
25 which is standard for that kind of vegetation

292
1 mapping, right before the vegetation died off
2 in the winter and to try to, under high
3 pressure, cloud-free conditions, to try and
4 minimize effects. Of course, that won't
5 account for all water level effects. But that
6 was just the standard tradition, was to take
7 this imagery in the fall, if possible, to make
8 that at least same season consistency over
9 decades.
10 Q. Okay. But my question was, is there
11 a margin of error that you guys utilize --
12 A. Well, personally I didn't --
13 Q. -- in your field? The people in
14 your field that are doing what you do for
15 evaluating that?
16 A. Yeah, they go ahead and evaluate.
17 There's a methodological error and
18 classification error, and what I am trying to
19 do now with the information I have got is
20 gather as many data points as possible so we
21 can actually see the spread with a consistent
22 methodology and data classification over time
23 so we have a much better idea of how this
24 information varies over time.
25 Q. And what was the margin of error
293
1 that you're talk about?
2 A. Oh, you'd actually go to the spread
3 -- If you go ahead and look, this will give
4 you the error estimates. If you go to look at
5 any of these layer regression graphs, it can
6 give you -- if you get the 294.9, you'll get
7 plus or minus 44 acres per year. That's
8 giving you the best fit estimate for the
9 data.
10 Q. Okay.
11 A. Each of those graphs has that.
12 Q. You, in your closing and general
13 statements, you indicate that you intend to
14 use photography and other materials cited in
15 your report or included in the Plaintiffs'
16 expert reports. Are there any other
17 photographs or materials that are not cited
18 that you intend to utilize in your report --
19 in your -- if you are called to testify at
20 trial?
21 MS. MILLER:
22 Objection.
23 MR. JOANEN:
24 What's the basis of your
25 objection?
294
1 MS. MILLER:
2 To the extent that it hasn't been
3 determined yet what the witness -- it
4 may be speculating.
5 THE WITNESS:
6 I would reserve --
7 MR. JOANEN:
8 Well, I'll clarify, to address
9 your objection, this report is written
10 on December 22nd, 2008.
12 Q. So your statement as of December
13 22nd, 2008 indicated that you would intend to
14 use the photography and other materials cited
15 in your report or included in Plaintiffs'
16 expert reports to support your testimony at
17 trial. Since that time have you determined
18 that you would use any other photography or
19 materials cited in your report --
20 A. No.
21 Q. -- if you were called to testify at
22 trial?
23 A. No, not that I am aware of. Of
24 course, I wouldn't find -- might find more to
25 help.

295
1 Q. Can you calculate the land loss that
2 was a result of dredging activity due to
3 maintenance of the MRGO?
4 A. No, the only information I can
5 calculate is the -- within the confines based
6 habitat configuration and spoil configuration
7 based on the 1978 data set.
8 Q. Can you calculate the land loss that
9 was a result of wave activity --
10 MS. MILLER:
11 Objection.
13 Q. -- within the MRGO?
14 MS. MILLER:
15 Objection to the question as to
16 vague as to the time frame.
17 THE WITNESS:
18 It can be calculated, but I
19 wouldn't want to do the work. You
20 have to take all the aerial
21 photography and photo rectify to get
22 the precision needed to accurately
23 identify shoreline expansion rates.
25 Q. And you haven't done that?
296
1 A. No. That's not part -- That's not
2 what I was asked to do.
3 Q. Have you or anyone on your team ever
4 tried to consider or quantify the amount of
5 land loss that was the result of the
6 maintenance of the MRGO?
7 A. Not --
8 MS. MILLER:
9 Objection.
11 Q. In the history of the MRGO?
12 A. Not to my recollection.
13 Q. Can you quantify, based upon the
14 habitats in the area of the levee system,
15 Reach 2 of the MRGO, what the frictional
16 coefficients would be of the water moving past
17 -- moving down the channel?
18 A. Again, the frictional coefficient is
19 not my area of expertise. No.
20 Q. Have you ever in your grid, 25 by 25
21 grid, taken into consideration the vegetation
22 that is on the levee of the MRGO, the Reach 2
23 levee of the MRGO hurricane protection project
24 levee?
25 MS. MILLER:
297
1 Objection.
2 THE WITNESS:
3 No, not -- If it's included in
4 the habitat data, but no.
6 Q. You hadn't specifically looked at
7 that?
8 A. No, no one has specifically asked me
9 to look at it.
10 Which figure are you at?
11 Q. I'm kind of looking at the maps real
12 quick just to make sure that I know what this
13 is.
14 In the first color print that's
15 entitled "Hurricane Katrina Mississippi River
16 Gulf Outlet assessment units", within the
17 polygon we have a green, which is going to be
18 the MRGO '78 spoil disposal area that runs
19 down the length, it looks like, of the MRGO
20 channel? Is that correct?
21 A. Yes.
22 Q. You also have the sole ridge, and
23 that -- is that the LaLoutre Ridge --
24 A. Yes.
25 Q. -- Delacroix Ridge? And the
298
1 remainder of that is going to be wetland
2 assessment units; correct?
3 A. Correct.
4 Q. And in most of your calculations,
5 you removed the Lake Borgne and Chandeleur
6 assessment area because they had nothing
7 really to do with habitat change?
8 A. Yes.
9 Q. When you have in here, going down to
10 the 2006 land water data, 2006 land is gray.
12 Q. Then you have the purple is 2006
13 water. Are you -- What's the purpose for
14 those differences in delineations?
15 A. That's the actual land-water
16 classification derived from the landsat
17 satellite imagery used for calculating loss
18 trends.
19 Q. A lot of that looks to be west of
20 the Mississippi.
21 A. Yes.
22 Q. Okay. Why would that only be
23 involved? Why would you only have those
24 colors west of the Mississippi?
25 A. The colors are actually east of the

299
1 Mississippi. It's just you have multiple
2 overlaid layers on top of it and I tried to
3 make it somewhat transparent so you could see
4 it. It's kind of confusing, but the -- the
5 overlaid -- the assessment areas are the areas
6 that were considered in the report. The other
7 areas include the rest of the Pontchartrain
8 basin and the Barataria basin that were
9 provided as data sources for all of the data
10 sets.
11 Q. Okay. So if you removed all of the
12 assessment area information and the only two
13 colors that appeared on this map were the 2006
14 land, 2006 water, the gray and the purple, you
15 would have gray and purple on the east bank of
16 the Mississippi?
17 A. Yes.
18 Q. The next colored paragraph, the next
19 colored page is your '56 habitats of the MRGO
20 assessment units?
22 Q. This information is strictly what
23 you recovered from the old data set; correct?
24 A. Correct.
25 Q. And basically you're putting colors
300
1 to it I guess in assimilating those colors to
2 your assessment areas that you have in the
3 previous unit; correct?
4 A. Well, actually the '56 habitat data,
5 this is what it looked like in -- I mean, the
6 color were assigned back in 1988. So none of
7 that has changed. I mean, this is the
8 original thing.
9 Q. Okay. Is this -- If I were to go
10 look at the habitat data, would I find this
11 exact same thing?
13 Q. Okay. And so you have done nothing
14 to change it in any way or alter it?
15 A. No. Let me specify, that depends if
16 you using a software, if you're using RGIS or
17 URDOS Imagine, it should read -- if you're
18 using a proper geographic information systems
19 software, it will read that file up and
20 display it properly.
21 Q. Okay. Going to your assessment
22 units in the '78 habitat is the next page.
23 Was this also the same data set that you
24 referenced earlier, the '78?
25 A. Yes.

301
1 Q. And again, if you were using the
2 proper software program and you went to this
3 data set, you would find this exact same
4 information; correct?
5 A. Yes.
6 Q. In your '88 habitat, is that the
7 same? Would your answer be the same to the
8 questions regarding the two prior data sets?
9 A. Yes.
10 Q. And so if in 1989 you wanted to
11 assess the habitat change from '56 to '78 to
12 '88, you could do -- when I use the term "an
13 overlay" and that would give you an image of
14 the change? Correct?
15 A. No, you -- Well, technically you
16 wouldn't be assessing 1989 change. You would
17 have to develop a new 1989 data set for that
18 point in time to assess change between 1988
19 and 1989.
20 Q. Right. My question maybe -- I was
21 picking 1989 because it was after '88. So
22 whenever '88 was concluded, then you have your
23 '88 habitats. The minute this report was
24 published, you could then take these three,
25 put them together, and you could assess, based
302
1 upon this, the habitat changes per the
2 information included in these reports.
3 Correct?
4 A. Yes.
5 Q. The next one is your MRGO assessment
6 unit, 2006 land and water data with 2001 marsh
7 types. Is this map the same map that would be
8 included in your first one, which was if you
9 take away your MRGO assessment units and you
10 just have the land data and the water data,
11 would that be what you're referring to here as
12 your 2006 land and water data?
13 A. Yes, but the data via GIS was an
14 operation of combining the 2001 marsh
15 community types which was developed by Greg
16 Linscomb and it merged the water and the marsh
17 types to create a tertiary data set that --
18 Q. You getting a little ahead of me.
19 A. Okay.
20 Q. I guess the first data set would be
21 what we have here originally if you remove
22 your assessment units?
23 A. Yes.
24 Q. And then with that, you combine the
25 2001 marsh types; correct?
303
1 A. Yes.
2 Q. And I am assuming that's a different
3 --
4 A. It's a different one.
5 Q. -- program. And then through the
6 wonders of your science you can combine that
7 and you come up with a map like this?
8 A. Yes.
9 Q. All right. When you come up with a
10 map like this, are you making any
11 calculations? Are you making any assessments
12 regarding the two data sets and merging them
13 together to come up with your tertiary amount,
14 or are you just operating the computer that
15 combines them and then the output is this?
16 A. You actually have to intelligently
17 combine them, because if you just give it to
18 the computer, it's going to make a fairly
19 complicated output. So you have to look at
20 how you're combining the data and then you
21 have to develop a color scheme and a table, a
22 color -- the appearance, and that will provide
23 the output data set.
24 Q. Okay. In the polygon, when we look
25 at the marsh types, does that include the
304
1 types of marsh types that would be the 2006
2 land-water data merged with 2001 marsh type
3 zones? Are those colors indicated in the
4 polygon?
5 A. Yes. If you actually -- If you look
6 at the legend at the bottom of figure 031, it
7 says "2006 land-water data merged with 2001
8 marsh types". It lists the types of
9 information. So you would see the lighter
10 color, that kind of yellowish green, it's 2006
11 land merged with 2001 fresh marsh. So that's
12 your fresh marsh areas.
13 Q. Do you see in the polygon whether
14 there is any fresh marsh zone?
15 A. It's hard to tell with this scale.
16 I would probably have to run area statistics
17 on it. But I -- I'd prefer to go back and
18 check it, but just from a casual glance, no.
19 Q. And really this -- I am trying to
20 get your description of the colors more than
21 anything else. The next one down is your 2001
22 intermediate marsh zone.
24 Q. Are there any colors of that shade
25 of green within the polygon and, if so, which
305
1 ones are they?
2 A. I don't think so.
3 Q. Okay.
4 A. Except possibly around the ridges,
5 but you can't tell because of the overlay of
6 the ridge, red ridge polygons.
7 Q. Okay. And then we have 2001
8 brackish marsh zone. And for -- When I was
9 looking at this, I was trying to figure out
10 whether there was a different color between
11 the brackish marsh zone and the assessment
12 area which would be the MRGO spoil disposal
13 area, which I am looking at -- I look at it as
14 running down the length of the MRGO.
15 A. That would actually be under the
16 2001 data. You can't see it because of all
17 the information overlaid, but I think it would
18 be the brown "Other land" category from the
19 2001 marsh characterization.
20 Q. The brown?
21 A. Yeah. It's kind of hard to see, but
22 you're going to have some of that.
23 Q. The other land zone?
24 A. Yeah, it's where the spoil, some of
25 the spoil. It's kind of hard to see. It

306
1 might be -- You're going to have a lot of
2 brackish marsh in there. But it's just hard
3 to see. You need to pull a figure up and blow
4 it up. You can't tell the scale at this
5 resolution.
6 Q. If you testify at trial, are you
7 going to utilize your hard data to tell the
8 Judge how much brackish marsh zone, 2001
9 brackish marsh zone is within the polygon?
10 A. If that's required, I can.
11 Q. So that information isn't specified
12 in your report. That's something -- That's
13 additional work that you would have to do in
14 interpreting your spreadsheets?
15 A. Yes. But I did provide the data
16 sets.
17 Q. The next color down is the 2001
18 saline marsh zone. Is any of that saline
19 marsh zone indicated in your polygon?
20 A. Yes. You can -- Not my poly --
21 Dale's -- Yes.
22 Q. The polygon that we have on this
23 map.
24 A. Yes.
25 Q. In the polygon?
307
1 A. Yes, in the poly- -- Yes, you can
2 see it clearly.
3 Q. Well, --
4 A. The darker -- Right here.
5 (indicating). Right here can you see it.
6 Q. Right. I would say that appears to
7 be on the lower end of the lobe of -- the
8 southern lobe of the -- the eastern lobe of
9 Lake Borgne --
10 A. Correct.
11 Q. -- running southward, southeastward
12 along the MRGO, but north of the MRGO and then
13 also below the MRGO, or south of the MRGO and
14 southeast of the LaLoutre Ridge.
15 A. You are correct.
16 Q. And then your 2001 swamp zone, is
17 that indicated within the polygon?
18 A. I doubt -- You know, I don't see
19 anything here. Again, I would like to check
20 the data set, but I don't think you're going
21 to find any swamp in that area.
22 Q. If you look at this and you evaluate
23 the area of the golden -- only the area of the
24 golden triangle, which is the area of land
25 north of the MRGO going up to the Gulf
308
1 Intracoastal Waterway and running north, that
2 golden triangle area, what would you describe
3 the type of marsh zone in that area?
4 A. Brackish and saline.
5 Q. Okay. And then the area from Fort
6 Beauregard up to Proctor's Point and then back
7 down again for the southern -- the eastern
8 lobe of MRGO, what would you describe that
9 marsh zone as being?
10 A. It appears to be saline marsh. I
11 would like to -- Yeah, the dark green.
12 Q. Now, I can't really see this very
13 well, but it looks like there's some letters
14 that are in the area south of the MRGO.
15 A. That would be the Delacroix marsh
16 east designation and the Delacroix marsh
17 west. The units were actually superimposed.
18 We need to blow it up in Adobe Acrobat or
19 something so you can see it. It's just the
20 name of my assessment units.
21 Q. Okay. The reason I am asking this
22 is because I can't read what that word is.
23 It's white, it's just north of the purple.
24 You see where the purple, where the --
25 A. Point out which one you're looking

309
1 at.
2 Q. Go back.
3 A. Okay. Oh, I'm sorry. Which one?
4 Q. The 2001 marsh types map.
5 A. Yeah. Yeah. Right here.
6 Q. You see how you have the purple
7 right here running along?
8 A. Yes.
9 Q. There's white lettering right there,
10 looks like it's a word.
11 A. It's probably the Chalmette
12 wetland. I would have to go ahead and blow it
13 up again. A lot of the stuff, we just blew it
14 up on a computer in Acrobat. You can read it.
15 Q. The reason I am asking that, because
16 when we get to the next one, which is your T
17 '32 sheet, you also have the word "Chalmette
18 wetland" and you also have the word "central
19 wetlands". And so I was trying to figure out
20 what term you were using on the 2001 --
21 A. Oh, this central wetlands is
22 actually from the -- It's just left over from
23 the transference of the figure. I didn't put
24 that on there. That's from the Fitzgerald
25 report.

310
1 Q. The area on your 2001 marsh types,
2 it talks about, where the white lettering is
3 -- how would you -- what marsh zone would you
4 describe?
5 A. Brackish. It looks to be for the
6 most part.
7 Q. Do you see anywhere within the
8 polygon that there is a swamp zone?
9 A. No, but on the 2001 data set, this
10 was developed by Chabrect, it's a generalized
11 marsh type zone. It is not an NWI habitat
12 derivative of marsh types or habitat types.
13 So it's a much more generalized interpretation
14 of marsh and swamp zones and isn't specified
15 to the detail of the National Wetlands
16 Inventory detail.
17 Q. So how does that help us in
18 determining what the type of vegetation is in
19 this area?
20 A. It gives you a general idea of the
21 marsh types within the area. The reason this
22 data set was developed was primarily for
23 planning by the Corps of Engineers because
24 there was no habitat data upsets -- updates,
25 so they were asking for some type of products

311
1 that could be used to assess current
2 conditions.
3 Q. So how would you rate this from an
4 accuracy scale as to what the accurate
5 vegetation is in the polygon?
6 A. This is as good as what was used in
7 the Fitzgerald report. They used the same
8 data, the 2001 marsh community types for some
9 of their information, plus, you know, the same
10 with the Oneal, '68 Chabrect.
11 Q. So if I were to look at this,
12 though, am I saying that there is no swamp in
13 the entire polygon?
14 A. Based on the Chabrect
15 classification, no.
16 Q. If you were looking at this and you
17 wanted to see the degree of accuracy, could
18 you send somebody out and go verify that the
19 marsh type zones are accurately reflected in
20 this, or if you sent someone out there, would
21 you feel that there would be a better picture
22 of what was actually out there?
23 A. I think it would help to have actual
24 field investigation, but all of these zones
25 were developed off helicopter trans sets

312
1 across coastal Louisiana by some of the top
2 experts in marsh classification. So as far as
3 a general guide, they're probably pretty good.
4 Q. And who produced this tertiary
5 output?
6 A. I did.
7 Q. Okay. When you came up with this,
8 did you look at any photographs to evaluate
9 the accuracy of the information or did you
10 simply take that 2001 marsh type data as it
11 was and then just combine it, with your skill
12 to get them combine accurately, with the
13 colors and all?
14 A. Yes, the actual marsh type
15 information was corrected and verified by I
16 think Greg Linscomb and it was actually
17 produced at National Wetlands Research Center
18 as a joint project with Greg Linscomb. The
19 output product's available for downloading on
20 the web. So I didn't have anything to do with
21 the accuracy assessment of it. I am just
22 utilizing the information.
23 Q. You mentioned that our experts had
24 used that information as well.

313
1 Q. Do you know whether they -- Do you
2 know whether they went out and evaluated the
3 -- Hang on a second.
5 off the record.)
7 Q. Would it be your opinion that if our
8 experts supplemented the information they had
9 in 2001 marsh type zone, would their
10 information be more accurate than the
11 information contained in 2001 marsh type zone?
12 MS. MILLER:
13 Objection.
14 THE WITNESS:
15 I can't answer that. You would
16 have to go to a wetland vegetation
17 expert.
19 Q. If they supplemented that by looking
20 at photographs and evaluating what was
21 actually out there through the photographs, do
22 you think their information would be more
23 accurate than that which is in 2001?
24 MS. MILLER:
25 Objection.
314
1 THE WITNESS:
2 I can't comment. I can't comment
3 for Chabrect's expertise and Greg
4 Linscomb's expertise.
6 Q. Turning the page to the '56 habitat
7 data with the '32 T sheet, you have a study
8 which is the T -- which is the '32 T sheet at
9 your disposal that you utilized. Correct?
10 A. Yes.
11 Q. And are you making any changes to
12 the information that's contained in the '32 T
13 sheet to combine it with the '56 habitat data?
14 A. The only changes that we did was to
15 take the actual file from the PDF that was
16 provided, rectify it so that we could -- and
17 rectify it so we could display it properly
18 with the 1956 habitat data.
19 Q. We have already established the '56
20 habitat data wasn't altered by you; correct?
21 A. No.
22 Q. When you put these together, is the
23 '56 on top or is the '32 on top?
24 A. The '56 is on the bottom. The '32
25 is on top. But I used a transparency option

315
1 so you could see both of them merged
2 together. Not merged, but displayed together.
3 Q. And the transparency, I see if you
4 look at it, there's a square that goes
5 around.
6 A. Where are you -- Point it out to me.
7 Q. (Indicating).
8 A. Sure. Okay.
9 Q. Okay. Is that the T '32 sheet or
10 the '32 T sheet?
11 A. It's the figure that was provided to
12 us on a PDF that was -- I'd assume was taken
13 from a '32 sheet since it's listed in the
14 upper right of the figure.
15 Q. In the orange part, which, according
16 to the '56 habitat data, is going to be swamp
17 -- correct?
18 A. Correct.
19 Q. -- I can't tell the difference
20 here. Would you be saying that that is upland
21 trees that is in that orange, or is that going
22 to be cypress swamp?
23 A. The orange color is cypress -- I
24 mean, is swamp. It may include -- In that
25 area it was probably predominantly cypress.

316
1 It may include some of the other categories
2 that I mentioned earlier.
3 Q. Okay. I am just having trouble
4 identifying the circles.
5 A. It's hard to look at. Yeah, it's
6 hard to look at.
7 Q. Then when you move up into a little
8 north of that, the browner areas, --
10 Q. -- which is just south of that blue
11 line that meanders through there, what -- is
12 that fresh marsh or is that non-fresh marsh?
13 A. That would be fresh marsh on the
14 habitat data.
15 Q. Now, I also see it looks like
16 there's circles in there, too, so it looks
17 like there would be cypress swamp in there as
18 well; correct?
19 A. Excuse me. The circles?
20 Q. Right in here (indicating). Is
21 there a change in the '32 T sheet indication
22 of cypress swamp between the '58 habitat data
23 of swamp and --
24 A. Oh, I see. Yes, there is. The 1932
25 T sheet is showing a more extensive extent of

317
1 swamp.
2 Q. And then north of your meandering
3 blue line you'll have, according to '32 T
4 sheet, marsh or is that marsh with scattered
5 cypress trees?
6 A. You would have some marsh with
7 scattered cypress trees. And then it grades
8 into marsh by Lake Borgne.
9 Q. And so am I to understand that
10 according to the information that you have
11 through the T '32 sheet and the '56 habitat
12 data, that there was no cypress swamp in the
13 golden triangle unit up to the Proctor Point
14 wetland?
15 A. Not in the 1956 habitat data. Well,
16 actually right on the boundary before the MRGO
17 was dredged there was two small areas of
18 swamp, but it's hard to see. It's these
19 little circles right here (indicating).
20 MS. MILLER:
21 I'm sorry, where?
22 THE WITNESS:
23 Right here (indicating).
24 MS. MILLER:
25 Oh, okay.

318
1 THE WITNESS:
2 This little island.
3 MS. MILLER:
4 This is --
5 THE WITNESS:
6 This is on the '56 data.
7 MS. MILLER:
8 And that's swamp or fresh marsh?
9 THE WITNESS:
10 Swamp with -- with some
11 freshwater that is grading into
12 non-fresh.
14 Q. And then we go to the lower
15 right-hand side, you have one point that's the
16 LaLoutre Ridge?
18 Q. Actually a forest there.
20 Q. Do you know -- I don't see where you
21 can tell what kind of -- on '32 if it
22 indicates that there's any type of trees
23 there.
24 A. Now, the '32 information that was
25 provided is only this square that's on top of

319
1 the '56 data.
2 Q. What would be the difference between
3 forest and swamp according to the habitat
4 data, different types of trees?
5 A. The forest would be drained wetland
6 forest. Like I say, it's not inundated except
7 during the possible river flood where it would
8 be bottom wave force. You would have a lower
9 high stage river flood or during a surge
10 event. In other words, it's dry most -- you
11 know, most of the time unless you have some
12 kind of event.
13 Q. Do you know if it would be different
14 types of trees?
15 A. Oh, yeah. I mean, it's going to be
16 bottom land hardwoods, oaks. Swamp maple.
17 Not swamp maple. Maple trees, other sorts.
18 Hackberries.
19 Q. Now, the next page is the 1930 T
20 sheet tree area.
22 Q. On this one it doesn't look like
23 there is a clearly defined square like you do
24 see in the '32 T sheet. Is there a different
25 type of configuration?
320
1 A. This is actual vector information
2 that was provided later. This was the first
3 information I had, was this -- this image
4 (indicating). And then the vector information
5 was provided in one of the expert reports, I
6 guess in the Fitzgerald report that actually
7 had that information so I could display it in
8 a prettier form, I guess a more easily
9 understandable format than the T sheet.
10 Q. And what is the difference between
11 the 1930 T sheet tree area and the 1932 T
12 sheet?
13 A. You'll have to ask your experts.
14 They provided the data.
15 Q. So my understanding is for this area
16 you took the 1930 T sheet tree area --
18 Q. -- and superimposed that on what you
19 already had as the 1936 habitat data, and then
20 what you get is what you get?
21 A. Yes. I didn't try to manipulate it
22 in any manner except to display it.
23 Q. Now, your last color document, you
24 have '56 to 2006 trends.

321
1 Q. Dealing with just the polygon area,
2 we see we do have the ridge assessment units,
3 which is the LaLoutre Ridge. This will only
4 deal with land loss trends; is that correct?
5 There's no habitat changes?
6 A. I'm sorry, it's land loss and gain
7 trends. Yes.
8 Q. So this would be a program where you
9 just run and you look at the grid and see if
10 you got a value of water or got a value of
11 land, whatever it would be?
12 A. It's actually a little more complex
13 than that, but that's close enough.
14 Q. Well, the reason I made it that
15 simple is because in the bottom you have --
16 A. Yeah.
17 Q. -- 2005 land, 2005 water.
18 A. Yeah. It's basically an overlay of
19 the trend data sets over time.
20 Q. When I look at this, in the polygon,
21 I see that there is a land gain where the
22 spoil bank would be; correct?
23 A. Actually, the green shading is
24 probably overlaying some of the green that
25 would be land gain in my file, the green that

322
1 I use for the '78 disposal area. So I
2 apologize, and that is going to be kind of
3 hard to see it, but yes, you would have green
4 land gain occurring in those areas.
5 Q. I want to ask you, if you have an
6 area that doesn't have a MRGO channel in it
7 and we know from the photographs that there
8 was land there, and then you dig out the
9 channel, so obviously you're going to have
10 area where there is no land, and you throw
11 soil on top of soil, how do you have land gain
12 if you are just putting soil on top of soil?
13 A. Because you also filled in a large
14 number of ponds that are actually outlined in
15 the area table that -- where you actually
16 infilled a fairly significant amount of ponds.
17 Q. So if we calculate the footprint of
18 the spoil bank prior to it becoming the spoil
19 bank, you're able to calculate the percentage
20 of land and water within that footprint?
21 A. Yes. That's included -- There's a
22 table. Table 3, page 16.
23 Q. Okay.
24 A. See, in the channel area of the
25 first category, you lost 2,718 acres of

323
1 water. That was actually conversion to land.
2 I don't know if that -- You know.
3 Q. Without -- But you're able to --
4 Just so I can understand, when you take the
5 footprint, whatever it's going to be before
6 there is actually the dredged material put on
7 there, you're able to calculate within that
8 footprint, and let's just say from an aerial
9 view it's a rectangle, you can calculate the
10 percentage of land to water or the acreage of
11 land to water?
12 A. It's a summary of acreage and then
13 you can calculate the percentages from the
14 acreage sums.
15 Q. Was that done? Was there a
16 calculation done --
17 A. That was done in this table.
18 Q. And so do you know as you sit here
19 what this percentage of land to water was in
20 the spoil channel footprint?
21 A. I'd have to go through and calculate
22 percentages, but it's -- it's -- I mean, you
23 have got the raw numbers there.
24 Q. And where are those located?
25 A. Here in the table. You --

324
1 Q. So when I ask you the question with
2 the 2000 trends in the last one and we show
3 that there is land gain from '56 to '78 along
4 the whole spoil bank, you're not saying with
5 this that there is 100 percent land gain?
6 You're saying there is just land gain there?
7 A. There is partial land gain where
8 ponds were infilled by the spoil disposal --
9 the dispersal process.
10 Q. And it would be your opinion that
11 this figure on figure 11 would accurately
12 depict the amount of land gain, the amount of
13 partial land gain?
14 A. What I could calculate with the
15 information I had. Again, keep in mind that's
16 based on the 1978 footprint. It's not based
17 on immediate -- immediate post-construction
18 footprint.
19 Q. When you fill in those ponds with
20 the soil, does it allow for additional growth
21 of habitat?
22 A. I would assume that you had
23 additional growth of habitat from the
24 shrub/scrub. If they're filled to a
25 sufficient elevation, it should.

325
1 Q. Okay. Based upon this 1956 to 2006
2 trends analysis, can you quantify how much
3 land was lost in the polygon?
4 A. It's actually under the area tables
5 in the back. Either through subtraction or we
6 -- it would have -- It's what I showed you
7 earlier where it actually had between the
8 periods, it showed you the numbers. It's in
9 the appendices somewhere.
10 Q. And how was this figure put
11 together? What did you do?
12 A. I digitized it, heads-up digitized
13 it over the 1978 habitat data.
14 Q. And so you utilized the '78 data
15 points?
16 A. As a base, because I wanted to be
17 consistent within my analysis and using the
18 same data sets over time.
19 Q. And then with that you overlaid the
20 '90, 2001, and 2004 and 2006 --
21 A. Yes.
22 Q. -- satellite imagery?
23 A. Actually, the regression figures
24 show the trends for that particular area.
25 From the 1985 to 2006 period.

326
1 Q. In your information that you're
2 providing through your expert report and also
3 that you are providing to other experts, are
4 you opining as to the causes of habitat
5 change?
6 MS. MILLER:
7 Objection.
9 Q. In the polygon.
10 A. The only area where I was completely
11 sure it was within the disposal area and '78
12 excavation area. After that, it gets into
13 what we described earlier as for multiple
14 causes of probable land loss.
15 Q. Okay. Things that you would really
16 put in as indirect causes as opposed to direct
17 causes as you defined in the first page of
18 your report?
19 A. The first page except for the
20 hurricane effects where you have direct
21 episodic impacts, direct episodic land loss.
22 Q. When you provide your information to
23 -- It's kind of one thing that's -- How to
24 ask this question. I don't mean to demean
25 what you do in any way.
327
1 A. Bless you.
2 Q. How did you equate what you're going
3 the provide to Dr. Westerink? Were you
4 providing some type of analytical reasoning to
5 give to him?
6 A. I was providing a data source for
7 him to use in his modeling effort. That was
8 the extent of it, you know, in my opinion what
9 I was providing.
10 Q. Okay. By "this", and again I am not
11 trying to minimize what you do, we talked
12 earlier about you taking things off the shelf,
13 the data sources.
14 A. Yeah.
15 Q. For the things that you provided to
16 Dr. Westerink, was that basically what you
17 were doing? You knew what to grab so you went
18 to the proper shelf, grabbed the proper thing
19 and gave it to him, making sure he got the
20 right things?
21 A. Did what I had a request for, the
22 oldest data set I had for, you know,
23 pre-MRGO. That was the only data set I had.
24 Yes. It's all off the shelf. This data set
25 was built 20 years ago. Yeah.

328
1 Q. Did you do any calculations of the
2 grids, of the contents of the grid to
3 determine what the actual type of vegetation
4 was?
5 A. Only in my report.
6 MS. MILLER:
7 Objection.
8 MR. JOANEN:
9 Could we take a quick break?
10 VIDEO OPERATOR:
11 Off the record.
13 off the record.)
14 VIDEO OPERATOR:
17 Q. Mr. Barras, I just want to cover a
18 few issues very quickly and I want you to know
19 that I ask this of all the witnesses, that I
20 am kind of entitled to, but I also have to.
22 Q. And don't take any offense to this.
23 I'm not implying anything untoward. But have
24 you ever been convicted of a felony before?
25 A. No.

329
1 Q. Have you ever been arrested of a
2 crime that involved fraud?
3 A. No.
4 Q. Do you anticipate as you sit here
5 today that you will be doing any additional
6 calculations or producing any additional or
7 supplemental reports to either substantiate
8 your own report or to opine as to the
9 correctness or incorrectness of any of the
10 Plaintiffs' expert reports?
11 A. I would assume that depends upon
12 what the Department of Justice requires of
13 me.
14 Q. But as you sit here now, you have
15 not been --
16 A. No.
17 Q. -- requested to do that?
18 A. No.
19 MR. JOANEN:
20 I have no other questions.
21 THE WITNESS:
22 All right.
23 VIDEO OPERATOR:
24 Off the record.
25 * * *

330
1
2 WITNESS'S CERTIFICATE
3
4 I, JOHN ASHLEY BARRAS, read or have
5 had the preceding testimony read to me, and
6 hereby certify that it is a true and correct
7 transcription of my testimony, with the
8 exception of any attached corrections or
9 changes.
10
11
_____________________
12 (Witness' Signature)
13 ____________
DATE SIGNED
14
15 DEPONENT PLEASE INITIAL ONE:
16
_____ Read with no corrections
17
18 _____ Read and correction sheet attached
19
20
DATE TAKEN: FEBRUARY 6, 2009
21
22
23
24
25

331
1
2 REPORTER'S CERTIFICATE
3
4 I, ROGER D. JOHNS, RMR, RDR, CRR,
5 Certified Court Reporter, do hereby certify
6 that the above-named witness, after having
7 been first duly sworn by me to testify to the
8 truth, did testify as hereinabove set forth;
9 that the testimony was reported by me in
10 shorthand and transcribed under my personal
11 direction and supervision, and is a true and
12 correct transcript, to the best of my ability
13 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 outcome
16 of this matter.
17
18
19
20 ROGER D. JOHNS
21 CERTIFIED COURT REPORTER
22 STATE OF LOUISIANA
23
24
25

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165:13 197:19 274:23 276:23 CERTIFICATE 239:20 240:3,21 234:17 246:20
234:18 235:6 279:17 285:10 330:2 331:2 257:4 259:21 266:14 284:25
252:18 253:8 causes 43:13 73:14 Certified 3:8 4:19 260:3,6 266:9 285:8 288:13,21
272:24 75:8 203:18,25 331:5,21 280:10 286:25 288:21 296:17
canals 271:14 204:4 272:14,19 certify 330:6 331:5 298:7 300:14 297:20 322:6,9,24
272:22 274:12 276:13 Chabrect 310:10 301:11,14,16,18 323:20
capabilities 211:12 277:11 326:4,14 311:10,14 316:21 326:5 characteristic
270:1 326:16,17 Chabrect's 314:3 changed 11:17 27:6 42:20
capability 36:13 causing 171:12 Chalmette 104:21 28:6 149:16 characteristics
270:13 272:10 274:2 162:9,13 163:25 157:16 169:24 290:18
capable 64:10 277:6,6 165:14 229:16 201:14 222:14,16 characterization
career 21:13 cautioned 80:9 243:22,23 244:7 257:2 300:7 152:10 305:19
careful 216:10 cautious 199:16 265:10 267:22 changes 27:13 42:5 characterizations
Carlton 191:14,16 CC 55:7 268:23 275:12,13 42:8,8,19,21,22 153:8,10
case 6:6 12:19 19:9 CD 19:23,23 275:21,25 280:21 42:23 64:19 85:8 characterize
60:25 116:8 Celia 218:9 281:9,10,23 282:8 87:24 90:2 102:9 154:19
287:23 cell 63:25 98:22,25 282:14 284:4 105:16 113:21 chart 141:3 247:4
casual 304:18 101:10 105:13 286:13 309:11,17 146:3 147:7 251:6 262:16
catch 46:10 265:19 109:13 chance 12:4 29:5 149:12,20 160:24 charts 61:20
categories 31:4 center 59:3 283:1 86:20,24 91:16 166:11 167:24,24 176:19 177:23
60:12 99:21 100:8 312:17 130:10 142:18 173:17 175:25 227:25 250:3
151:10,12,13 central 162:2,6,15 237:13 177:1,12 178:18 cheap 269:4
163:2,2 179:10 162:19 170:16 Chandeleur 38:2,8 178:23 179:14 check 148:4 158:11
220:13 222:6 179:23 202:25 155:15 196:4 181:24 183:4 187:21 257:20
224:8 241:5 243:9,11,13,17 211:25 256:1 184:16,18,19 304:18 307:19
265:12 316:1 244:12 246:18 298:5 195:25 197:25 checked 148:7

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214:24 233:2 228:22 230:11 97:7 101:25 colors 131:19 communicating

checking 148:3,3 245:1 260:2 115:15 116:22 265:14 298:24,25 264:9
216:3 243:6 280:20 290:8 127:1 157:11 299:13,25 300:1 communication
checks 215:10 classifies 179:18 189:6 199:8 304:3,20,24 20:22 33:21
Chenier 82:17 classify 217:1 203:10 248:25 312:13 communications
child 21:9 44:13 classifying 153:14 312:1 combination 185:5 12:23 18:10 33:13
circles 316:4,16,19 153:16 coastline 52:18 281:17 33:16 116:7
317:19 clean 244:21 88:18,19,20 89:2 combinations communities
circulation 114:12 cleaner 187:8 89:13 96:14 271:16
cite 164:2 281:4 clear 66:1 121:17 coastwide 36:9 combine 146:23 community 302:15
cited 245:22,24 134:25 145:24 88:17 89:2,5,13 282:13 302:24 311:8
293:14,17 294:14 146:1,2 268:4 97:10 200:24 303:6,17 312:11 company 122:16
294:19 283:22 code 95:10 96:12 312:12 314:13 comparable 220:13
Civil 1:7 2:18 4:7 clearly 8:15 232:14 96:13 147:5 combines 303:15 compare 149:9
clarification 241:3 268:25 coded 151:1,2 combining 302:14 266:1
130:16 158:1 284:14 307:2 152:8 303:20 compared 284:12
223:24 319:23 codes 96:15 97:5,14 come 34:11 50:4 comparing 155:21
clarified 281:22 click 99:1 107:8 101:7 236:23,24 64:4 72:9,12 80:3 256:6
283:2 clicked 106:24 236:25 95:8 98:23 111:1 comparison 155:7
clarify 16:19 125:6 climatological coding 30:7 31:9 123:22 124:17 210:8 213:25
183:18 294:8 249:10 131:21 220:10,20 132:20 156:3,6 215:9
clarifying 67:22 clipped 48:18 225:16 196:12 199:12 comparisons 175:9
CLARK 2:12 49:11 52:15 COE 161:22,22 269:5 281:17 compensation 22:5
class 95:18 227:1,4 104:12 105:9 coefficient 120:7,7 303:7,9,13 compet 202:15
227:5 239:25 clipping 49:9 120:12,15 150:6,8 comes 96:1 98:9 competing 202:16
240:1,6,7,20,22 close 217:21 269:3 270:13 296:18 269:18 complete 17:13,15
240:24,25 241:7 281:20 321:13 coefficients 296:16 comfortable 18:13 19:24 81:14
242:15 255:18 closely 87:18 collaborating 173:16 184:13,15 244:10,15
256:16 266:3 closer 281:23 170:5 184:18 255:1 completely 20:25
classes 220:12 closing 293:12 colleagues 141:1,15 274:10 213:24 214:11
240:5,10 255:20 cloud-free 292:3 collecting 32:13 coming 46:11,12 276:1 326:10
255:21 coast 29:4 30:2 college 24:13,17 75:15,20 214:15 complex 31:9 79:2
classification 58:11 59:7 77:11,18 colloquially 37:7 commencement 96:15 97:14
63:24 64:3 95:21 78:12 80:14 82:15 colonization 46:17 321:12
106:19 107:14,17 87:25 126:1,1,15 223:21 comment 182:9 complexes 261:23
107:18,24,25 156:14 186:21 colonized 265:23 201:10 208:17 complicated
193:6,7 216:11 188:14,17,21,24 color 98:18,21 99:4 266:24 267:1,12 167:22 271:25
218:25 219:7 192:2,18 278:4 132:10,19,20 314:2,2 273:25 274:13
222:2 223:12 279:23 280:24 133:4 163:15 commenting 303:19
230:13 265:1 281:5 222:2 229:15 205:11 component 62:15
292:18,22 298:16 coastal 15:9 24:25 265:18 297:14 comments 221:19 187:14
311:15 312:2 27:2 48:11,15 300:6 303:21,22 COMMITTEE 2:6 components 155:14
classifications 59:4 69:23 72:5 304:10 305:10 commodity 101:25 268:3
23:15 61:22 87:5 73:18,23 74:3,8 306:17 315:23 217:9 composed 162:8,9
95:12 99:18 77:20 80:16 83:16 320:23 common 228:2 composition 187:8
102:25 217:24 88:7,16,16,23 colored 164:23 commonly 227:24 compress 202:19
classified 69:3 89:8 96:18,22 299:18,19 281:15 comprise 148:6

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281:14 141:25 234:18 243:1 116:6,10 118:24 211:9 223:4

comprised 66:10 conflicting 245:21 248:16 267:2 119:1 120:17 242:16,24 243:4
comprises 203:9 confounding 173:2 consultant 146:17 122:24 127:22 251:8,19 253:18
computer 20:10,13 confuse 223:23 consultants 96:22 128:8 288:7 289:21
28:8 32:24 60:1 confused 64:8 consulting 70:10 conversations 310:23
62:19 63:6 101:8 191:11 220:6 consuming 36:8 53:22 54:16 56:22 correct 13:5 14:5
108:4 109:9,14 247:13 281:7 contacted 13:12,19 57:11 112:13,17 23:3 24:14 35:24
144:11,16,22 confusing 168:2 13:22 14:4 40:2 116:5 127:10 38:15,18 39:14
145:3,22 146:4,12 188:20 231:1 56:18 74:5 87:12 128:13,14 129:12 41:3,13 50:25
147:4,5,20 148:24 299:4 contacting 14:13 129:20 142:24 51:14 52:19,20
149:3 224:15 confusion 9:22 15:7 143:4 56:6,17 61:17
236:17 303:14,18 223:9 contain 80:10 conversion 141:3 63:22 64:7 66:7
309:14 conjunction 58:17 102:21 243:25 172:2 197:9 66:11 68:24 78:21
computer-genera... 76:9 contained 17:19 231:24 242:14 79:22 81:22 86:11
59:24 conservative 21:19 91:22 244:9 253:21 90:23 94:17 99:7
concerned 266:5 182:21 140:17 142:12 271:19,23,24 103:23 104:5,8,22
concerning 7:22 consider 77:9 150:20 166:4 272:14 323:1 104:25 105:14
13:14 111:7 120:19 187:16 197:1,2 convert 97:5,10 111:8 113:19,24
concluded 301:22 218:4 260:5 296:4 313:11 314:12 214:19 118:20,21 119:8
conclusion 72:9,11 consideration contains 53:12 converted 26:17 124:2,2,25 130:24
72:13 80:3 156:6 103:8 107:19 140:5 162:17 97:17 214:11 131:18 132:4
conclusions 32:19 291:20 296:21 175:9 255:16 268:18 139:10 148:18,20
43:2 73:4 74:19 considered 57:2,5 contents 263:8 converting 231:19 151:21 167:16
156:3 71:3 148:16 328:2 253:4 168:13,15 170:24
conclusive 126:20 178:19 222:7 contiguous 200:25 converts 101:5,9 177:10,24 178:20
conditions 166:17 262:5 270:17 continue 156:15 convicted 328:24 178:21 179:1
175:10 234:14,23 272:5 299:6 CONTINUED 3:2 cool 121:18 182:25 183:1,15
235:3,3 290:6 considering 133:21 continuous 123:2 coordinate 22:16 184:4 187:25
291:12 292:3 146:6 181:24 continuously 252:4 copies 16:13 17:22 188:4 192:22
311:2 consist 29:1 187:13 contract 122:9,9 17:24 18:9,16,20 198:3,19 200:11
conducted 29:12 consistency 115:14 contractor 122:11 22:24,25 23:4,13 203:13 209:10
conference 46:14 292:8 contractors 41:3,6 23:19,19 174:17 212:25 221:6
54:1,21 55:1,4,10 consistent 220:21 contributing 75:6 copy 11:24 12:1 224:20 225:9
55:17 56:17 121:7 268:7 292:21 contribution 73:23 19:7 20:7,16 230:23 241:9
128:14 325:17 control 106:7 21:16,23 23:9 244:7 248:1,6,13
conferences 45:7 consisting 186:16 147:14 150:1 271:1 251:25 257:9
confidence 103:6 consists 29:24 213:13 cores 205:3 260:3 263:21
configuration 58:5 Consolidated 1:8 Controls 122:13 Corps 2:22 7:2,15 264:19 265:8
58:7 59:15 67:16 6:5 conver 253:20 13:15 14:23 15:6 266:7,8 284:10
131:4,5 154:23 constantly 28:11 conversation 15:14 15:9 23:18,23 286:16 287:15,19
157:16 230:4 68:9 45:16 46:15 47:16 39:22 40:3,4,7 297:20 298:2,3
295:6,6 319:25 constraining 74:11 49:25 50:1 52:6 41:8,24 42:11 299:23,24 300:3
configurations construction 52:22 53:15,18,24 43:11,16,24 64:15 301:4,14 302:3,25
68:20 69:3,4,19 163:23 167:10 53:25 56:9,14 82:22 90:15,21 307:10,15 314:9
69:22 105:8 180:11 183:5 57:6,8,14 59:11 91:21 93:9,12,15 314:20 315:17,18
confines 295:5 217:18 227:7 69:14 109:19 93:16 136:15 316:18 321:4,22
confirm 126:19 228:15 230:5 112:18 114:1,21 207:22 209:3 330:6 331:12

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corrected 312:15 create 302:17 253:24 254:5,17 58:4 65:20,24,25 280:7 288:24,25
correction 330:18 creating 75:3 255:2,8 256:4,12 66:6,10,17,24 289:3,5,6 290:22
corrections 330:8 crime 329:2 264:24 265:3 67:6,16,22,22,23 290:23 291:9,14
330:16 CRIMS 119:23,24 267:7,14 268:19 67:25 68:3,6,10 291:19,19 292:20
correctly 104:14 125:22 126:21,23 269:2,7,18,21 68:17,22,23,25 292:22 293:9
correctness 329:9 CRR 3:8 4:19 270:2,12,14,17,18 69:13 70:15 85:12 295:7 297:4
correlate 117:2,4 331:4 315:22,23,25 87:6 89:7 96:6 298:10 299:9,9,23
149:7 crunching 109:9 316:17,22 317:5,7 99:22 101:23 300:4,10,23 301:3
correspond 60:2 CSR 3:8 317:12 103:18,20,22 301:8,17 302:6,10
correspondence Culp 201:23 104:13,16 105:7 302:10,12,13,17
18:9,17 curiosity 236:10 D 105:10 109:17 302:20 303:12,20
corresponds current 21:13 D 3:8 4:19 5:1 110:1,5,9 111:9 303:23 304:2,7
132:24 311:1 95:14 331:4,20 111:10,13 113:12 305:16 306:7,15
counsel 4:4 6:12 currently 41:1 daddy 44:14 117:4 120:5 307:20 310:9,22
12:23 13:5,12 51:25 76:11 Dale 20:7 29:20 122:19 123:12 310:24 311:8
18:11,17 20:5 curriculum 11:3 30:12 137:5 140:9 126:21 131:22 312:10 314:7,13
124:11 331:13,14 cursor 98:22,23 143:10 157:21 134:5,6,13,18 314:18,20 315:16
couple 55:22 cursory 187:22 160:20 162:14 136:25 144:11,12 316:14,22 317:12
130:10 268:11 cut 61:7,8 66:19 179:18 180:2,6 144:13 147:12 317:15 318:6
course 8:19 9:12 166:2 168:10 185:12 204:22 148:5,7,11,17,19 319:1,4 320:14,19
10:2 16:21 36:17 176:14 231:22 205:2 215:14 151:22 152:7 321:19 325:13,14
37:25 101:11 269:8 285:19,22 226:12 228:12 154:1,19 155:17 325:18 327:6,13
110:13 196:3 cutting 248:12 237:22 242:17 155:21,23 156:4,4 327:22,23,24
268:9 288:5 292:4 CWPPRA 40:10 243:7 247:7 250:6 156:10,11,17,21 date 6:8 8:21 47:3
294:24 41:8 93:14 206:9 263:3,7 266:18 157:13 158:12 87:11 222:25
courses 26:8 cycle 196:18,20 275:15 277:16 159:1 161:9,11,12 289:19 330:13,20
court 1:1 3:8 4:19 cyp 261:25 Dale's 140:9 217:6 164:20 165:1,16 dated 7:18 20:2
6:10 7:4,9 8:8,14 cypress 61:23 62:5 225:3 241:15 166:9 169:18 38:14,21 243:3
8:22 9:5,20 10:7 62:8 96:2 98:17 275:22,23 277:4 170:8,9,14 179:9 dates 19:15 42:9
34:8 52:1 143:19 151:20,21,24 306:21 180:23,24 181:10 46:23 69:6 146:24
331:5,21 152:3,4,5 153:4 damage 279:8,25 182:10,11,18 day 10:2 19:21,22
courtesy 94:6 165:2 169:1 172:7 dark 133:25 308:11 183:23 184:6 19:25 38:14 39:2
Couvillon 119:2,15 173:24 176:2,20 darker 307:4 185:1 190:24 39:6 52:3 54:24
122:7,23 195:18 196:23,25 data 23:18,21,25 195:11,17 196:21 147:23 215:16
cover 30:1 106:19 197:3,4 206:18 28:1,2,14,15,18 208:7 210:20 266:21 268:1
115:17 136:5 214:13 215:21 28:25 29:2,15,17 211:8 212:22 days 78:7 85:19
223:8 328:17 216:4 217:25 29:19 31:5 32:10 213:6 215:3,5 87:7 145:23
covered 100:14 218:1,1,12,20 36:1,2,3,5,9,14,20 217:19 219:4 dead 226:12,16
199:17 214:10 219:5 222:6,15,20 36:25 37:5,15 220:21 222:9 232:20 233:4,9,13
220:2 246:13 223:17 226:17 38:4 42:2 43:21 226:11,21 228:24 deal 127:8 223:7
290:16 227:1 231:8,9 43:24 45:9,11,13 232:1,11 234:10 269:13 321:4
covering 68:19 232:15,18,19 48:9,11,21 49:6,9 234:21 235:5,7,16 dealing 206:15
Cowardin 95:10,10 240:13 243:17 49:12 50:8,10,14 237:2 245:7 252:2 220:9 240:4
95:13,15 96:13,20 244:4,9,11 245:10 50:17 51:2,5,12 252:20 255:7 262:10 321:1
97:5 236:25 246:7 247:5 51:16,19 52:14,21 256:2 261:14 death 267:3 271:15
co-chair 112:7 248:18,23 249:2 52:25 54:3,22 266:1 268:10,10 278:12
co-principal 87:16 253:1,3,9,17,24 55:13 56:15 58:2 268:15 270:18 deca 222:25

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decades 292:9 degree 136:9 137:7 330:15 140:3 152:19 dig 322:8
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38:17 39:19 87:1 181:23 311:17 224:23 190:13 281:12 digital 57:22,25
243:3 294:10,12 degrees 26:12 deposition 1:19 4:5 288:16 328:3 238:4
decide 154:25 277:24 4:14 6:2,3 7:20 determined 294:3 digitized 180:24
155:5 Delacroix 38:1 8:2,6,10,20 10:11 294:17 188:25 206:9
decided 44:3 49:14 188:1 212:14,15 10:12 11:12,19,22 determining 79:6 212:21 213:6,6
162:22 261:23 297:25 12:1 21:3 29:11 153:13 185:14 325:12,12
decrease 184:16 308:15,16 33:25 34:8,23 310:18 digitizing 213:11
193:8 264:17 delay 36:4 86:24 114:25 develop 36:9,11 213:14
deep 271:14 272:22 delineations 298:14 142:19,25 143:8,9 40:17 94:10 101:3 digs 279:20
defend 8:5 Deloche 138:12,13 245:14,17 265:23 116:23 301:17 direct 180:16,22
Defendants 16:14 140:2 depositions 21:2 303:21 181:1,5,11,12,13
defense 67:15 delta 107:19 depth 141:22 developed 28:20 181:25 182:5,10
116:8 136:11 196:14,18,19 288:22 37:8 59:2,3 90:4 183:2,13 197:8,12
138:2 139:8 204:8,10 derivative 310:12 96:7,19 98:8 197:21 203:15
defer 139:6 177:3 deltaic 82:16,16 derived 124:14 134:10 144:9 204:3 245:16
203:5 205:2 215:2 203:10 201:23 298:16 189:6 302:15 246:3,7,19,22
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274:13 162:22,24 163:8 44:17 45:7 230:8 developing 111:10 274:10 285:4,10
deferring 231:16 demean 326:24 308:2,8 310:4 development 285:25 286:12
define 89:5 109:13 demonstrative described 235:17 261:18 278:17 287:18 326:16,20
160:2,10 179:15 21:17 326:13 develops 37:5 326:21
182:17 188:6 dense 218:3,3 describing 56:23 de-aggregated direction 331:11
198:18 217:23 density 150:9,16 287:11 236:24 directly 29:22 53:2
246:2 152:12,16,19 description 26:24 diagrams 176:15 53:7 111:19
defined 39:7 83:6 211:5 252:2 108:24 304:20 died 292:1 113:13 135:13
84:1 88:12 160:3 Department 1:23 design 95:12 difference 89:14 140:20,25 220:12
161:18 163:25 2:16 6:23 7:16 designated 191:25 202:23 217:23 274:22
195:15 198:12 14:9 17:23 18:2 designation 83:20 227:4 315:19 disagree 139:5
319:23 326:17 51:22 53:5,14 209:20 308:16 319:2 320:10 205:1 208:10
defines 160:11 56:8 96:17 98:5 designed 64:18 differences 223:11 disappear 168:7
195:17 102:13 110:6 89:25 163:1 298:14 disappeared
defining 154:16 142:14 240:16 256:25 different 29:19,20 147:19
212:10 244:22 277:15 329:12 detail 185:3 271:7 30:4,11,14 31:2,2 discourse 35:11
247:15 285:1 dependent 26:10 310:15,16 49:7 52:3 83:20 discovery 34:7
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251:23 254:8 106:2 214:16,19 276:7 162:1,12 173:22 discrete 175:23
definition 57:2 290:4 detecting 110:24 179:20 202:16 discriminate 240:9
67:18 183:14 depends 216:8 determination 238:12 243:21 discuss 10:14 34:2
195:9 300:15 329:11 208:19 265:18 278:6 54:2 121:8 127:12
definitively 200:4 depict 324:12 determinations 280:1 282:22 135:12 239:7
200:16 depiction 132:2 200:2 303:2,4 305:10 discussed 14:8
degradation 166:19 determine 12:5 319:4,13,24 110:10 129:15
169:11,12,22 deponent 17:7,11 23:15 34:3 43:13 difficulties 9:11 140:23 235:20
196:19 19:9 21:18 24:7 43:17 80:18 82:11 99:9 238:25

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discussing 73:15 160:24 164:7,8 54:16 55:2,5 56:5 290:1 317:17 327:12
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300:20 314:17 32:9 42:15 49:8 113:12,18 114:2,9 218:10 eastern 1:2 155:14
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disputing 255:15 112:22 114:5,7 266:21,21,21 143:13 145:11 268:3
distinct 83:14 129:25 258:19 268:1,2,2 270:22 231:5 education 26:10
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distributary 136:23 draft 16:13 86:11 duties 14:17 30:20
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1

UNITED STATES DISTRICT COURT

IN RE: KATRINA CANAL BREACHES CIVIL ACTION

PERTAINS TO: MRGO ROBINSON JUDGE DUVAL

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285

JOHNS PENDLETON COURT REPORTERS 800 562-1285