KTR00184

DONALD RESIO February 9, 2009
UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF LOUISIANA
IN RE: KATRINA CANAL BREACHES

CONSOLIDATED LITIGATION PLAINTIFF
CIVIL ACTION NO. 05-4182 "K"(2)
PERTAINS TO: MRGO, ROBINSON (NO. 06-2268) DEFENDANT
____________________________________________________
DEPOSITION OF DONALD RESIO, P.H.D.
____________________________________________________
APPEARANCES:
JAMES P. ROY, ESQUIRE
ASHLEY E. PHILEN, ESQUIRE
Domengeaux Wright Roy & Edwards
556 Jefferson Street
Lafayette, Louisiana 70502
JONATHAN B. ANDRY, ESQUIRE
The Andry Law Firm
610 Baronne Street
New Orleans, Louisiana 70113
REPRESENTING THE PLAINTIFFS
ROBIN D. SMITH, ESQUIRE

JACK WOODCOCK, ESQUIRE
United States Department of Justice
Benjamin Franklin Station
Washington, DC 20044
REPRESENTING UNITED STATES OF AMERICA
ALSO PRESENT: Jeff Conner, Videographer
Taken at the instance of the Plaintiffs

At the US Army Corps of Engineers
3909 Halls Ferry Road
Vicksburg, Mississippi 39180
On February 9, 2009, at 9:29 a.m.
REPORTED BY: SHARRON F. ALLEN, CSR, RPR

CSR NO. 1144
JOHNS PENDLETON COURT REPORTERS 800 562-1285

Page 2 Page 4
1 TABLE OF CONTENTS 1 VIDEOGRAPHER: This is the video
2 Examination by Mr. Roy 5 2 deposition of Dr. Donald T. Resio taken in the
3 Exhibit 1 (Notice of Deposition) 6 3 suit styled In Re: Katrina Canal Breaches,
4 Exhibit 2 (Donald Resio CV) 7 4 Consolidated Litigation, Pertains to: MRGO,
5 Exhibit 3 (Donald Resio Expert Report) 7 5 Robinson, No. 06-2268, being Civil Action
6 Exhibit 4 (Appendix 4-Nearshore Waves) 55 6 No. 05-4182-"K"(2) in the United States District
7 Exhibit 5 (Appendix 3-Offshore Waves) 55 7 Court, Eastern District of Louisiana.
8 Exhibit 6 (Appendix 5-Storm Surge) 57 8 We're at the U.S. Army Corps of Engineers,
9 Exhibit 7 (Final Report-Performance Evaluation) 58 9 ERDC, Vicksburg, Mississippi. Today's date is
10 Exhibit 8 (User's Manual for STWAVE, Version 3) 79 10 Monday, February 9, 2009. The time is 9:29 a.m.
11 Exhibit 9 (Modeling Nearshore Waves for 11 The court reporter is Sharron Allen with
12 Hurricane Katrina) 82 12 Sharron Allen & Associates. I am Jeff Conner,
13 Exhibit 10 (Application of Boussinesq Modeling) 95 13 the legal video specialist, with Conner
14 Exhibit 11 (Figure 11 STWAVE Modeling Domains) 95 14 Reporting.
15 Exhibit 12 (Improved Shallow-Water Wave 15 Will the attorneys please introduce
16 Modeling) 119 16 themselves on audio.
17 Exhibit 13 (Diagram) 123 17 MR. ROY: Jim Roy, representing MRGO,
18 Exhibit 14 (Figure 16 Full-plane Maximum Wave) 136 18 PSLC, and the Robinson plaintiffs.
19 Exhibit 15 (NOT MARKED) 19 MS. PHILEN: Ashley Philen with MRGO,
20 Exhibit 16 (Wave Forces and Overtopping) 142 20 Robinson plaintiffs.
21 Exhibit 17 (Figure 23 Profile for Boussinesq) 172 21 MR. ANDRY: Jonathan Andry with MRGO,
22 Exhibit 18 (LIDAR Format) 181 22 PSLC, and the Robinson plaintiffs.
23 Exhibit 19 (LIDAR Format) 183 23 MR. SMITH: Robin Smith for United States.
24 Exhibit 20 (Figure 24: Snapshot of 24 MR. WOODCOCK: Jack Woodcock, United
25 Water Surface) 212 25 States.
Page 3 Page 5
1 Exhibit 21 (Shore Protection, Planning 1 VIDEOGRAPHER: Swear the witness, please.
2 & Design) 241 2 * * * * * *
3 Deposition Concluded 254 3 DONALD T. RESIO, Ph.D.,
4 Certificate of Court Reporter 255 4 having first been duly sworn, was examined and
5 5 testified as follows:
6 6 EXAMINATION
7 7 BY MR. ROY:
8 8 Q. Dr. Resio, my name is Jim Roy. I'm from
9 9 Lafayette, Louisiana, and I'm one of the attorneys
10 10 representing the plaintiffs in the Robinson case and
11 11 certain other cases. I'll ask you some questions
12 12 today. If you have any doubt about what I'm asking
13 13 you, feel free to tell me you don't understand, and
14 14 I'll try to make it more clear to you.
15 15 A. Thank you.
16 16 Q. If it's possible for you to answer with a
17 17 yes-or-no answer, even if you have to explain, the
18 18 customs and the rules would suggest if it's possible to
19 19 answer with a yes or a no, you answer it; then you've
20 20 certainly got the right to explain. And I'll certainly
21 21 afford you that right if you insist on having that
22 22 right today.
23 23 Understand we've got your report. We have
24 24 read it many times. We understand what you have said.
25 25 So the purpose of the deposition today is hopefully not
2 (Pages 2 to 5)
Page 6 Page 8
1 to ask you to spit back word for word what you've 1 Q. My object, I'm sure, is similar to yours:
2 already written. 2 Save as much time as we can.
3 A. Good. 3 MR. ROY: And I might add on the record,
4 Q. Okay? Fair enough? 4 Robin, without going into any unnecessary
5 A. Yes, that is. 5 sidebar, we're taking it today, taking the
6 Q. All right. The first exhibit I'm going to 6 deposition today, certainly without waiving any
7 show you is Exhibit 1, which is the original and 7 rights there may be to petition him for a second
8 amended notice of this deposition. 8 day as the ongoing dialogue has been going with
9 MR. ROY: Robin, without wasting a lot of 9 you and Joe, which I'm not involved in.
10 time, I've showed it to you before. Can we agree 10 MR. SMITH: I understand.
11 that's the original -- 11 MR. ROY: Okay, great.
12 MR. SMITH: Yes. 12 BY MR. ROY:
13 MR. ROY: -- and amended notice of this 13 Q. The last housekeeping matter is there was a
14 deposition? 14 disk of support materials that was furnished to us in
15 MR. SMITH: I didn't even look at it. I 15 connection with your report, and these are copies of
16 suppose I should. I kind of took your word for 16 the printed disk.
17 it. 17 I'd like for you to take a few minutes and
18 (Reviews document) Yes, I agree. 18 look at them. I want to be sure that -- just look. I
19 THE WITNESS: He agreed, and that's far 19 want to be sure that these are -- perhaps I'll frame
20 more important than me agreeing. 20 the question like this: There was a disk that was
21 MR. ROY: It's asked to be attached as 21 furnished to us that was represented as being the
22 Resio 1 englobo. 22 materials that you relied upon --
23 (EXHIBIT 1 MARKED) 23 A. Right.
24 BY MR. ROY: 24 Q. -- in preparation of your report. Are you
25 Q. Dr. Resio, I'm going to show you what has 25 familiar with such a disk?
Page 7 Page 9
1 been presented to us as your curriculum vitae and ask 1 A. I did not see the disk. I think these are
2 you if in fact that is correct. Take your time. 2 the publications upon which I relied upon. Is that --
3 A. (Reviews document) Yes, this is the one I 3 this is the publications. What it looks like is this
4 believe I prepared. 4 looks like all the publications that were either
5 Q. That's correct? 5 referenced in my report or used in somewhere -- they
6 A. It is correct. 6 must be referenced in my report, I'm assuming.
7 MR. ROY: All right. I'll ask that be 7 Q. All right.
8 attached as Exhibit 2. 8 A. But I would have to cross-check.
9 (EXHIBIT 2 MARKED) 9 Q. Well, my point is we've been furnished
10 BY MR. ROY: 10 nothing other than what's in front of you right now --
11 Q. And the report that we have been given has 11 A. Okay.
12 been marked as Exhibit 3. In fact, is that your 12 Q. -- as far as materials that were used or
13 report? 13 referenced in development of your opinions on relation
14 A. (Reviews document) It certainly looks like 14 of your opinions.
15 it, yes. 15 A. Right.
16 MR. ROY: Okay. We ask that be attached 16 Q. So other than this, is there anything else?
17 as Exhibit 3. 17 A. Other than things that I got from other team
18 (EXHIBIT 3 MARKED) 18 members that you should also have. I got things from
19 BY MR. ROY: 19 the Westerink team.
20 Q. You can keep in front of you Exhibits 2 and 20 Q. We'll go into those specifically.
21 3. 21 A. Okay. But, I mean, I either got things from
22 A. Okay. 22 the modelers that worked with me on this, and that was
23 Q. If you need to refer to them during the 23 Jane Smith, as you know, and Pat Lynett, who does this;
24 deposition, I don't have a problem with that at all. 24 and then everybody else was material that you're saying
25 A. Okay. Thank you very much. 25 you're considering independently.
3 (Pages 6 to 9)
Page 10 Page 12
1 Q. All right. Well, if you'll hand those back 1 transcript. I don't know.
2 to me. 2 Q. Do you know which physics courses?
3 A. Okay. 3 A. The standard physics courses that a physics
4 Q. I'm not going to tie up the record with 4 major would take. Now, that would be physics -- I
5 these, but we have -- we'll come back to these. 5 mean, it would be numbers. It would be like physics
6 A. Okay. 6 this, physics that, and I don't know after that.
7 Q. So we have approximately -- well, 20 or 30, I 7 Q. Do you know what year of your studies you
8 would guess at least, articles here. 8 changed your major from physics to either geography or
9 A. Right. Okay. I would have to cross-check, 9 physical geography?
10 you understand, to provide -- 10 A. '68. I believe. And, you know, this is not
11 Q. I understand. But the disk, as you 11 a detailed --
12 understand it, simply were copies of articles 12 Q. That would be your junior year?
13 referenced in your report. 13 A. Yes, sir.
14 A. That is correct. 14 Q. Okay. So you would have taken some freshman
15 Q. All right. 15 and sophomore physics courses you're telling me?
16 I need to learn a bit about your background. 16 A. That is correct.
17 I apologize for not being more familiar. I'm sure you 17 Q. More than two?
18 are very well known and a famous scientist, but I still 18 A. Oh, yeah. I mean, it was -- you know, you
19 need to go into the background. So why don't we start 19 took about four per semester --
20 with -- as I understand it, you went to the University 20 Q. All right.
21 of Virginia and got your undergraduate degree. 21 A. -- so it was, yes.
22 A. That's correct. 22 Q. Did you take any calculus courses?
23 Q. And as I appreciate it, that was a bachelor 23 A. Yes.
24 of arts? 24 Q. Math?
25 A. That's correct. 25 A. Yes.
Page 11 Page 13
1 Q. And you received that in '69? 1 Q. Engineering?
2 A. Yeah. I'm sure you have it in front of you. 2 A. No. Not in undergraduate.
3 Yes. 3 Q. Fluid dynamics?
4 Q. All right. What was your major course of 4 A. Not undergraduate.
5 studies? 5 Q. Material sciences?
6 A. I started off in physics, and then I talked 6 A. Not undergraduate.
7 with some people; I didn't want to stay in physics. So 7 Q. Geology?
8 I switched to physical geography, which is the study of 8 A. Yes.
9 natural phenomenon. 9 Q. What geology did you take?
10 Q. And when you received your B.A. in 1969 from 10 A. It was called physical geology -- they're
11 University of Virginia, did you graduate with a 11 like historical geology. And, again, this is the best
12 designated major? 12 I can do. I mean, I remember particular courses. One
13 A. Yeah. I believe it was physical -- physical 13 was on historical geology; one was on physical geology,
14 geography. I believe. I mean, I'd have to go back and 14 which does get into some earth materials. It doesn't
15 look; it's been a few years. But I believe it says -- 15 get into material sciences like steels and man-made,
16 it could say "geography"; it may say "physical 16 but it does get into some of the earth materials and
17 geography." One of those two, I think, is on it. 17 the -- well, standard geology. It's a -- it's a
18 Q. All right. Now, in connection with your 18 background for standard geology.
19 coursework in your undergraduate program leading up to 19 Q. Any courses in geomorphology?
20 your B.A. -- 20 A. Yes. That was my major professor's main area
21 A. Um-hum. (Affirmative) 21 of interest, and he had his degree from LSU.
22 Q. -- did you take physics courses? 22 Q. And what courses did you take in
23 A. Yes, I took some physics courses. 23 geomorphology as an undergraduate?
24 Q. How many physics courses? 24 A. I would have to check my transcript.
25 A. I'd just have to go back and check my 25 Q. But there were --
4 (Pages 10 to 13)
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1 A. I believe so, yes. 1 one, I wouldn't be asking you --
2 Q. Okay. Any courses in statistics as an 2 A. Oh, okay. No --
3 undergraduate? 3 Q. -- these questions.
4 A. Yes. Like theoretical and statistical 4 A. -- I don't remember, because it's -- when you
5 mechanics, which is a lot of statistics. Economics, we 5 get into the master's program, you take very
6 had a statistics bent in it. 6 specific -- there are quantitative courses that are
7 Q. Any physical oceanography? 7 inside your department. It's not taught -- the math
8 A. No. 8 department. It's talking about departments. It's
9 Q. According to your résumé, it then shows that 9 called like "quantitative methods." It teaches
10 you have an M.S. degree from the University of 10 calculus, it teaches all this, but it's not per se a
11 Virginia. Is that correct? 11 calculus course in the math department.
12 A. That is correct. 12 Q. Well, let me explain perhaps my own ignorance
13 Q. Awarded in 1970, according to the records we 13 here.
14 have. 14 A. Okay.
15 A. I think that was it, yeah. 15 Q. When I think of a master's program, I think
16 Q. All right. And that is a master of science 16 in the context of a master's in business
17 and not a master of arts? 17 administration; in the law context, a master of laws.
18 A. I believe so, yes. 18 In the context of others, a master's in a particular
19 Q. Okay. Would there be any doubt? 19 designated area.
20 A. Yeah. I mean, you know, this is a long time 20 A. Right.
21 ago. And I don't think even if you would have asked me 21 Q. And so I'm at a loss. All I see is your M.S.
22 on that day, maybe I would probably have had to read 22 And what I'm trying to get at is --
23 the fine print on it. You know, because you're in a 23 A. Sure. What I did.
24 department, you're a student, and that's not -- you're 24 Q. -- if it was a M.S. and what was the
25 in that department. I believe it was master of 25 designated master of science degree, if indeed that's
Page 15 Page 17
1 science. 1 what it was.
2 Q. When you graduated from University of 2 A. It was in -- okay. Now, the main reason why
3 Virginia, did you immediately transition into and 3 there's a little difficulty is the University of
4 commence the master's program? 4 Virginia was changing at this particular time, and
5 A. Yes. Yes. 5 that's when the Department of Environmental Science was
6 Q. And you did that as a full-time student? 6 being formed. And there were some of us that were in,
7 A. That's correct. 7 like, in between, and they had the -- and what was
8 Q. How many hours was that master's program? 8 written on the degrees on that year, I'm not sure. I
9 A. I met the requirements. I mean, I don't 9 had -- I'm not sure what was on my degree. It may have
10 remember. I mean, maybe I should. I mean, typically a 10 been physical geology for my master's, but you'd have
11 master's -- well, I don't want to start guessing. I 11 to check; but it was in the department that was the
12 don't remember. 12 same department that I got my Ph.D. in.
13 Q. So did your master's reflect a concentration? 13 Q. Okay. Physical geography?
14 Was the master's in a particular area? 14 A. Geology.
15 A. Yes. My master's thesis was on equilibrium 15 Q. Geology.
16 beach profiles. It was coastal. And it was getting 16 A. Yes.
17 into wave mechanics, and it was getting into -- 17 Q. So you're telling me you graduated with a
18 into the response of bottom sediments to waves. 18 B.A. with a major in physical geography?
19 Q. So while you were taking your master's 19 A. Right.
20 curriculum, did you take any physics courses? 20 Q. And then you got a master's in physical
21 A. I don't remember. 21 geology.
22 Q. Did you take any calculus? 22 A. I believe that is what they called it, yes.
23 A. And, again, I mean, I'm sure the transcripts 23 Q. All right. Now, are you familiar with the
24 are public information, but I don't remember. 24 clearinghouse of degrees that colleges report their
25 Q. Actually, the transcripts aren't. If I had 25 degrees on?
5 (Pages 14 to 17)
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1 I'm not trying to play hide the ball here; 1 A. That's correct.
2 I'm just going to tell you right up front. 2 Q. Okay. Now, your Ph.D. is reflected in your
3 A. Sure. Okay. 3 résumé, Exhibit 2, as "environmental science:fluid
4 Q. All right. The only public record that 4 dynamics."
5 universities report degrees to and dates of degrees 5 A. Right.
6 reflects your receiving a master of arts degree -- 6 Q. Is that actually what your Ph.D. was granted
7 A. Okay. 7 in?
8 Q. -- on June 7th of 1970. And I'm just 8 A. Well, environmental science, yes. I believe
9 wondering -- seems likes there's a little discrepancy 9 environmental science is all they said, and I put the
10 between your résumé, Exhibit 2, showing a M.S., a 10 colon on there because that's what I specialized in.
11 master of science, and the national reporting agency 11 Q. Okay. You told me what your master's thesis
12 reflecting a master of arts. And I -- 12 was; and I apologize, I did not write it down. Can you
13 A. Right. And, again, I don't know which -- if 13 tell me again?
14 you asked me right now what my Ph.D. was in -- you 14 A. It was an equilibrium -- and I don't know the
15 know, luckily, I don't have to put arts or science on 15 exact title, but it was on equilibrium beach profiles.
16 that. I thought it was master of science. 16 It was all about how waves created a particular profile
17 Change it on the résumé. 17 off the coast.
18 Q. Well, if I were to tell you that the public 18 Q. Off the coast of the Atlantic?
19 records that University of Virginia apparently -- 19 A. Anywhere. It was a generalized theoretical
20 A. Right. 20 formulation.
21 Q. -- reports to, this national entity -- 21 Q. Okay. Now, at any time while you were
22 A. Right. 22 working on your bachelor of arts, your master's, or
23 Q. -- reflects it as a master of arts, you would 23 your Ph.D., did you do any work for any governmental
24 not take issue with that? 24 agency?
25 A. No, no, no. In fact, that's -- I think I 25 A. I mean, I was funded by ONR, Office of Naval
Page 19 Page 21
1 tried to make it clear when you asked that I wasn't 1 Research. It was -- they had a project, and I was
2 sure. And in fact, a lot of times when I read this 2 funded by Office of Naval Research to work. I mean,
3 M.S., I thought it was an M.S. when I wrote that, but 3 that was part -- that was one of the things I did to
4 if you say it was -- I probably should go back and 4 support myself.
5 check, but it was one of those things where I just 5 Q. When did the funding by Office of Naval
6 didn't. 6 Research start for you during college?
7 Q. Let's go now to your Ph.D. 7 A. I'm going to guess, but approximately --
8 A. Okay. 8 Q. I won't hold you to the year. Just
9 Q. Did the master's program take approximately 9 approximately.
10 12 months or less? 10 A. Approximately, maybe 1971.
11 A. I can't -- if memory serves me, yes. 11 Q. In terms of reference, that would be early in
12 Q. Okay. And did you immediately transition 12 your master's program?
13 into your Ph.D. -- 13 A. It would be in my Ph.D. program.
14 A. That is correct. 14 Q. Early in your Ph.D. program.
15 Q. -- studies? 15 A. It might have been -- but that's what I'm
16 A. Right. 16 saying, it may have been the last year -- my only
17 Q. And that took what would appear somewhere in 17 year -- in '70 and then into '71; but it may have also
18 the neighborhood of three or four years? 18 just been '71 and on. I don't remember.
19 A. Yes. And one year postdoctoral. 19 Q. Tell me how you got started with the Office
20 Q. One year post what? 20 of Naval Research.
21 A. Postdoctoral study at the University of 21 A. My major professor, Dr. -- Professor Robert
22 Virginia. 22 Dolan, had a contract with them, and that was to study
23 Q. All right. That's after you get the degree. 23 the classification of coastal environments.
24 A. That's correct. 24 Q. Was your first published work of any kind
25 Q. All right. After you get the Ph.D. 25 done through ONR research?
6 (Pages 18 to 21)
Page 22 Page 24
1 A. Yes. It was Journal of Geology, and it 1 A. Yes.
2 was -- I don't know; it's a long time ago. But it was 2 Q. Now, did you consider your first year after
3 published in 1975 Journal of Geology, something on 3 receiving your Ph.D. to be your first year of
4 offshore beach profiles and an IgON function method of 4 governmental service?
5 representing them. 5 You reference in your résumé 20 years of
6 Q. During the time you were -- from the time you 6 government service, or a phrase to that.
7 started with ONR to the time you finished your Ph.D., 7 A. I don't believe that's counted in there.
8 was your major source of income for self support the 8 Q. Okay.
9 Office of Naval Research grants, or whatever they were? 9 A. Because officially, I was employed by the
10 A. I think so. The reason I say that: I mean, 10 University of Virginia.
11 I had to do some odd jobs. I had a wife and child at 11 Q. But coming straight out of your Ph.D.,
12 that time, and so there were a few other things I'm 12 100 percent of your time and your income, substantially
13 sure I did. 13 all of it was devoted toward the government work with
14 Q. Now, when you got your Ph.D., you then did a 14 the Office of Naval Research.
15 year of postgrad study, I think you told me? 15 A. Research.
16 A. Yes, postdoctoral. 16 Q. Okay. When you finished that, tell me who
17 Q. And was that at University of Virginia as 17 you went to work for and where.
18 well? 18 A. Okay. When I finished working, I came to
19 A. That is correct. 19 work for the organization that at that time was the
20 Q. And who were you working for or with during 20 U.S. Army Corps of Engineers Waterways Experiment
21 that period of time? 21 Station, which is this place, but it's changed its
22 A. That was also for the Office of Naval 22 name.
23 Research. It was for the University of Virginia. I 23 Q. All right. I have to apologize having to ask
24 mean, you have to understand when ONR gives money to a 24 you to repeat yourself. Normally --
25 place like University of Virginia, any government 25 A. That's fine.
Page 23 Page 25
1 entity funds, somebody to do a postdoc, the postdoc is 1 Q. -- I can see it written on my screen. And I
2 somewhat looser than -- it's not like you have to 2 don't always hear that well, so I didn't get part of
3 produce a particular item or something. So it's just 3 that name. I got the U.S. Army Corps of Engineers
4 research. They funded me to do research for a year, 4 part, but I didn't --
5 the Office of Naval Research. 5 A. Okay. Okay. Waterways Experiment Station.
6 Q. Well, in your experience, the Office of Naval 6 It was WES. Everybody knew this place as WES.
7 Research doesn't let just anybody do research for them, 7 Q. That's here in Vicksburg.
8 do they? 8 A. Yes. The ERDC is a subsequent evolution of
9 A. No, they don't. 9 WES, with some additional labs added.
10 Q. They are fairly selective in who they allow 10 Q. And when you refer to "ERDC," that's the
11 to work for them to do that sort of work. Right? 11 acronym all caps, E-R-D-C.
12 A. I think so. 12 A. That is correct.
13 Q. You would hope so. 13 Q. Which stands for?
14 A. I would hope so, yes. 14 A. Engineering Research and Development Center,
15 Q. Now, what was your thesis? 15 I think.
16 A. And, again, I'm going to paraphrase it, but I 16 Q. Which is what it's now called.
17 believe it was an integrated model of storm surge of 17 A. I think so, yes.
18 storms -- storm surge and waves. 18 Q. All right. Now, your first position would
19 And it was very broad. It looked at climate 19 have been in the neighborhood of '75, '76, if my math
20 variability and it looked at wave models and it looked 20 is correct. Mid '70s?
21 at surge models and attempted to integrate them all 21 A. That's correct.
22 into some idea of how the way climate was changing on 22 Q. And how long did you stay with the Corps of
23 the mid-Atlantic region. That's what it did. I don't 23 Engineers?
24 remember the exact title. 24 A. Until 1981.
25 Q. And did you write that alone? 25 Q. And I take it when you started, you entered
7 (Pages 22 to 25)
Page 26 Page 28
1 in a GS capacity of one kind or another. 1 Q. Who did you consult with? I don't want you
2 A. Twelve. 2 to betray any confidences. What I'm after is
3 Q. Okay. And you began as a GS 12. And working 3 government or private contractors.
4 full-time here in Vicksburg for the Corps through about 4 A. A range. I mean, it was government. It was
5 '81. 5 also the parishes. Plaquemines Parish we did a lot of
6 A. That's correct. 6 work for. And I don't know whether you consider
7 Q. And in '81, what happened? 7 them -- I guess they're government too. But
8 A. Well, I was a GS 14 at that point, and they 8 Plaquemines, Terrebonne were some of our big . . . We
9 wanted me to stay, and offered me a 15 to stay, but I 9 did a lot -- we did legal cases, which the government
10 did not. I -- well, I was having a divorce, and people 10 was on the other side more often than they were on the
11 change things when they have a divorce. 11 same side. And we did -- so our clients ranged. We
12 Q. I understand that. 12 had -- I would say more than half would be
13 A. I wanted a change, so I was under -- in the 13 nongovernment.
14 middle of that. And so I went to work for Ocean 14 Q. Did you do any work for the Corps or any of
15 Weather, Incorporated, as a vice president. 15 its affiliates?
16 Q. Now, is Ocean Weather, Incorporated, still 16 A. Very, very, very little. Almost none. I
17 around? 17 mean, there -- there was probably -- I'm talking maybe
18 A. Yes, they are. 18 $10,000 ballpark.
19 Q. Is it a nationwide company? 19 Q. Were you the only principal of that company?
20 A. It's inter- -- I mean, it works 20 A. Yes. I mean, I had a vice president, and he
21 internationally. 21 was a part owner, but I bought him out. So he was in
22 Q. That was going to be my next question. 22 there for about four years, I think, if I remember
23 So if it works internationally, I assume it 23 right.
24 covers the nation too. 24 Q. Did that company have any engineers at any
25 A. Yeah, right, right. Okay. 25 time?
Page 27 Page 29
1 Q. All right. That's good. 1 A. Yes. We had a branch in -- outside of
2 Now, during those two years you were with 2 Baltimore. Outside of Philadelphia; excuse me.
3 Ocean Weather, what did you do? 3 Q. That's your company, Offshore Coastal?
4 A. We did storm predictions, waves, and some 4 A. That's correct. That's right.
5 surge on the north slope of Alaska. 5 Q. Okay.
6 And mainly it was design work for oil rigs, 6 A. And we had an individual who actually I sold
7 trying to say how high should they be built. It was 7 the company to when I left, and he still has the
8 giving the specs for the design. In other words, we 8 company today.
9 said, Okay, here's -- based on this set of storms, the 9 Q. When you talk about doing work in that eight
10 100-year water level that you might want to design for 10 years, what was the principal specific work that you
11 is this; the 200, if you want to use that, is this. 11 did?
12 And we specified -- we recreated storms much in the 12 A. Well, it's different. It's a variety. We
13 same sense we're doing here. And we spent a lot of 13 were a small company.
14 time trying to get it right so that people would build 14 We did -- like I say, we were involved in the
15 oil rigs in a sensible fashion and not have large 15 lawsuit in which case -- we have been on both -- the
16 losses. 16 defendants were the death claimants on the Glomar Java
17 Q. All right. Was that here in Vicksburg? 17 Sea. And that was -- the other side of it were people
18 A. That's correct. Because my children were 18 who were good friends of mine. They were oil company
19 here, I stayed in Vicksburg. 19 people. But I thought something needed to be changed,
20 Q. All right. And then apparently you left that 20 so we did it. But it was a . . .
21 employment and became president and owner of your own 21 So on one hand I've worked for everybody from
22 consulting company, Offshore and Coastal Technologies? 22 law firms that I always will look at the case and I'll
23 A. That's correct. 23 see if it is in fact something that I think is right;
24 Q. Did that for about eight years? 24 and if it is, then I will go ahead and take it.
25 A. That's right. 25 Q. But what was the nature of the --
8 (Pages 26 to 29)
Page 30 Page 32
1 A. What I produced? 1 firm."
2 Q. -- expertise you were offering? 2 A. That's correct.
3 A. Okay. Right. 3 Q. All right. Sometime, then, apparently in the
4 Q. What were you doing? Were you calculating 4 mid '90s you went back to work for the Corps. Is that
5 wind directions, storm waves, water heights? What were 5 correct?
6 you doing? 6 A. Right. After I went to academia for a while.
7 A. Some were all of the above. We were 7 I had four years where I taught physical oceanography
8 reconstructing storms. Very frequently what people 8 at FIT; that's Florida Institute of Technology. I was
9 wanted us to do was reconstruct the storm, because some 9 the physical oceanographer there.
10 damage -- 10 Q. Tell me what the field of physical
11 Q. In hindcast? 11 oceanography encompasses specifically.
12 A. Hindcast, right. 12 A. It's very broad. I mean, it all depends. It
13 Q. Hindcast. 13 covers everything from climate variation in the ocean,
14 A. Hindcast the conditions in the storm. And 14 to air/sea interaction, to wave generation, to surge
15 some of it was even I was paid to be an arbitrator in a 15 generation. And we covered all of that. Temperature,
16 case in Norway that was Delft on one side, and it 16 salinity. It goes on and on.
17 was -- all the Europeans were already involved, so they 17 Q. Were you a professor?
18 needed to come over here to get somebody in this 18 A. Yes.
19 country to be on the board of arbitration for the 19 Q. Associate professor, assistant --
20 international -- was it the chamber of commerce port? 20 A. Associate.
21 I don't know. I'm not -- again, those are the details 21 Q. -- professor --
22 that I don't keep straight in my mind. 22 A. Associate.
23 Q. And I'm not interested in the specific 23 Q. Associate professor. With or without tenure?
24 details at this time. 24 A. They don't have tenure at that university.
25 A. Okay. 25 Q. Okay.
Page 31 Page 33
1 Q. You've answered my question. 1 A. Nobody has it.
2 A. All right. 2 Q. And after four years, then -- which puts us
3 Q. In terms of the work that you did during 3 now, I think, into the mid '90s --
4 those eight years, did you utilize ADCIRC during those 4 A. That's correct.
5 eight years? 5 Q. -- you left there to come to work again for
6 A. It didn't exist during those eight years. 6 the Corps. Is that correct?
7 Q. Okay. Did you utilize STWAVE during those 7 A. That is correct.
8 eight years? 8 Q. And you came in as, what, a senior
9 A. At the end of those eight years, I developed 9 technologist?
10 STWAVE. 10 A. Right.
11 Q. Okay. 11 Q. Now, you say in your résumé that this is the
12 A. So after that I utilized it. 12 highest technical rank in the Department of Defense
13 Q. All right. All right. Now, you apparently 13 civil service. Less than 40 such positions are
14 were familiar as far back then as the early '90s, late 14 authorized within the army.
15 '80s with Delft. Is that correct? 15 Is that within the Corps of Engineers or the
16 A. That is correct. 16 entire United States Army?
17 Q. Has Delft had an international reputation as 17 A. The entire United States Army. There's four
18 being involved in coastal engineering and hydrodynamics 18 inside the Corps.
19 for decades? 19 Q. Okay.
20 A. Yes, they have. 20 A. At present. They may be trying to increase
21 Q. Doing the same sort of work that you have 21 it, but I think I know of four.
22 described that you've done and your coastal firm has 22 Q. How many senior technologists are there in
23 done. 23 the Corps here in Vicksburg? Just you?
24 A. That is correct. 24 A. No, no, no. There's one -- there are
25 Q. Your private consulting firm; I said "coastal 25 different fields you have. There's one that does
9 (Pages 30 to 33)
Page 34 Page 36
1 structures, there's one that does soils, and there's 1 Q. And who do they report to?
2 one that does biology. So there's three others in 2 A. They report to -- well, I don't know how much
3 Vicksburg. So we're all here because we're the main 3 detail you want to get in I charts, but they would, I
4 research branch for the Corps. 4 believe -- I don't know whether -- they either report
5 Q. Okay. And your field is not structure, 5 to the assistant director or to the director of ERDC,
6 soils, or biology. 6 and if they -- and I don't keep track of who reports to
7 A. No. 7 whom, but if they report to the assistant director,
8 Q. It's what? What's the field? 8 that would be Jeff Holland; if they reporter to the
9 A. It's coastal sedimentation. 9 director, it would be Jim Houston.
10 Q. All right. So you are the senior 10 These are all what's called senior executive
11 technologist in charge of the coastal sedimentation 11 service positions, so at this point it becomes somewhat
12 division? 12 different.
13 A. No, no. There's not a division. It's just 13 Q. The facility where we are now, I mean, I
14 a -- I'm like a senior scientist that is supposed to 14 couldn't help but notice there's barbed wire on some of
15 give advice, to set provisions where we want to go and 15 the fences; there's a guard gate; there are posts that
16 what we want to achieve. 16 obviously can stick up out of the ground to stop
17 Q. All right. Who do you report to? 17 people. It's very well protected.
18 A. Who? 18 Is this a military installation?
19 Q. Who's your boss? 19 A. I'm not sure. I mean, it's very few military
20 A. My boss? My immediate boss is the director 20 people here. Now, it is owned by the U.S.
21 of the laboratory, but because my rater is actually in 21 Government -- that part's for sure -- and it's owned by
22 the army in general and so I don't want to -- this gets 22 the Corps of Engineers, and that is a military
23 confusing. Because there's only four of us, you don't 23 organization. So if you follow it through, but . . .
24 have enough inside the Corps to have a rating pool. 24 Q. I have no follow-up for it. I was just
25 And as you know, when you get into that level, you need 25 asking.
Page 35 Page 37
1 to have enough people to judge relevance. So I get 1 A. Okay. I mean, I don't know whether this is
2 rated by the whole army. 2 considered to be -- we do a lot of -- the Corps of
3 Q. All right. By the -- when you say "the 3 Engineers, as you know, is divided into two parts -- a
4 army" -- 4 civil works part and a military part.
5 A. Right. 5 Q. Right.
6 Q. -- generals? Who are you -- 6 A. And probably it's about 50/50 here, I think,
7 A. No, no. It's -- it would be the senior -- 7 between civil works and military.
8 the senior scientist for the army. There's two of 8 Q. Let's talk about your specific expertise for
9 them, Tom Killion and John Parmentola. And they 9 this case. Certainly you're aware that there are other
10 convene a committee of individuals to review all of the 10 experts on the Army Corps team of experts -- Mossier,
11 STs -- is what we're called -- and then we get our 11 Westerink, Ebersole, others. You're familiar with
12 ratings, our final ratings, based on the opinions of 12 these names. Right?
13 that committee. 13 A. Yes. Yes, I am.
14 Q. Your immediate boss here -- 14 Q. What are you -- what is your designated area
15 A. Yes. 15 of expertise as amongst this team? If you have one.
16 Q. -- is who? 16 A. Okay. Sure. I hope I have one.
17 A. Is my lab director. 17 I am supposed to be the person who takes --
18 Q. And who is that? 18 who takes the waves into the situation and converge
19 A. I have an acting lab director. My lab 19 what the waves are doing and make that into some
20 director was Tom Richardson until the beginning of 20 understanding of how much water is going over the
21 January. My acting lab director is Bill Martin. 21 levees and the forces acting on the levees and give
22 Q. And are these full-time Corps employees? 22 that to the interior drainage team and to Bruce
23 A. Yes, they are. 23 Ebersole, who -- I mean, again, it's a team effort; so
24 Q. Civilian? 24 I try to stay in my lane, and, hopefully, they stay in
25 A. That's correct. 25 theirs.
10 (Pages 34 to 37)
Page 38 Page 40
1 I also, you know, look at some of the -- I've 1 Q. All right. And when we say the winds and the
2 reviewed some reports by other people. I don't want to 2 surges, Dr. Resio, I presume we're talking about all
3 leave that out either. 3 things related to them -- the times of them, the
4 Q. All right. But -- you certainly anticipated 4 locations of them, the charts. All these sorts of
5 where I was going. 5 things.
6 In the reports, have you read reports of -- 6 A. That is correct.
7 for example, Mr. Ebersole, have you read his report? 7 Q. All right. And it's your understanding that
8 A. I actually have not read his report. 8 Dr. Westerink computed these things using ADCIRC?
9 Q. Have you read Dr. Westerink's report? 9 A. That's right.
10 A. I have not read his report. 10 Q. Okay. Now, specifically -- and we'll get
11 Q. Have you read any of the other reports of the 11 into some specifics in your report, but since we
12 team, your team? 12 brought it up now, let's go ahead and talk about it.
13 A. No, I have not. 13 Did Dr. Westerink actually give you specific
14 Q. Okay. Have you discussed with any of them 14 printouts of specific information -- snapshots, if you
15 their findings? 15 will -- of information for particular times of
16 A. Yes. Yes, I have discussed their findings. 16 particular events dealing with winds and surges from
17 Q. All right. So you're at least generally 17 his ADCIRC modeling?
18 aware of what the rest of your team's conclusions are 18 A. Well, it's really -- it's a misnomer to say
19 within their discrete areas. 19 it comes from the ADCIRC modeling. The winds go into
20 A. Yes, absolutely. 20 the ADCIRC modeling.
21 Q. All right. I would suggest to you that in 21 Q. I understand.
22 the reports that have been rendered by a number of your 22 A. All right. The winds come from -- come from
23 team's experts that -- I'm sure it's unintentional -- 23 Vince Cardone and from Mark Powell. The winds were
24 but there is overlap; and to some extent, I'm sure it's 24 totally objectively determined by them in a reanalysis
25 necessary. But I'm trying to find out basically whose 25 of the storm. And they're the two best in this --
Page 39 Page 41
1 discrete area begins and ends where. 1 well, they're the two best in the world on doing that,
2 A. Okay. 2 so I trust them.
3 Q. That's part of this exercise. And I think 3 So I don't want to make it sound like
4 you've tried to answer it when you said basically -- if 4 Johannes was doing meteorology, because he simply used
5 I understand it -- your job was to take the waves and 5 his winds.
6 convert the waves into something reflecting the water 6 Now, once he starts going in there, it's
7 going over the levee and the forces working on the 7 simply mathematically interpolating and taking those
8 levee, or words to that effect. Is that correct? 8 wind fields; and that's what he's using and that's what
9 A. Right. And to do that, we had to have the 9 he gave -- he gave to Jane Smith, who is actually doing
10 winds and surges from Dr. Westerink. 10 the runs with STWAVE.
11 Q. All right. You need to be a lawyer. You're 11 And it gets complicated, but, okay, Jane did
12 anticipating my question. 12 the STWAVE of runs with the same wind fields. You have
13 My next question was going to be the 13 to keep the wind fields the same, obviously.
14 information provided to you. 14 Q. All right. So for you to write your report,
15 A. Do you want me to give you time to ask it? 15 all I want to know is the person that gave you the
16 Q. No, no. This is great. I'm all for saving 16 information. I'm not asking where they got it.
17 time. All right? 17 A. Okay. Okay.
18 A. Okay. Well, I just -- sometimes I'm not sure 18 Q. The person that gave you the information was
19 what the total implication is of your question. 19 Dr. Westerink. Is that correct?
20 Q. I understand, and I'll stop you if it's in 20 A. That is correct.
21 the wrong direction. 21 Q. Did anybody other than Dr. Westerink furnish
22 But the winds and surges, for all purposes of 22 you information? I don't care who gave it to him.
23 your calculations in your report, were provided to you 23 A. Okay. All right. All right.
24 by Dr. Westerink. 24 Q. All I want to know is who gave you the
25 A. That is correct. 25 information --
11 (Pages 38 to 41)
Page 42 Page 44
1 A. -- that I used. 1 up with." And I said, "Okay."
2 Q. -- you used to compute your report. 2 Q. Who said? Who's "he"?
3 A. Okay. Both Bruce Ebersole and Steve 3 A. Pat Lynett.
4 Fitzgerald gave me information on levee heights, 4 Q. P-A-T L-Y-N-E-T-T?
5 because they were the ones that were charged with doing 5 A. That's correct. The Lynett that you have on
6 that. 6 a lot of your documents there.
7 Q. All right, hold on. Steve Fitzgerald. 7 Q. Okay. And he is with or she is with Texas
8 A. Right. 8 A&M.
9 Q. And who? 9 A. He. It's Patrick. It's Texas A&M.
10 A. And Bruce Ebersole. You've been saying 10 Q. And he directly furnished you with generic
11 "E-ber-sol." 11 profile information?
12 Q. I apologize. 12 A. That's correct.
13 A. That's all right. It's the same person. 13 Q. Didn't go through Dr. Westerink or
14 Q. Mr. Ebersole gave you the info on the levee 14 Mr. Ebersole or anybody else?
15 heights. 15 A. No, it did not.
16 A. Well, they gave me levee height information, 16 Q. All right. Did you contact Pat Lynett?
17 yes. 17 A. To do it, or what?
18 Q. Whatever -- let me put it like this: 18 Q. Yes.
19 Whatever levee height information you relied upon -- 19 A. I mean --
20 A. -- I got from them. 20 Q. How did Pat Lynett get into this equation,
21 Q. -- to write your report that we've identified 21 get into --
22 came from Steve Fitzgerald or Mr. Ebersole. 22 A. Yes. I -- this -- this actually was being
23 A. That is correct. 23 done as part of some continuing work that we were
24 Q. All right. Now, whatever wind and surge 24 looking at for overtopping characteristics and levee
25 information that you relied upon to write your report 25 vulnerability, and so we were doing it as part of that
Page 43 Page 45
1 you obtained from Dr. Westerink. 1 work.
2 A. That is correct. 2 Q. Where in your report do you refer to Pat
3 Q. Now, other than Fitzgerald and Ebersole for 3 Lynett?
4 the levee height information and the winds and surges 4 A. I mean, lots of places he's referenced.
5 through Dr. Westerink, did anyone other than those 5 Q. By name?
6 three individuals provide information to you needed to 6 A. Yes. He's the author of the -- oh, you mean
7 write your report? 7 like did he give me the generic -- I did not say where
8 A. Well, I mean -- 8 the generic profile came from, if that's what you're
9 Q. Essential information. 9 asking.
10 A. Essential information. I mean -- I mean, the 10 Q. Yeah, that's it.
11 generic profile I talked to a lot of different people 11 A. Okay. We can add a footnote down there.
12 about. We used a generic profile. And Pat Lynett, 12 Q. And was this given to you orally?
13 professor at Texas A&M, actually came up with that 13 A. No, no. It's a computer file.
14 generic profile independently. 14 Q. What type of computer file is it?
15 Q. All right. What do you mean they "came up 15 A. It's a -- well, I mean, it's the input to the
16 with it"? 16 Boussinesq model COULWAVE.
17 A. I don't -- I mean, my -- when one is 17 Q. And this was prepared by Pat Lynett at Texas
18 modeling, one wants to be as objective as possible. 18 A&M?
19 All right. Now, it's very important that in order for 19 A. That's right.
20 me to say I'm being objective, that I just say, I want 20 Q. Okay. Tell me who Pat Lynett is.
21 you to give me a very good representative generic 21 A. In my opinion, he's the best Boussinesq
22 profile, and not then go back and say Make it higher or 22 modeler in this country.
23 make it lower. 23 Q. Was the computer file a COULWAVE file, an
24 So in the end, the particular profile, he 24 STWAVE file, some other file? What was it? An ADCIRC
25 said, "This is what I came up with. Here's what I came 25 file?
12 (Pages 42 to 45)
Page 46 Page 48
1 A. A COULWAVE file. 1 And then it became somewhat apparent, since I
2 Q. Now, go back to my question -- or variation 2 had done that same part for the IPET study, the
3 thereof. Anywhere in your report do you say that the 3 Interagency Performance Evaluation Task Force, that
4 COULWAVE generic profile came from or was created by 4 that should be me to do that. And so I said, "Okay, I
5 anybody other than you? 5 will do it."
6 A. No, I did not. I probably should have, but I 6 But at that point it was still left to me to
7 did not. I mean, it was -- it was -- we got the report 7 say how should it be done, you know, what are the
8 in at a short time before the deadline, and we were 8 elements of it.
9 pushing to do that. 9 Q. All right. Let's do this: Look at your
10 Q. Who gave you your assignment that you 10 report. You've got a copy in front of you.
11 described to me just a few moments ago? Taking the 11 A. Right, um-hum.
12 waves and convert the waves and so forth. Who actually 12 Q. What exhibit is it? Three?
13 gave you your assignment in connection with this 13 A. Yes.
14 litigation that resulted in the writing of the report? 14 Q. All right. Go to page 6, if you would.
15 A. I mean, I'm assuming that the Department of 15 A. Okay.
16 Justice did. I mean, we -- I have been in a lot of 16 Q. I believe I have it right.
17 meetings, and those meetings say, "Okay, who's going to 17 A. Um-hum. (Affirmative)
18 do what?" 18 MR. ROY: Well, the court reporter has got
19 Q. I don't want to know what your lawyers told 19 to change tapes. Let them change tapes, and I
20 you. 20 will save us time when we come back on.
21 A. Okay. Well . . . I'm not even looking at 21 Strike that question.
22 him. 22 VIDEOGRAPHER: Off record at 10:24 a.m.
23 Q. I understand. That's got to be a full-time 23 (OFF THE RECORD)
24 challenge. Right? 24 VIDEOGRAPHER: On record at 10:32 a.m.
25 A. Yeah, right. 25
Page 47 Page 49
1 Q. But, no. But, look, what I want to know from 1 BY MR. ROY:
2 you, Dr. Resio -- 2 Q. All right, we're back. Everybody's had a
3 A. Okay. 3 break and a cup of coffee. You're ready to proceed,
4 Q. -- is -- and if you can recall -- 4 Dr. Resio?
5 A. Um-hum. (Affirmative) 5 A. Yes, I am.
6 Q. -- was it somebody within the engineering or 6 Q. All right. In your report at page 5 -- I had
7 scientific team that you're involved with for this 7 earlier told you page 6. It's actually page 5.
8 litigation that actually said to you, "Resio, I want 8 A. All right.
9 you" -- or words to that effect -- "to take the waves 9 Q. At the top sentence, the top three lines,
10 and convert them," or whatever you described to me is 10 basically captures the spirit of what you told me a
11 your task. All right. Did anybody in the team tell 11 little bit earlier, taking waves and converting waves
12 you that? 12 where -- on the introduction, page 5 --
13 A. I think they asked me to. 13 A. I'm just reading.
14 Q. Somebody in the team? 14 Q. -- "The work described in this report was
15 A. Well, I mean, we had a -- you have to 15 undertaken to estimate the runup, setup, and
16 understand there's a lot of meetings that were taking 16 overtopping effects of waves on levees along Reach 2 of
17 place. 17 the Mississippi River Gulf Outlet, (Figure 1) for the
18 Q. I understand. 18 six scenarios described in Table 1."
19 A. Now, you're trying to reduce it to a black 19 Correct?
20 and white, did somebody just walk in my door one day 20 A. That is correct.
21 and said, "Do this." It somewhat evolved. 21 Q. All right. That's the general assignment you
22 They came in and they said, you know, "How 22 were given.
23 should we in fact give a good presentation of this and 23 A. That is correct.
24 who should do it?" Which is more, if you think about 24 Q. All right. Now, you are not a professional
25 it, the more logical way of approaching this. 25 engineer. Correct?
13 (Pages 46 to 49)
Page 50 Page 52
1 A. That's correct. 1 I'm not sure. When you say "environmental science," if
2 Q. You're not a licensed engineer. 2 you're talking about the biological aspect of
3 A. That's correct. 3 environmental science, then I am not a biologist.
4 Q. You're not a forensic engineer. 4 Q. Are you a coastal engineer?
5 A. That is correct. 5 A. I've published a lot in coastal engineering
6 Q. You're not a physicist. 6 topics, but I am not an engineer.
7 A. That is correct. 7 Q. Okay. If you could answer my question. Are
8 Q. You're not a geologist. 8 you a coastal engineer?
9 A. That is correct. 9 A. Well, if coastal engineering requires that
10 Q. You're not a statistician. 10 you be an engineer, then I am not a -- I was trying --
11 A. That is correct. 11 I was trying to answer it that I'm not a coastal
12 Q. You're not an oceanographer? 12 engineer if I'm not an engineer.
13 A. Well, that's -- I mean, I was a professor of 13 Q. Okay. Now, as were a number of your team,
14 oceanography. So you really have to -- 14 including Mr. Ebersole, Fitzgerald, Westerink, and
15 Q. All right. 15 others, you were involved with IPET. Is that correct?
16 A. I mean, I'm a member of the American 16 A. That is correct.
17 Meteorological Society. I have published a lot in 17 Q. In your report, page 4, paragraph 1, you say,
18 oceanography. Most people think of me as a physical 18 quote, "Recently I led the Interagency Performance
19 oceanographer. 19 Evaluation Task Force (IPET)."
20 Q. Okay. 20 A. Right. That's actually -- and I -- it should
21 A. So . . . 21 be Bob Dean and I. We were the co-leads of it. I
22 Q. That's -- that's what you think you are. I 22 should have said I co-led there.
23 mean, that's what you -- I don't mean that 23 Q. All right.
24 pejoratively. 24 A. That's a . . .
25 A. Right. 25 Q. And my point was going a little bit further
Page 51 Page 53
1 Q. But that's what you -- 1 into it, though.
2 A. Well, that's kind of where I think I fit in 2 A. Okay.
3 with the mold. 3 Q. Task 5A: "Analysis of wave and surge effects
4 Q. That's what I'm trying to figure is where -- 4 overtopping and related forces on levees during
5 where, if I can -- to put the label if I can. 5 Hurricane Katrina."
6 A. You just got a label. 6 A. That's correct.
7 Q. All right. Are you a meteorologist? 7 Q. All right. The appendices of that report,
8 A. I am a member of the American Meteorological 8 IPET, that reflected your specific work --
9 Society. I give papers. I just gave an invited paper 9 A. Um-hum. (Affirmative)
10 at their annual conference. So I'm -- I taught marine 10 Q. "Your specific," meaning you individually.
11 meteorology. So somebody thinks I'm a meteorologist. 11 A. Um-hum. (Affirmative)
12 Q. All right. So you feel you're an expert 12 Q. -- would that have been Volume IV, Appendix
13 physical oceanographer? 13 3, "Offshore Waves"? Would it have included that?
14 A. That's correct. 14 A. I had inputs to that. We -- we work as a
15 Q. An expert meteorologist. 15 team on this.
16 A. Marine meteorology. I'm not really big into 16 Now, the part that was directed -- and I
17 thunderstorms and things over land. 17 think it's important to the Offshore Waves was done as
18 Q. All right. Hydrologist? 18 part of task 4. All right. And this is -- you want
19 A. I studied it. I mean, that was part of all 19 the exact structure; I'm trying to give you the exact
20 of that environmental science training. I've done 20 structure. The regional hydrodynamics. And so the
21 court cases previously about flows through rivers back 21 Offshore Waves were done as part of the regional
22 when I was in my -- in -- so I have experience in it, 22 hydrodynamics.
23 but it's not my main specialization. 23 Q. All right.
24 Q. All right. What about environmental science? 24 A. And then when you got real close to the
25 A. That's such a broad topic. I mean -- I mean, 25 levees and in the canals, which is really where a lot
14 (Pages 50 to 53)
Page 54 Page 56
1 of the work I was doing -- 1 BY MR. ROY:
2 Q. Nearshore waves? 2 Q. That is Westerink and who?
3 A. Nearshore, right. 3 A. Oh, I'm sorry. You just handed me something
4 Q. Right. 4 that said "Offshore Waves." I thought you said
5 A. The -- the Boussinesq and the -- and the 5 "Surge."
6 STWAVES inside of canals and that sort of thing. 6 Q. Well, no, I had asked you that. Let's ask
7 Q. I think I've got a question you're leading 7 this question again.
8 into. 8 Appendix 3 --
9 A. Okay. 9 A. Right.
10 Q. IPET Volume IV, Appendix 4, "Nearshore 10 Q. -- "Offshore Waves" --
11 Waves" -- 11 A. Right.
12 A. Right. 12 Q. -- which I've handed to you --
13 Q. -- would that have been your primary result 13 A. Okay.
14 of task 5A? 14 Q. -- which is Exhibit 5 --
15 A. I would have to look at -- do you have it? I 15 A. Right.
16 mean -- 16 Q. -- who led that? What task was that part of?
17 Q. Yeah, I do. 17 I understood you to say task 4.
18 A. -- it's such a massive thing. I don't know 18 A. Yes, it is. It's task 4, but it's not
19 where everything ended up. 19 Westerink's work. It -- the "Offshore Waves" was not.
20 Q. Certainly -- certainly, you don't think I 20 Q. And so who handled this task?
21 wouldn't have one? 21 A. Ebersole.
22 A. I don't know. I mean, I -- I have a feeling 22 Q. Ebersole.
23 that this is still STWAVE runs; in which case, then it 23 A. The people who did -- he was, again, the --
24 was still part of what we did as the regional. But I 24 it's a team, so he got -- he didn't do the runs or
25 don't want to speculate on that. 25 anything.
Page 55 Page 57
1 Q. All right. I'll mark IPET Appendix 4 1 Q. I got you. Okay.
2 Nearshore Waves as Resio 4 for you to look at. 2 You can set that down right there. That's
3 (EXHIBIT 4 MARKED) 3 good.
4 A. This was still done under the -- wait, wait, 4 A. Okay.
5 wait. I started to say that. 5 MR. ROY: And Appendix 5, which I'll mark
6 BY MR. ROY: 6 as Exhibit 6.
7 Q. There's references to STWAVES. 7 (EXHIBIT 6 MARKED)
8 A. Yes. This is still done as part of what was 8 BY MR. ROY:
9 done under the regional team. 9 Q. Appendix 5 of IPET, this was "Storm Surge,"
10 Q. All right. Which is part of task 4. 10 and that's what you said was Westerink's.
11 A. That is correct. 11 A. That is specifically what Westerink did, yes.
12 Q. All right. What about Appendix 5, "Storm 12 Q. All right. Now, so which -- where are your
13 Surge"? 13 results reported?
14 A. No. That was done by Professor Westerink. 14 A. In the main text. I believe there's some --
15 Q. All right. So who -- let's back up here. 15 I would -- if you -- I mean, if you show me the whole
16 Who led the Appendix 3, "Offshore Waves"? 16 thing, I'll show you where it is.
17 A. That was Ebersole and Westerink. 17 Q. All right.
18 Q. All right. 18 A. But I -- yeah, it's all -- it's all of the
19 A. They're co-leads on that. 19 Boussinesq runs, the overtopping, and all of those
20 Q. So we're talking about the same thing, I'm 20 estimates that are made. The same type of thing I'm
21 going to mark that specific -- 21 doing here. If you want to hand that to me, I can --
22 MR. ROY: All right. So Exhibit 3 of IPET 22 Q. Right. I will. Would it be in Volume IV?
23 I've marked as Exhibit 5. 23 A. It should be in Volume IV. Unless they did
24 (EXHIBIT 5 MARKED) 24 it different than I thought they were doing it.
25 25 Q. All right.
15 (Pages 54 to 57)
Page 58 Page 60
1 MR. ROY: For purposes of this deposition, 1 the canals to try to resolve the specific problems
2 I'm going to mark it as Exhibit 7. 2 there; whereas, the regional people were getting us the
3 (EXHIBIT 7 MARKED) 3 boundary conditions that we used.
4 A. Right. Okay. This is the main text of the 4 Q. Right. When you talk about canal in the
5 storm. 5 context you've just used it, you're referring to the
6 Okay. All of this part here about the London 6 17th Street Canal?
7 Avenue -- I mean, you want -- where do you want me to 7 A. Well, we did all of them. We did the IHNC,
8 say about which part? 8 we did the GIWW.
9 BY MR. ROY: 9 Q. Okay.
10 Q. All I want to know is where -- 10 A. They're not specific canals. But all of the
11 A. I can give you -- 11 waves and surge -- you know, all the waves in there, we
12 Q. I don't need page by page at this point. 12 did. And all the waves in the London Avenue, 17th
13 A. Okay. 13 Street, IHNC, and -- shoot, I forgot. We did those,
14 Q. All right. We'll come, perhaps, to that 14 yeah.
15 later. 15 Q. We're here today to talk about the IHNC, the
16 A. Ballpark, I can see that most of my stuff 16 GIWW, and the MRGO.
17 cuts in about page 200-ish and goes to the end of the 17 A. Right, right.
18 report. 18 Q. To the extent your work is relevant.
19 Q. All right. 19 A. Okay.
20 A. So 200 to about 250 or so. 20 Q. All right? Now, let me ask you: Physical
21 Q. All right. So Resio No. 7 -- 21 modeling, what is physical storm surge and wave
22 A. Right. 22 modeling? Physical.
23 Q. -- from about pages 200 to 250 -- 23 A. It's building of a model out of concrete and
24 A. Right. 24 putting a wave generator that makes little waves to
25 Q. -- is basically the conclusion of your 25 scale. Everything is supposed to be scaled very
Page 59 Page 61
1 specific wave-oriented work, if you will -- 1 precisely. So we built a very carefully constructed
2 A. Right. 2 replication of the 17th Street area. And that's on
3 Q. -- of Volume IV of the IPET report? 3 site here if you want to see it.
4 A. That is correct. 4 Q. We may do that if Robin lets us. But I'm
5 Q. Fair enough. Just set that right there. 5 sure that is fascinating to see.
6 Thank you very much. 6 But is it correct thus far a scale physical
7 Now, in an early draft of the assignments, 7 model for these purposes of the MRGO has not been
8 where it shows you as a co-leader of task 5A, the 8 recreated?
9 actual assignment was "Storm Surge and Wave Physical 9 A. Right, yes, yes. Sorry. Yeah. I mean, I
10 Model - Hydrodynamic Forces." 10 don't know -- we didn't do it.
11 Do you recall that, by any chance? 11 Q. That's what I'm asking you.
12 A. I do, actually. 12 A. We -- as part of that, we did not do a
13 Q. All right. Did that assignment ever change? 13 physical model.
14 A. Well, it broadened. We -- you know, this 14 Q. To the best of your knowledge --
15 was -- you do what you have to do to get the product 15 A. Right.
16 people need. You can't -- you know, that -- you know, 16 Q. -- no physical model has been constructed or
17 people don't bother, as we're doing here, to write 17 physical modeling of storm surge and wave effects along
18 everything down in a lot of detail. You write down 18 the MRGO has been done.
19 enough to convey the gist of it and move on. 19 A. None that I've done, and I'm not aware of
20 We did do a physical model and we reported on 20 anybody else. But if they have --
21 it, and that was on waves in the -- but it was specific 21 Q. That's all I was trying to get to.
22 to the 17th Street Canal. We did do studies of surges 22 A. Okay.
23 inside the canals. We did do a lot of the detail -- 23 Q. Same question for the GIWW, Reach 1 portion
24 this was the whole point was we were the people doing 24 of the MRGO.
25 the real detailed work close to the structures inside 25 A. Right.
16 (Pages 58 to 61)
Page 62 Page 64
1 Q. The same answer would be correct. 1 MR. SMITH: Yes.
2 A. That is -- 2 BY MR. ROY:
3 Q. Correct? 3 Q. All right. Using H1 or H2 or H3 or H6 -- I
4 A. -- right. Right. 4 don't care.
5 Q. All right. Now, you, in connection with your 5 A. Okay.
6 work for your report, you yourself ran no ADCIRC 6 Q. Any one of them. Let's say H1 -- wherever
7 modeling. Is that correct? 7 assumption -- regardless of what aspect of output is
8 A. That is correct. 8 generated or displayed, is it your understanding that
9 Q. Whatever ADCIRC modeling you relied upon or 9 the inputted information, whether it was adjusted or
10 ADCIRC outputs you relied upon, you got from Westerink. 10 not -- I'm calling those assumptions.
11 A. That is correct. 11 A. Okay.
12 Q. Now, in your report -- and I'm sure you'll 12 Q. -- remained constant?
13 correct me if I'm wrong, as well you should. But in 13 A. I mean, I think so, but, I mean --
14 your report, as near as I can tell, wherever you make a 14 Q. That's all you can answer.
15 reference to an ADCIRC output or showing an ADCIRC 15 A. Okay.
16 output, whatever, the impression, at least, is that it 16 Q. That's all you can --
17 is from a single run. 17 A. I mean, I probably should just say I'm not
18 A. I did not intend to give that impression. If 18 sure.
19 I gave that impression, it -- I mean, it was from 19 Q. But --
20 whatever number of runs needed to be made. I know we 20 A. I mean, I would hope that you would ask
21 considered six different scenarios, so I'm sure there 21 Professor Westerink that question.
22 had to be, at least, a minimum of six runs. And so I'm 22 Q. All -- we have.
23 not sure. 23 A. Okay.
24 Q. All right. And when -- good point. You're 24 Q. And I know what he said, but I don't think at
25 talking about the base case -- 25 this time it's appropriate for me to share that with
Page 63 Page 65
1 A. Um-hum. Right. 1 you.
2 Q. -- the no MRGO, the six or so scenarios. 2 A. Okay.
3 A. Right, right, right. 3 Q. I need to know what you thought.
4 Q. Right. And, of course, each, presumably, had 4 A. Okay.
5 some kind of a different run. 5 Q. That's all I want to know.
6 A. Right. 6 A. Right. Okay.
7 Q. But in terms of underlying baseline 7 Q. There's no right or wrong answer here.
8 information for still-water levels, boundary 8 Okay. As far as your assumption was --
9 conditions, tides, this sort of stuff, to your -- best 9 A. Right.
10 of your knowledge, that was one uniform constant 10 Q. -- was that you were dealing with a uniform
11 throughout all of them. Is that right? The starting 11 set of inputs. Correct?
12 point. Other than the physical geography. 12 A. A uniform set of -- I mean, the surges came
13 A. I mean, I -- if you're saying did -- does 13 from -- from a uniform run? I'm just trying to
14 Johannes Westerink, when he's running a model, have 14 rephrase it to make sure I'm understanding.
15 internal boundary conditions, I don't think he does. 15 Q. Sure. If -- do you have an understanding as
16 Q. Let me -- no, no. 16 to -- tell you what: Let's use a for an example.
17 A. I'm missing -- I'm missing -- I'm sorry. I 17 A. Okay.
18 -- 18 Q. Still-water height, does that have -- is that
19 Q. Between -- 19 a term of art as far as you know, in -- in
20 A. Yeah. 20 Dr. Westerink's?
21 Q. Well, let's take scenario 1, however that's 21 A. He uses that. He uses still water.
22 referred to. I think it's H1 by the government team. 22 Q. That's one of the inputs. Right?
23 A. Right. 23 A. He -- it comes out of his model.
24 MR. ROY: Robin, is that correct, so I 24 Q. All right.
25 don't get the terminology wrong? 25 A. So I'm trying to figure out, when you are
17 (Pages 62 to 65)
Page 66 Page 68
1 calling it input, are you talking about an input to me 1 information available to me.
2 or an output -- I mean, it's an output from him. 2 Q. So you relied, then, upon Dr. Westerink to
3 Q. Very good point on semantics. 3 put the appropriate inputs, if any, for bathymetry for
4 A. Yeah. 4 the ADCIRC modeling?
5 Q. Thank you. We'll come back to this. 5 A. Right.
6 A. I'm sorry. I really am -- I just want to 6 Q. Surge fields. Correct?
7 make sure I give you exactly what you're asking for and 7 A. That's right. He -- that was his end of
8 not mislead you to some other conclusion. 8 that.
9 Q. Let's go through some specific statements. 9 Q. Winds?
10 In your expert report at page 5 -- 10 A. Winds really didn't come from him. As I
11 A. Okay. 11 said, I don't think he's an expert in winds. So I
12 Q. -- the statement is made: "The ADCIRC models 12 think I'm probably closer to an expert in winds. But
13 used here are described in Westerink (2008)." 13 I've looked at the winds already.
14 That's what it says in your report. 14 Q. But didn't the ADCIRC modeling, one of the
15 A. That is right. That was -- that is exactly 15 major inputs is winds?
16 my understanding. 16 A. Oh, absolutely. He didn't generate those
17 Q. Is that a true statement? 17 winds, though.
18 A. To my knowledge, yes. 18 Q. Okay.
19 Q. All right. That's what you understood to be 19 A. So I don't want to -- I want to make sure you
20 correct. 20 understand that you really should not consider
21 A. That's right. 21 Dr. Westerink as the expert for the wind input on
22 Q. Now, what is "Westerink (2008)"? 22 this -- for the wind fields, excuse me.
23 A. That is where they -- that's his final 23 Q. But my point is: To the extent you relied
24 report. 24 upon ADCIRC modeling from Dr. Westerink, you relied
25 Q. Okay. So how did you know, if you have not 25 upon whatever wind inputs he put in.
Page 67 Page 69
1 read his report, that the ADCIRC model runs used in 1 A. That is correct. Absolutely correct.
2 your report are described in Westerink's report? 2 Q. Whatever surge fields he put in.
3 A. That's an excellent point. But we were 3 A. He produced. The surge fields he -- output.
4 writing them at the same time, so I had to trust, if he 4 So yes.
5 said he was going to put it there, that he indeed was 5 Q. Well, both. Whatever his inputs were and
6 going to put it there and did put it there. 6 whatever his outputs --
7 Q. And that's a fair answer. So you got it from 7 A. Whatever the -- okay. We're quibbling, so --
8 him. He said, "These are in my reports." 8 Q. True for bathymetry, surge fields, and wind?
9 A. Right. 9 A. That is correct.
10 Q. That's the way you referenced them. 10 Q. Whatever Westerink inputted and outputted to
11 A. That is correct. 11 you, you relied upon.
12 Q. All right. Now, at page 5 of your report, 12 A. That is precisely true.
13 the next sentence, I believe, says, "These runs provide 13 Q. All right. Good enough.
14 water surface elevations at half-hour intervals over 14 Now, within -- well, let's back up.
15 the duration of Hurricane Katrina for each of the 15 Did Dr. Westerink himself actually nest the
16 scenarios considered." 16 STWAVE onto the ADCIRC modeling, or was that something
17 That's correct. 17 done by another person in your team?
18 A. That is correct. 18 A. Jane Smith was -- is the -- our best --
19 Q. Did you make that observation by reading the 19 excuse me -- our best STWAVE modeler, and we had her do
20 ADCIRC graphs that he gave you? 20 it. She is -- at this point, she's probably more the
21 A. By the files. The computer files that I got 21 developer of -- I developed the initial code. She has
22 from him covered that amount of time. 22 now taken it and made it her own, and she is now the
23 Now, I mean, presumably, he -- you know, if 23 person who does more with STWAVE than I do.
24 he had it in my area, he had it elsewhere. But I was 24 Q. Okay. All right. And then you've got the
25 interested in, relative for my purpose, I had that 25 STWAVE superimposition on Westerink's ADCIRC.
18 (Pages 66 to 69)
Page 70 Page 72
1 A. Right. 1 I saw no reason to go back and recreate it.
2 Q. So it's coming to you. Now it's time to do 2 Q. Was it produced -- was it originally produced
3 your COULWAVE? 3 in Texas by whomever this person is for the MRGO?
4 A. Yes, right. 4 A. Yes, yes. But it totally had nothing to do
5 Q. All right. And we're going to get into great 5 with -- it was a while -- I mean, it was produced -- I
6 depth on COULWAVE. 6 had this before we even went into any of this stuff. I
7 A. Okay. 7 had -- I had all of the inputs from him that I ended up
8 Q. But who actually did your COULWAVE modeling? 8 using a year and a half ago? Maybe -- I mean, I'm
9 A. It was done -- it is -- it's sort of funny. 9 trying to guess. Which is well before I got involved
10 It's -- 10 in this.
11 Q. For this report. 11 Q. All right. So, then, to the extent and for
12 A. For this report. All of the runs were done 12 purposes of this question --
13 on a generic profile, not specifically for this report 13 A. Um-hum. (Affirmative)
14 but for just to be used in any application by Pat 14 Q. I'm just asking to the extent --
15 Lynett. 15 A. Um-hum. (Affirmative)
16 In other words, it's generic. So if you've 16 Q. -- there may be any substantial errors in the
17 got a stretch somewhere that looks a bit like this, 17 data that Dr. Westerink furnished you, either as a
18 then we can use this -- this tool. And the idea was to 18 result of erroneous input or erroneous adjustment --
19 be able to interpolate and get data you needed without 19 A. Okay.
20 having to keep running very tedious slow models. 20 Q. -- this could affect your ultimate
21 Q. At page 6 of your report, you make the 21 conclusions. Correct?
22 statement: "The COULWAVE model estimates velocities on 22 A. It could affect the overtopping rates as --
23 the levees, wave setup, and overtopping rates for water 23 as I would -- is my conclusions?
24 passing over the levee crest." 24 Q. Well, it could also affect the COULWAVE
25 A. That's correct. 25 modeling because --
Page 71 Page 73
1 Q. "These estimates have been provided to the 1 A. Yeah. But that predicts the -- I mean, I'm
2 interior drainage group (Fitzgerald, 2008) and the 2 trying to just be real specific. My conclusions, I'm
3 levee erosion group (Ebersole, 2008) and used by them 3 not sure that --
4 in their breach and flooding modeling." 4 Q. Fair enough. Let's back up.
5 A. That's correct. 5 A. Yeah.
6 Q. That's true, isn't it? 6 Q. It all starts with Westerink's ADCIRC.
7 A. That is -- yes, yeah. That is true. 7 Correct?
8 Q. Okay. So Jane Smith did the STWAVE. Someone 8 A. Yes. Well, it starts with the winds. The
9 else did the COULWAVE. 9 winds always start it in these. And a lot of people
10 A. Um-hum. (Affirmative) 10 skip that part, and that's their -- that is extremely
11 Q. Did -- you, apparently, then, did not 11 bad.
12 supervise this COULWAVE that was done by this person 12 Q. But the winds are built into and inputted
13 over in Texas, then. 13 through ADCIRC?
14 A. No, no. I certainly have done some -- some 14 A. Yeah, this is true. But he didn't develop
15 runs and things, but I don't need to supervise him. 15 them. He got the winds elsewhere.
16 Q. Okay. But so you did your own COULWAVE runs 16 Q. We had this discussion --
17 here on this -- for your -- 17 A. That's a very important point.
18 A. No. No, no, no. No. 18 Q. We've had it the second time today. All
19 Q. All right. Well, I'm talking about your 19 right. I understand. But you also told me that, to
20 report. 20 the extent you relied upon what that information was,
21 A. No. For this report I relied on something 21 it came to you through and part of ADCIRC.
22 that already existed -- 22 A. That is exactly right, yes.
23 Q. Okay. 23 Q. All right. So for whatever work and
24 A. -- that had been produced for a different 24 conclusions you ended up reporting in your expert
25 purpose that is very related to this, but it was not -- 25 report --
19 (Pages 70 to 73)
Page 74 Page 76
1 A. Right. 1 Q. I got you.
2 Q. -- were based upon a foundation of 2 Are you an ADCIRC modeling expert?
3 Westerink's ADCIRC results. 3 A. Not an expert, no.
4 A. Right. 4 Q. All right.
5 Q. And for STWAVE to be superimposed -- 5 A. I have taught numerical modeling of surges,
6 A. Right. 6 but I am not an expert at ADCIRC.
7 Q. -- regardless of whether it's by Jane Smith 7 Q. Let's talk about STWAVES specifically. As I
8 or whomever -- 8 appreciate it, you're the father of the STWAVE model.
9 A. Right. 9 Is that correct?
10 Q. -- for those results to be valid -- 10 A. Yes.
11 A. Um-hum. (Affirmative) 11 Q. All right. You developed it in -- was it the
12 Q. -- you need valid ADCIRC foundational coming 12 early '90s?
13 out of Westerink. Correct? 13 A. '88 was the first publication on it.
14 A. To be perfectly -- I mean, AD- -- I mean, I 14 Q. All right. And you either authored or
15 know where you're going with this, but it's a -- 15 co-authored the STWAVE manual, user manual. Is that
16 accuracy is relative. 16 right?
17 Q. You can explain it, Doctor. But as a general 17 A. That is correct.
18 principle, that is a true statement. 18 Q. STWAVE, as an overlay or nesting into the
19 A. As a general principle, good input makes good 19 ADCIRC modeling, is the second step of the foundation
20 output. 20 that you have to build in order to be able to then come
21 Q. All right. So as a general principle, then, 21 over and superimpose the COULWAVE. Right?
22 if Dr. Westerink's ADCIRC had nonaccurate -- 22 A. That is correct.
23 A. Um-hum. (Affirmative) 23 Q. And it's the COULWAVE itself that you rely
24 Q. All right. -- output -- 24 upon to tell us or opine in your expert report what
25 A. Yes. 25 velocities were of the --
Page 75 Page 77
1 Q. -- to you -- 1 A. Right.
2 A. Right. 2 Q. -- water at the front, top, and back side of
3 Q. -- that was relied upon for ultimately the 3 the levees. Is that correct?
4 STWAVE modeling or the COULWAVE modeling -- 4 A. I don't think I have front in there. I
5 A. Right. 5 believe I have crest and back side.
6 Q. -- the results of those -- 6 Q. Okay.
7 A. Um-hum. (Affirmative) 7 A. I believe.
8 Q. -- could be altered? 8 Q. I believe you're right.
9 A. Yes. And the point I'm trying to make sure 9 So we're absolutely clear, you have not
10 you understand is that it will alter velocities; it 10 expressed an opinion anywhere in your expert report
11 will alter overtopping. The question whether it alters 11 addressing velocities of water or waves on the MRGO
12 the overall consequences or the conclusions, it might 12 side or Lake Borgne side of the Reach 2 earthen berms
13 not. It might or might not. 13 or levees. Correct?
14 Because if, in fact -- what I've tried to do 14 A. In my -- in my report, I did not do that.
15 in mine is to -- in my approach is to consider the 15 Q. That's all I'm asking about is your report.
16 variability in all of the things. I consider uncertain 16 A. That is correct.
17 to be -- uncertainty to be a big issue that we had to 17 Q. This is the only report you've written, isn't
18 deal with, and, therefore, I -- I have some low places 18 it?
19 in my levees, some high places in my levees. A lot of 19 A. Oh, no. There's IPET, where there are some
20 people -- 20 front-tide velocities on -- on the IPET.
21 Q. We're coming to them. 21 Q. We're going to come to that.
22 A. Okay. A lot of people try to represent 22 A. Okay.
23 everything by one value -- 23 Q. But aside from IPET, for this case --
24 Q. I got you. 24 A. Okay.
25 A. -- and you just can't do that. 25 Q. -- for this litigation, the report here --
20 (Pages 74 to 77)
Page 78 Page 80
1 A. Yes. 1 United States Army Corps of Engineers, Research --
2 Q. -- that's been identified as Exhibit 3, is 2 Engineer Research and Development Center STWAVE Users
3 the only report you've issued. 3 Manual for STWAVE, Version 3.0.
4 A. That is correct. 4 A. (Reviews document) Yeah, it looks like it.
5 Q. All right. So -- and there are no opinions 5 Yes, it is. I'll just say it is.
6 expressed on velocities of wind or wave or surge on the 6 Q. Is that what that is?
7 front side, that is, the MRGO or Lake Borgne side, of 7 A. Yes, it is.
8 the Reach 2 earthen berm or levees? 8 Q. All right. Now, according to the website
9 A. In this report, that is correct. 9 that we accessed and referenced, this is the latest
10 Q. Is the same true for Reach 1, the -- that 10 user manual that's publicly available. Are you aware
11 would be the Gulf Intracoastal Canal/MRGO side of 11 of anything to the contrary? When I say "publicly
12 the -- 12 available," publicly available --
13 A. That is the -- I mean -- 13 A. On a website. Available on a website. I
14 Q. -- Reach 1 levee? 14 understand what you're saying.
15 A. Yes. There is only Reach -- only these 15 Q. That's --
16 numbers 1 through 21 here, and that has only crest and 16 A. I don't keep track of what's available on our
17 back side information on velocities. 17 website. So if you're saying this is what's available
18 Q. On Reach 2? 18 on our website, then I'm -- I trust that you're right.
19 A. On Reach 2. 19 Q. Well, this truly is not a trick question.
20 Q. All right. You would agree that STWAVE is 20 Your -- the intent --
21 one of a series of wave models that are used throughout 21 A. Yeah.
22 the world to produce estimates of wave overtopping and 22 Q. -- of you and this organization --
23 velocities? 23 A. Um-hum. (Affirmative)
24 A. No, STWAVE does not do wave overtopping. 24 Q. -- is to make this an openly available tool
25 COULWAVE would do overtopping. 25 for anybody that wants to use it.
Page 79 Page 81
1 Q. All right. Well, let's go to your page 29 of 1 A. Right.
2 your report. 2 Q. Anywhere.
3 A. Okay. 3 A. This is true.
4 Q. And I'm going to try to find the exact 4 Q. Which is why the manual is published openly
5 location myself. For clarification, go to page 29, the 5 on the Internet.
6 first sentence. 6 A. Right.
7 A. Okay. 7 Q. All right. You helped write this user
8 Q. Where you've got "This section is a 8 manual. Is that correct?
9 description of the series of wave models used to 9 A. Yes, I did.
10 produce estimates of wave overtopping and the 10 Q. Now, go to page 31 of your report.
11 velocities of the Reach 2 levee." 11 A. Okay.
12 A. Um-hum. (Affirmative) 12 Q. The first full paragraph reads: "STWAVE can
13 Q. I actually -- I believe I misconstrued that 13 be implemented as either a half-plane model, meaning
14 when I was beginning to ask you the question. 14 that only waves propagating toward the coast are
15 A. Okay. 15 represented; or a full-plane model, allowing generation
16 Q. When you're talking about wave models, you're 16 and propagation in all directions. Wave breaking in
17 referring to both STWAVE and COULWAVE? 17 the surf zone limits the maximum wave height based on
18 A. That is correct. 18 the local water depth and wave steepness."
19 Q. All right. I apologize for my confusion. 19 Correct statement in your report?
20 A. It's easy to happen on these things. 20 A. Yes.
21 Q. Let's look at the user manual. 21 Q. All right. I'm trying to understand how it
22 MR. ROY: I'll mark this as Exhibit 8. 22 works with writing within the Corps of Engineers,
23 (EXHIBIT 8 MARKED) 23 whether it's manuals, other documents, or whatever.
24 BY MR. ROY: 24 That actually is also a direct quote from an
25 Q. And ask you to please identify that as the 25 article written by Jane Smith, "Modeling Nearshore
21 (Pages 78 to 81)
Page 82 Page 84
1 Waves for Hurricane Katrina." And the question to you, 1 Q. You make the statement at page 24 of your
2 I guess, is: Are you familiar with her article 2 report: "It has been widely established in the
3 where -- I'll show it to you. 3 literature that monochromatic waves do not produce the
4 MR. ROY: Exhibit 9. 4 same results for runup and wave heights incident on a
5 (EXHIBIT 9 MARKED) 5 slope."
6 A. Do you know where this was published? Was 6 A. That's correct.
7 this the casting and forecasting? Do you know where 7 Q. Do you cite at that place or anywhere in your
8 this was -- 8 report what widely established literature,
9 BY MR. ROY: 9 peer-reviewed literature, you're referring to?
10 Q. All I have is exactly what's before you. 10 A. I don't think I do here. I mean, I -- maybe
11 A. Do you know where you got it? Because there 11 I should have. There's certainly ample --
12 was a conference in Hawaii that -- that this could have 12 Q. Well, let's assume for the sake of this
13 been from. If it's -- if it was produced there, then 13 question that it is true.
14 I'm familiar with it. I mean, you're asking me if I'm 14 A. Okay.
15 familiar with it. I sat through the briefing on it 15 Q. Is the same true without a slope, that is, a
16 if -- if it was that. 16 perfectly flat surface?
17 Q. I don't know where it came from. It has come 17 A. How technical do you want to get on this?
18 in our possession from one of these -- 18 Q. All I want to know is: Is the same true?
19 A. Okay. 19 Will it produce the same results for --
20 Q. -- sources, Internet or otherwise. 20 A. Well, you're saying --
21 A. I can certainly find out where it was 21 Q. -- runup and wave heights?
22 published, and it looks familiar with -- with my 22 A. You're saying "runup," and then you're saying
23 understanding of what she's doing -- of what she was 23 on a flat slope.
24 doing for the Katrina waves. 24 Q. Well, your point is --
25 Q. Well, when articles are published internally 25 A. Is it a runup or flat slope --
Page 83 Page 85
1 here, is there a repository for them? 1 Q. Well, your point is you can't have a runup on
2 A. No. 2 a flat slope. That's your point.
3 Q. Okay. I guess I'm just asking you about the 3 A. Yes. Right. And that's what I'm saying. My
4 coincidental -- 4 point is the waves behave differently -- monochromatic
5 A. Sure. 5 waves behave fundamentally different than spectral
6 Q. -- verbatim language. 6 waves for a number of reasons. It has to do with the
7 If you go to -- on the right-hand column of 7 nonlinearities inherent in the interactions between the
8 that article, the second full paragraph -- let's see. 8 components.
9 Wait a minute -- second full sentence, starting "STWAVE 9 And that being said -- and the other main
10 can be implemented either as" -- it appears to be 10 difference is that monochromatic waves, anybody that's
11 verbatim, the same as your report. 11 ever stood at a beach sees it's not constant waves
12 A. Okay. 12 coming in. You have big waves come in; you have little
13 Q. And I was just wondering at the coincidence 13 waves come in. So, because of that, the breaking
14 at that. 14 begins much farther off the coast with irregular wave
15 A. Well, I'm sure that -- that Jane was 15 breaking.
16 certainly contributing to this, so Jane did a lot of -- 16 For monochromatic waves, the same wave every
17 contributed to some of this material here. And when 17 time, it always breaks the same place. Those big waves
18 she would send me snippets and things, then I would 18 break farther off in -- in nature.
19 take them. 19 Q. We're -- we're perhaps getting ahead of
20 So it's not a surprise that -- that there are 20 ourselves here.
21 some things where I said, "What did you do to do the 21 A. I'm sorry.
22 model setups?" And she said, "Here's what I did to do 22 Q. No, no.
23 the model setups." And I said, "All right." 23 A. That's why I was asking how technical you
24 So I don't think it's a surprise at all that 24 wanted to get.
25 there's some commonality in it. 25 Q. I'm getting ahead of myself here.
22 (Pages 82 to 85)
Page 86 Page 88
1 A. Okay. 1 that's probably up and down all day. You see it on a
2 Q. But I want to ask you about three terms. 2 quay wall or something where it just goes up and down,
3 A. Okay. 3 and the same thing on any slope. Wave runup is this
4 Q. "Runup, overtopping, setup" on a levee. 4 passage up and down the slope. What you described was
5 A. Okay. 5 wave breaking, which is a different process.
6 Q. "Runup" and "setup" are two terms that you're 6 Q. So what do you call the water from the wave
7 familiar with and use in your analysis of wave and 7 that travels from the edge of the surface of the flat
8 surge. Correct? 8 land inland? Before it hits anything.
9 A. Yes. 9 A. I mean, to me that's wave propagation.
10 Q. Is that right? 10 Q. All right. Fair enough. I just want to be
11 A. That's correct. 11 sure we had the same semantics.
12 Q. How would you describe runup? 12 A. Okay. Okay. We've got -- that's wave
13 A. Runup is the up-and-down passage of the -- 13 propagation of wave energy. If there's wave energy
14 call it the lip, call it the wetted surface of the wave 14 left out of a part that broke, it will propagate it as
15 as it goes up and down the surface that it is running 15 a wave. The part that broke is going to be lost to the
16 up on, that it is passing onto. 16 wave field.
17 Q. What do you call it when the lip of the 17 Q. All right. And as the wave continues to
18 surface is first breaking over a long flat surface, but 18 deteriorate on that flat surface as it comes in over
19 the water level, the still-water level, has not risen 19 the dry shelf that the wave has gotten wet --
20 to the point, the surge has not risen to the point, 20 A. Um-hum. (Affirmative)
21 such as to completely inundate the flat shelf? 21 Q. -- it's going to degrade the force and energy
22 A. Are you asking whether they call it if it 22 in the wave.
23 runs over the crest? 23 A. I mean, you're assuming that there's no
24 Q. No, sir. 24 stable -- I mean, most -- most wave heights go to some
25 A. I'm -- 25 stable limit, you know. And once you get down to that,
Page 87 Page 89
1 Q. If -- if -- 1 it's not going to -- there's no particular reason it's
2 A. Okay. 2 going to keep getting less if you're on a glass bottom.
3 Q. -- this table is -- let's -- let's use an 3 And I'm assuming you're saying a frictionless --
4 absurd length to illustrate my point -- 100 miles long. 4 Q. Right.
5 A. Okay. 5 A. -- idealized situation.
6 Q. Perfectly flat and made of glass. 6 Q. Right.
7 A. Right. 7 A. So -- so there should be a -- a wave that
8 Q. There's no surface like that in the world, 8 would be quite stable there.
9 but I'm making my point for a reason. 9 Q. All right. If you put vegetation on this
10 A. Okay. Right, right. 10 infinite flat surface, with the wave breaking over
11 Q. All right. If a wave breaks from the ocean 11 it --
12 at the edge of the table -- 12 A. Um-hum. (Affirmative)
13 A. Um-hum. (Affirmative) 13 Q. -- the friction is going to retard the
14 Q. -- and a wave falls onto this perfectly flat 14 distance the wave can travel. Correct?
15 surface -- 15 A. Yes. You have now introduced a -- a new
16 A. Um-hum. (Affirmative) 16 source term.
17 Q. -- what do you call it in your area of 17 Q. Friction.
18 expertise, the running of the water as it comes inland, 18 A. And, yes, that would have that effect.
19 as it runs down this perfectly flat piece of land? 19 Q. Friction is the source term. Correct?
20 A. That was wave breaking. Nothing more, 20 A. That is correct.
21 nothing less. Now, that particular -- that is not to 21 Q. All right. And whether it is a coefficient
22 be confused with wave runup because, I mean, that was 22 of friction for sand, concrete, gravel, grass, bushes,
23 -- waves can actually run up on a surface without 23 tall bushes, trees, tall trees, thick trees, dense
24 breaking. 24 trees, but as the progression may go --
25 I mean, you -- I mean, you can have waves 25 A. Um-hum. (Affirmative)
23 (Pages 86 to 89)
Page 90 Page 92
1 Q. -- each has an increased effect in breaking 1 MR. WOODCOCK: Yeah. I think we -- do you
2 wave height and energy. Correct? 2 want to write right on it?
3 A. And dissipating energy. 3 MR. ROY: Yeah. I mean, just write across
4 Q. Yes. 4 the margin on each --
5 A. And again, you don't want to mix this with 5 MR. WOODCOCK: -- "Subject to Protective
6 breaking. That's why you -- that's why I just wanted 6 Order"?
7 to -- 7 MR. SMITH: Put "Confidential."
8 Q. I'm sorry. Dissipating energy. 8 MR. WOODCOCK: Confidential?
9 A. Yes. 9 MR. SMITH: "Subject to Protective Order."
10 Q. Thank you for correcting me. 10 MR. ROY: If you would write the same
11 So my statement is correct: For dissipating 11 thing across one of the margins close to the text
12 energy of waves? 12 coming up the side of it.
13 A. Friction dissipates energy, yes. From waves 13 VIDEOGRAPHER: On record 11:31 a.m.
14 is one of the specific cases. 14 THE WITNESS: We're planning on maybe
15 Q. In your report, which model did you rely 15 about another hour before -- before lunch?
16 upon to calculate runup on the levee of waves, or was 16 MR. ROY: If that works for you. Robin,
17 that furnished to you by somebody else? 17 if it's all right with you, is that cafeteria
18 A. It was implicit in the material that was 18 open for lunch? Can we --
19 given to me by Professor Lynett before this started, 19 THE WITNESS: Yes, it is.
20 before this effort started. I had asked him to do that 20 MR. ROY: We don't have to take a whole
21 for exactly this reason. 21 hour.
22 Q. So -- all right. And for overtopping, would 22 MR. SMITH: Whatever Don wants. If he
23 the same be true? 23 wants to come back sooner, we'll come back
24 A. It is, yes. 24 sooner.
25 Q. And for setup, would the same be true? 25 THE WITNESS: Half an hour? Is that what
Page 91 Page 93
1 A. Well, I mean, some setup comes from STWAVE, 1 you were thinking?
2 and some setup -- additional setup -- comes from the 2 MR. ROY: Well, I don't want you to
3 Boussinesq model. 3 exhaust yourself. Whatever works.
4 Q. Well, in your report, did you rely upon both 4 THE WITNESS: I do appreciate it.
5 STWAVE and SWAN for your setup on the levee of the 5 MR. ROY: As fast as we can eat and get
6 waves? 6 back over here, and everybody's all right. I
7 A. You said "SWAN." Did you mean to say "SWAN"? 7 mean, we only have to walk 50 feet to the --
8 Q. Yes. 8 THE WITNESS: Right. I was just asking
9 A. I don't think we used SWAN, no. 9 if, ballpark, a half an hour sounded about right.
10 Q. You're right. I didn't mean to use it. 10
11 COULWAVE. 11 MR. SMITH: It's up to you, Don. In other
12 A. COULWAVE. Okay, yes. We -- there's -- 12 words, if you need -- want more time for a break,
13 ADCIRC and STWAVE talk to each other, and so there is 13 we'll give you one.
14 some setup coming into the -- some of the wave setup is 14 THE WITNESS: I don't think I need more
15 going into the ADCIRC results. And then in -- once we 15 time than that.
16 turn on at sort of the center of the channel, that -- 16 MR. ROY: We are sensitive to it, and if
17 the COULWAVE, then it captures the rest of the setup. 17 you need it, you let us know.
18 VIDEOGRAPHER: Off record at 11:46 a.m. 18 THE WITNESS: Okay. I guess if I, like,
19 (OFF THE RECORD) 19 you know, an hour after that say, wow, that was
20 MR. ROY: Do you -- can you write across 20 stupid, then I'll -- I'll just take a ten-minute
21 the margin "Confidential, Subject to Protective 21 break.
22 Order," just something -- I just want something 22 MR. SMITH: Yeah, we can take a ten-minute
23 that's a red flag -- 23 break whenever you need one.
24 THE WITNESS: Sure. 24 THE WITNESS: So I have that option.
25 MR. ROY: On page 1. 25 Okay.
24 (Pages 90 to 93)
Page 94 Page 96
1 MR. ROY: Okay. All right, are we now on 1 BY MR. ROY:
2 the record? 2 Q. All right, what I'm doing on Exhibit 11,
3 VIDEOGRAPHER: Yes, sir. 3 which is the blowup of your Figure 11, is I'm simply
4 BY MR. ROY: 4 labeling two of these boxes with an A and a B.
5 Q. All right. You want to pass that over? 5 A. Okay.
6 We'll come back to that. 6 MR. ROY: Robin, I've put an A for the big
7 MR. ROY: Make a note, Ashley, and we'll 7 box and a B for the small box over the Lake
8 come back to that. 8 Borgne area.
9 BY MR. ROY: 9 BY MR. ROY:
10 Q. We'll come back and identify it. But while 10 Q. To simplify things here a little bit, the box
11 we were off the record, Dr. Resio, you and Mr. Smith 11 that we've marked as A is a box that extends out on the
12 held up an article, prepublication, not yet published, 12 southeast axis past the Chandeleur Islands into the
13 that you received yesterday, I believe you said, from 13 Gulf of Mexico. Correct?
14 Dr. Lynett at Texas A&M? 14 A. That is correct.
15 A. That is correct. 15 Q. On the north axis, which also runs from
16 Q. And -- but you said you didn't rely upon this 16 northeast to southwest, runs basically over the
17 in any way for the preparation of your report. Right? 17 Rigolets, in that direction. Correct?
18 A. No. I did not have it. 18 A. I think so, yes. I'm trying -- yeah, I think
19 MR. ROY: All right. And since we've 19 about, yeah.
20 already taken the time to go this far, for 20 Q. All right. And then those two parallel lines
21 identification, I'm going to mark it as 21 are connected by parallel lines running, roughly, from
22 Exhibit 10. We do note and agree it is subject 22 the southeast up to the northwest.
23 to a protective order, confidentiality, not to be 23 A. That is correct.
24 used outside this litigation. 24 Q. All right. That's the big box, the A box.
25 Is that fair enough, Robin? 25 Correct?
Page 95 Page 97
1 MR. SMITH: Yes. 1 A. That is correct.
2 MR. ROY: And I'll just mark it englobo 2 Q. This was an STWAVE grid model -- or model, I
3 10. 3 should say -- that was actually run.
4 (EXHIBIT 10 MARKED) 4 A. Yes.
5 BY MR. ROY: 5 Q. That you relied upon for your report.
6 Q. And the sole purpose is to identify what you 6 A. That is correct.
7 were talking about. 7 Q. That model that was run was to establish an
8 A. Okay. 8 outer boundary. Is that correct?
9 Q. But, otherwise, since you in no way relied 9 A. That's right.
10 upon it for your report, it's just an incidental to our 10 Q. The outer boundary that is the southeast edge
11 passing. 11 past the Chandeleur Islands, past the Chandeleur Sound
12 A. All right. 12 into the Gulf of Mexico, that edge, that boundary,
13 Q. Let's go to your report, Figure 11. And for 13 meets up with information you're getting off of the
14 purposes of our discussion today, I've brought an 14 WAM, W-A-M. Is that correct? Or somebody's getting
15 enlargement of Figure 11 which I'm going to hand to 15 off of it.
16 you. 16 A. Yes, that is correct.
17 A. Um-hum. (Affirmative) 17 Q. All right. So your -- your macro long
18 Q. And actually, for purposes of reading, let me 18 distance wave and surge --
19 have that back if I could. 19 A. Um-hum. (Affirmative)
20 A. I can read my Figure 11. 20 Q. -- is -- the buildup over whatever number of
21 Q. All right. Well, we can agree this is an 21 days, that's coming from the WAM information. Correct?
22 illustration in your report. Correct? 22 A. That's right.
23 A. That is correct. 23 Q. Then this A box, or the STWAVE, is then
24 (EXHIBIT 11 MARKED) 24 picked up to establish and bring it toward the smaller
25 25 box, which is basically the Lake Borgne itself area,
25 (Pages 94 to 97)
Page 98 Page 100
1 the B box. Correct? 1 Q. All right. Well, let's talk about Lake
2 A. That is correct. 2 Pontchartrain.
3 Q. All right. So this STWAVE program that's 3 A. Okay.
4 first run for the A box on Exhibit 11 was a half-plane 4 Q. All right. I don't want to get all
5 version of STWAVE. Correct? 5 wrapped --
6 A. That is right. 6 A. You said Pontchartrain. I just want to
7 Q. All right. And who made the decision to use 7 make --
8 the half-plane version of STWAVE to establish the 8 Q. I said it intentionally.
9 boundary in this case? 9 A. Okay.
10 A. Well, it was -- it already -- it's -- the 10 Q. I don't want to get all wrapped up in it.
11 decision was made it was part of the IPET run, so 11 A. That's fine. That's fine.
12 that -- so we had used it like exactly as you're seeing 12 Q. But I do know that when -- for the studies
13 here in -- in IPET. And then we decided that we wanted 13 you were involved with --
14 to put in a sub element with the full-plane inside of 14 A. Um-hum. (Affirmative)
15 that. 15 Q. -- in doing Lake Pontchartrain --
16 Q. All right. So would the short answer be the 16 A. Correct.
17 half-plane version of STWAVE that was already done for 17 Q. All right? -- I know that there was an
18 IPET was used here, it was convenient? 18 analysis done there and whatnot. Can we agree that
19 A. It was already set up and it was functional, 19 Lake Pontchartrain is a -- do you want to say fully --
20 and we didn't see where the results would suffer 20 fully -- it's not a lake. Right?
21 because of it. 21 A. Right. Right.
22 Q. IPET did not run a full-plane version of 22 Q. I mean, it does have an open tidal outlet in
23 STWAVE, did it? 23 two locations: The Rigolets and the IHNC, GHIW --
24 A. No, it did not. 24 GIWW.
25 Q. And your expert group determined that there 25 A. Yes.
Page 99 Page 101
1 should be a full plane of STWAVE run; and so you ran it 1 Q. So it's semi-enclosed too. Right?
2 not over the whole area represented where the 2 A. A little more so.
3 half-plane had been done, the A grid, but put it in the 3 Q. A little more so.
4 small box, the B box, basically overlapping Lake 4 A. Right.
5 Borgne? 5 Q. But in terms of analysis, it's bigger. It
6 A. Yes. Yeah. We would put it in the area 6 has longer fetches than Lake Borgne. Correct?
7 where we thought the -- the primary generation area 7 A. Right.
8 would be, and we didn't extend it to where we didn't 8 Q. Right?
9 think it would contribute. 9 A. That is correct.
10 Q. All right. And when you talk about "primary 10 Q. "Fetch" being the number of miles or feet or
11 generation area," you're talking about primary 11 thousands of feet over which a wave can be generated by
12 generation of waves? 12 wind. Of course, restricted or enhanced by other
13 A. Yes. 13 functions such as depth. Right?
14 Q. All right. In fact, Lake Borgne is a 14 A. That is correct.
15 semi-enclosed waterway; and, as such, that term has 15 Q. So basically -- all right.
16 special significance, in your experience, in that it is 16 The northeast edge of the smaller rectangle
17 not directly affected by, generally, ocean-type waves 17 on Exhibit 11 --
18 with long periods coming in? 18 A. Okay.
19 A. No. If there's no storm surge, this is 19 Q. -- I think is near Cat Island. Would you
20 correct. 20 agree? Or do you know? And if you don't, that's fine.
21 Q. I understand. But -- but to the extent it 21 A. I mean, I think it's -- my recollection is
22 may be even then, it's only during the duration of the 22 that Cat Island is somewhere in that vicinity, so I
23 surge. 23 would agree, you know, that -- that it's consistent
24 A. Well, I mean, if there's storm surge, then it 24 with -- with what I -- where I think Cat Island is.
25 becomes exposed. 25 Q. The real question is: From the right -- from
26 (Pages 98 to 101)
Page 102 Page 104
1 the -- from the edge, the bottom right -- that's not 1 Q. And I'm going to make one other letter.
2 good. 2 A. Okay.
3 From the rectangle B -- 3 Q. I'm going to put a Z -- let me see yours.
4 A. Um-hum. (Affirmative) 4 I'm going to put Z.
5 Q. -- the corner that is eastmost at the top -- 5 MR. ROY: And I put that up here, Robin.
6 A. Okay. 6 MR. SMITH: (Nods affirmatively) Okay.
7 Q. -- from that line to roughly where the funnel 7 BY MR. ROY:
8 is referred to in this litigation -- 8 Q. Now, I want to talk about how the half-plane
9 A. Um-hum. (Affirmative) 9 version was oriented for purposes of developing the
10 Q. -- can we agree that's a distance of about 40 10 boundary information on waves.
11 or 45 miles? 11 A. Um-hum. (Affirmative)
12 A. If you say it is, I -- it looks -- I would 12 Q. All right? You understand?
13 guess it's about that. I -- there's no scale on here, 13 A. Yes.
14 so I can't tell it by this. But I'm thinking you're -- 14 Q. It's got to be properly oriented. Correct?
15 you're approximately right. 15 A. Yes.
16 Q. Would you say it's, at least, in excess of 16 Q. All right. The half-plane version was
17 30 miles? 17 actually oriented facing out toward the Gulf from the
18 A. I would say so, yes. 18 line between the X and the Z. In other words, the face
19 Q. All right. I'm just trying to get some broad 19 formed by the line X and Z draw an arrow straight
20 geographic frames of reference. 20 across Lake Borgne and out into the Gulf --
21 A. You got it. 21 A. Um-hum. (Affirmative)
22 Q. That's at least as long in that axis as Lake 22 Q. -- that was the orientation of the STWAVE
23 Pontchartrain is wide. 23 half-wave program. Correct?
24 A. Yes. 24 A. Yes, that is correct.
25 Q. Now, the half-plane grids, were they 25 Q. That was used to establish the outer boundary
Page 103 Page 105
1 200-meter grids? 1 at the WAM. Correct?
2 A. Yes, they were. 2 A. That took the outer boundary from the WAM,
3 Q. When the full plane was run over the Lake 3 yes.
4 Borgne rectangle, the B rectangle, did those grids 4 Q. Sorry for my semantics, but you agree with
5 remain 200 meters -- 5 that?
6 A. Yeah. 6 A. Yes.
7 Q. -- or 656 feet square? 7 Q. All right. Now, half-plane STWAVE modeling
8 A. Yes. And in all of our runs that -- that 8 has some limitations, doesn't it?
9 contributed to -- to this report, we -- we used only a 9 A. Yes, it does.
10 200-meter grid size. We've -- we've done more detail 10 Q. The half-plane -- well, first the -- the
11 since then, but that's what -- that's what we had at 11 full-plane version of STWAVE will pick up waves and
12 this time. 12 wind, regardless of direction. Correct? Let's say
13 Q. Looking at Exhibit A, I'm going to put an X 13 wave; stick with waves.
14 and I'm going to put a Y. I'm going to mark them on my 14 A. I'm not sure what you're --
15 copy. This is my copy. Where is the exhibit? And 15 Q. Just waves. Forget wind.
16 I'll mark it on there so I can ask you questions and 16 A. Okay.
17 the record will make sense. 17 Q. Just waves.
18 A. Okay. 18 A. Okay, it will -- what do you mean by "pick up
19 Q. I'm placing an X and a Y. 19 waves, regardless of direction"?
20 MR. ROY: Robin, I've put the X at the top 20 Q. Well, what does -- what does it do -- what
21 of the small line here and the Y at the bottom. 21 does the ST -- what's the purpose? If you're trying to
22 MR. SMITH: (Nods affirmatively) 22 go out and receive from WAM at the boundary --
23 BY MR. ROY: 23 A. Um-hum. (Affirmative)
24 Q. Do you see the X and the Y? 24 Q. -- waves --
25 A. I see the X and the Y. 25 A. Right.
27 (Pages 102 to 105)

Page 106 Page 108
1 Q. All right. -- is it important to pick the 1 Q. Exhibit 11.
2 information up for the waves coming from that 2 A. All right.
3 direction? 3 Q. I put the letter T with a line connecting the
4 A. Yeah, it is important. It covers a 4 X to the T.
5 half-plane. So it's -- it's 180 degrees -- if you look 5 When the half-plane version of STWAVE was run
6 at the line that is running along the seaward edge, the 6 for Lake Pontchartrain in the calculations that you did
7 southeastern edge of what you had as A in your box -- 7 for IPET --
8 Q. Um-hum. (Affirmative) 8 A. Right.
9 A. -- and now you take any grid point along 9 Q. -- that was the shore side of the half-plane
10 there, it will consider waves along the entire -- 10 version of STWAVE that was run, wasn't it?
11 within 180 degrees. So it will be considering waves -- 11 A. Exactly, yes.
12 well, minus 5 degrees on each side to be precise. But 12 Q. And that was because the primary direction of
13 if you -- if you then look at that -- it will consider 13 the wind and wave that you were concerned about was
14 waves anywhere from heading toward just about to the 14 coming from the north, generally, to the southern shore
15 south -- southwest rotated westerly 5 degrees, and it 15 of Lake Pontchartrain.
16 will consider waves heading all the way over to 16 A. Yes. That is --
17 northeast, rotated northerly by 5 degrees. 17 Q. Correct?
18 I think I said that right. 18 A. Yes, that is correct.
19 Q. The half -- go ahead. 19 Q. All right. So the southern shore of Lake
20 A. So it covers all of those waves in that is 20 Pontchartrain was your real live coastline you were
21 not one -- you know, you don't cover one wave 21 concerned with?
22 direction. It covers -- wave direction is a computed 22 A. That is right.
23 quantity based on the integrated attributes of that 23 Q. It was a real problem that you wanted to
24 propagation and source of generation. 24 address.
25 Q. The half-plane version has a limitation, 25 A. Right. And I didn't want -- I wanted to make
Page 107 Page 109
1 would you agree, that's generally inappropriate for 1 sure that you understood we -- we would think that
2 nearshore coastal applications? 2 the -- the half-plane model would work very nicely for
3 A. Was that the end of the question? 3 that. It did work very nicely for that.
4 Q. Yes. 4 Q. All right. Now, in this situation for your
5 A. No. 5 report, the real coastline problem you're addressing --
6 Q. All right. 6 A. Um-hum. (Affirmative)
7 A. I mean, otherwise -- I mean, you just asked 7 Q. -- is the -- the 20-something miles of Reach
8 you'd never want to use this model for a nearshore 8 2 of the MRGO. Right?
9 coastal application, and we recommend it for nearshore 9 A. That's right.
10 coastal application, so . . . 10 Q. All right. And that is represented generally
11 Q. But you have to use the full plane to build 11 along the same axis as between X and Y on Exhibit 11.
12 on whatever your half plane developed as far as wave 12 Correct? Give or take a few degrees.
13 data. Correct? 13 A. Are you saying that's the Pontchartrain --
14 A. Only in certain situations. And in most 14 that's the orientation of the lake --
15 situations, the half plane works very, very nicely. In 15 Q. No. The Mississippi -- the Mississippi River
16 fact, the half plane worked very nicely in Lake 16 Gulf Outlet, the MRGO.
17 Pontchartrain in this. We compared it to the full 17 A. I'd like -- I mean, if you say it is, I'll
18 plane. 18 take your word for it. I can't see it on here.
19 Q. For the Lake Pontchartrain, now that you 19 Q. Is it closer to the orientation of the axis
20 bring it up -- 20 of the MRGO, that is, the XY line on Exhibit 11, than
21 A. Um-hum. (Affirmative) 21 any other line on Exhibit 11, except one that may be
22 Q. -- the axis of orientation, if you will -- 22 parallel to XY?
23 give me your drawing, and I'm going to put one more 23 A. I -- I mean, I think you're right. It's just
24 letter on there. 24 hard to tell on this. If you want me to just say -- I
25 A. Okay. 25 think that was fairly parallel with that edge, and then
28 (Pages 106 to 109)

Page 110 Page 112
1 from -- based on other information, it is. 1 Borgne --
2 Q. So for just like the southern shore of the 2 A. Right. Sure.
3 Lake Pontchartrain -- 3 Q. -- and immediate vicinity grid on
4 A. Um-hum. (Affirmative) 4 Exhibit 11 --
5 Q. -- was the real coastline against which the 5 A. Um-hum. (Affirmative)
6 primary wind and waves were coming -- 6 Q. -- that was laid on top of the half-plane
7 A. Right. 7 results.
8 Q. -- the X-to-Y line, the MRGO on Exhibit 11, 8 A. Yes.
9 is the real coastline against which the wind and waves 9 Q. Correct?
10 you're trying to determine the effects? 10 A. That is correct.
11 A. That is -- I mean, yes. Approximately, 11 Q. It did not start de novo from scratch --
12 right. 12 A. Right.
13 Q. All right. Now -- 13 Q. -- over Lake Borgne. It started with the
14 A. Yes. 14 half-wave results.
15 Q. So why wasn't the -- let's back up. Why 15 A. Yes.
16 wasn't a full-plane version of STWAVE run over the 16 Q. All right. So if it started with the
17 entire big grid, the A block, if you will -- 17 half-wave results inside this largely enclosed bay --
18 A. Um-hum. (Affirmative) 18 A. Um-hum. (Affirmative)
19 Q. -- instead of the half plane? 19 Q. -- from everything I can tell from the user
20 A. Well, it's because wave generation and 20 manual and the articles that have been written about
21 propagation -- wind input, if you think about it as 21 STWAVE, it basically had excluded from that initial
22 a -- as a -- sorry -- fields. Okay? But there's only 22 foundation of wave material wave growth and
23 a certain spacial extent of the winds when it's coming 23 transportation in a -- greater than a plus or minus
24 through here. At any one time, it's affecting 24 90-degree of the axis.
25 different areas. 25 A. To the axis. So -- so what you're missing at
Page 111 Page 113
1 In a wave -- in a -- the difference between a 1 that boundary are waves that are propagating away from
2 half plane and a full plane shows up only in those 2 the coast. If you look at the south -- no, excuse
3 areas where your -- where the main wave generation 3 me -- the northeast line site, but it's Z to the
4 axis, the winds, is, in fact, out of alignment -- 4 unlabeled corner.
5 strongly out of alignment with the grid. 5 Q. All right. Well, let's put a -- let's put --
6 Now, when you look at the -- most of the 6 A. What do you want to put? Z prime?
7 wave -- the strong wave generation in A probably came 7 Q. Well, you know you're dealing with a
8 in not too obliquely from the direction that it's a 8 nonphysics major there. How about W?
9 line to. I mean, if you think -- you know, if you look 9 A. W, okay. Do you want to do it or do you want
10 at -- at the path that it was coming, a hurricane 10 me to?
11 coming -- coming straight north, and there was a huge 11 Q. Go ahead.
12 amount of wave generation that should have been coming 12 A. All right. Now there's a W on there.
13 and captured by this seaward boundary and allowed to 13 Q. So now all four corners of B are labeled.
14 propagate in fairly reasonably. 14 A. All right. The Z-to-W is the part that we --
15 Now, then, on top of that, you then have to 15 we are assuming there's not much wave -- waves at the
16 resolve -- which I presume the point you're making is I 16 boundary propagating from that, and I don't think there
17 now have to resolve the local wave generation, which is 17 will be. Because there's a refraction, and that's
18 going to be in this region B, and that's why we -- we 18 coming from the coast. There is no wave generation on
19 switch. Now -- switched to it in this case. In the 19 the coast.
20 IPET we -- we did not realize that the source terms 20 And -- and if you look at the timing, it's
21 that were in the STWAVE would not handle that. But 21 important to remember that it's not waves at all times;
22 that's part of a learning process. 22 it's waves when we were doing the peak of the storm,
23 Q. But my point, ultimately, to you is, is that 23 when we were getting our maximum waves in here, these
24 you -- for purposes of your report, then the S -- the 24 -- the waves aren't -- the wind's not coming from
25 full-plane STWAVE modeling done in the B grid, the Lake 25 northeast; it's coming from due east. And I think
29 (Pages 110 to 113)

Page 114 Page 116
1 we -- you know, all of the easterly components of that, 1 model confirms that we put our boundary in the right
2 we're catching okay along the boundary. 2 place, but we put our boundary in the right place under
3 Q. But the shore boundary, the shore side, is 3 the assumption that we had covered sufficient space to
4 the X-to-Z axis. Correct? 4 do so.
5 A. The -- 5 Q. The study that your report is about, your
6 Q. That was the orientation you told me in your 6 report's about the MRGO, at least, whether or not
7 full-plane and your half-plane version. 7 it's -- at the bottom line, whether it had any impact
8 A. The -- I mean, the -- yeah, the -- the 8 on wave and water velocity on the levees or earthen
9 shoreward boundary is X to Z. This is correct. 9 berms. Is that right?
10 Q. And so let me be even more fundamentally 10 A. That's my understanding, yes.
11 simple here. 11 Q. Even though it's not part of your task to
12 A. Okay. Sure. 12 determine actual damage mechanisms, if you will, to the
13 Q. You told me how you oriented -- let me see 13 levees themselves. Correct?
14 the exhibit, because I didn't mark it on my working 14 A. That's correct.
15 copy, and I want to make sure my lettering corresponds. 15 Q. There are disadvantages to the half-plane
16 When I asked you about Lake Pontchartrain -- 16 model of STWAVE. Is that correct?
17 A. Um-hum. (Affirmative) 17 A. Yes, that is correct.
18 Q. -- you told me that you aligned the 18 Q. One of them is the model simulates wave
19 half-plane version between T and X basically along the 19 growth and transformation in a half plane, plus or
20 southern boundary of Lake Pontchartrain because the 20 minus 90-degree of the axis, as opposed to full;
21 winds were coming across that enclosed bay from the 21 omnidirectional, if you will?
22 north and so were the waves. 22 A. Yes. Right.
23 A. That is correct. 23 Q. You agree with that?
24 Q. All right. So my only question to you is: 24 A. I absolutely agree with that.
25 Why didn't you orient the STWAVE wave modeling with the 25 Q. You agree another disadvantage of the
Page 115 Page 117
1 shoreline, the baseline that you were concerned with, 1 half-plane version of the STWAVE is lack of
2 as the XY line rather than the area between X and Z? 2 flexibility; that is, it requires square grid cells?
3 A. Well, because there's two different wave 3 A. I don't consider that to be a disadvantage in
4 trains. The main large waves generated offshore are, 4 a wave model.
5 in fact, coming out of the southeast. We didn't want 5 Q. All right.
6 to ignore those. We didn't want to neglect those. So 6 A. Waves travel in -- waves travel in straight
7 they're coming in from the southeast. They don't go 7 lines. You solve the equations in straight lines.
8 away. We had to model those. 8 It's the best way to solve them. They can be written
9 What we did was we added a -- a section that 9 in -- in different, but it's not like a long wave,
10 would consider all the angles, and I think we 10 ADCIRC.
11 appropriately populated the boundary conditions on 11 Q. Let me rearticulate the question like this:
12 those to pick up what would happen inside of that 12 Would you agree the disadvantages of the half-plane
13 boundary that would make the waves come on to -- up to 13 version of STWAVE include lack of flexibility, that is,
14 the MRGO. And I think that our results and the results 14 requires square grid cells --
15 of the -- the Delft work, Riley, and everybody, are 15 A. Um-hum. (Affirmative)
16 really consistent on that edge. 16 Q. -- half-plane coverage, that is, mean
17 So I'm not sure if -- you know, it's -- it's 17 direction greater than 60-degree relative to the X axis
18 almost -- our results and their results on the -- the 18 loses significant energy; and lack of higher order
19 seaward edge, if you want to call it that, of the MRGO 19 processes, that is, diffraction, reflection,
20 and -- and ours, they're not that different. In our 20 transmission, bottom interaction, and wave asymmetry?
21 half-plane, you know, they're 5 to 6 feet, and I think 21 A. Yes. I mean, those are, in fact -- but when
22 their -- 5 to 6 feet on theirs too. 22 people are saying the part that you're talking about
23 Where -- where we differ is what happens when 23 the square grid, that -- that's a computer. I mean,
24 we go across. Now, I'm just saying I think we -- I 24 that is -- when they're saying "lack of flexibility," I
25 think actually the results from their full-plane larger 25 think that's an overrated -- when I was developer and
30 (Pages 114 to 117)

Page 118 Page 120
1 -- of the initial code, and I think sometimes today 1 A. Right.
2 people want to put everything onto an irregular grid, 2 Q. -- and I've got in brackets?
3 but the equations themselves are best posed in a 3 A. And I will read it --
4 rectilinear system. 4 Q. Can you read it?
5 Now, you can pose them in any system you 5 A. "Disadvantages include lack of flexibility
6 want, but -- you make it sound like there's a problem 6 (requires square grid cells), half-plane coverage
7 with the solution. No, it's -- it's a problem with the 7 (mean" -- I mean, I'm sorry. I'm not -- I'm going to
8 convenience is what people are talking about in that 8 start over again here.
9 particular reference that you're reading. 9 "Disadvantages include lack of flexibility
10 Q. In a published article, did you and Jane 10 (requires square grid cells), half-plane coverage (mean
11 Smith -- 11 direction greater than 60 degrees relative to the X
12 A. Yes. 12 axis lose significant), and the lack of high order
13 Q. -- say, quote, "Disadvantages" -- and I'm 13 processes (diffraction, refraction, transmission,
14 saying in bracket Re half-plane STWAVE bracket -- 14 bottom interaction, and wave asymmetry)."
15 A. Right, right. 15 I think I did that well.
16 Q. -- and picking up at the quote, "include lack 16 Q. Great. Was that true when that article was
17 of flexibility (requires square grid cells), half-plane 17 written?
18 coverage (mean direction greater than 60 degree 18 A. It was in the context I was saying. It was
19 relative to the X axis lose significant energy), and 19 true. It still is true.
20 lack of higher order processes (diffraction, 20 Q. And so we're clear about the context, a
21 reflection, transmission, bottom interaction, and wave 21 little higher in the paragraph, if you want to look --
22 asymmetry)." 22 A. Um-hum. (Affirmative)
23 Did you and Ms. Smith say that? Yes or no? 23 Q. -- you're directly referring to the
24 A. Well, that's -- I mean, I will say that was 24 half-plane version of STWAVE, which you're showing
25 written, but you have -- you can't -- you have to 25 attributable to Resio 1987-'88; Smith, Sherlock, and
Page 119 Page 121
1 understand three of those were due to -- were physics, 1 Resio 2001; and Smith and Smith in 2002, released in
2 and one of those was numerics. It's more convenient if 2 2001. That version. Right?
3 I can put irregular grids on top of an irregular grid. 3 A. I -- Jane was the first author on this. Now,
4 Q. I understand what your preference is. 4 I'm assuming yes. I'll just say I'm thinking those are
5 A. Right. 5 the right versions. I'm assuming she did it correctly.
6 Q. All I want to know -- and it's a yes or no -- 6 Q. All right. But your name is on this article,
7 were you the co-author of that -- 7 isn't it --
8 A. I was the co-author that said that, but 8 A. Yes.
9 you're trying to interpret it a different way than we 9 Q. -- or is it?
10 intended it. So I just want to make sure you 10 A. It is on that article.
11 understand that you're not -- you know, when we wrote 11 Q. Huh?
12 that, we -- we had -- there were disadvantages, and 12 A. It is on that article because I did part of
13 some of those were disadvantages with the ability to 13 the article. I did not do that part of the article.
14 model the process, and one was a disadvantage with the 14 Q. Okay.
15 difficulty in modeling the process. The computational 15 A. If you want to know the specific part of the
16 prerogative would be to have an arbitrary grid. I 16 article I did --
17 don't use those two. 17 Q. No. All I want to know is if your name is on
18 Q. I'm going to hand you Exhibit 12, and I've 18 the article.
19 marked the sentence in brackets in the bottom. 19 A. Yes, it is.
20 (EXHIBIT 12 MARKED) 20 Q. All right. While we're at it, was that
21 BY MR. ROY: 21 article, which is entitled "Improved Shallow Water Wave
22 Q. And that's the article of you and Ms. Smith. 22 Modeling," was that published?
23 A. Right. I agree. 23 A. No. No. That was an article in a -- in a
24 Q. Can you read me the sentence that you and 24 conference that I organized on waves, international
25 Ms. Smith wrote -- 25 conference. Every two to three years we alternate with
31 (Pages 118 to 121)

Page 122 Page 124
1 the Canadians, and I organize one and they organize 1 that I have marked on there.
2 one. 2 A. I understand.
3 That's a reprint from it or just a -- we put 3 Now, is that line supposed to be Y and W on
4 it there for communicating to scientists. 4 the other?
5 Q. Well, talking -- and maybe this will be about 5 Q. Yes, sir. Generally.
6 the last time we fool with this half plane versus full. 6 A. Oh, okay.
7 A. That's fine. 7 Q. Generally.
8 Q. But the half-plane limitation -- 8 A. And that's fine. All right.
9 A. Um-hum. (Affirmative) 9 Q. The A-to-B line on Exhibit 13 --
10 Q. -- is generally appropriate for nearshore 10 A. Right .
11 coastal applications, with the exception of enclosed or 11 Q. -- is supposed to be generally the same
12 semi-enclosed bays, estuaries, and lakes, where seas 12 orientation as the Y-to-W line on Exhibit 11.
13 and swells may oppose each other or there is no clear 13 A. Okay. I understand now.
14 offshore direction. Correct? 14 Q. Okay. Now, why wasn't that line generally
15 A. That is correct. That's why we superimposed 15 used as the shoreside axis of a half-plane STWAVE
16 the full-plane portion onto it. 16 modeling extending offshore, and then you start at that
17 Q. All right. But my question to you is: Why 17 line and come into the Lake Borgne and the Lake Borgne
18 wouldn't you have not superimposed the full plane over 18 Sound and do full plane from scratch rather than coming
19 that? Why wouldn't you have simply started your 19 on top of half plane within Lake Borgne?
20 STWAVE -- for example, instead of using as your base 20 A. Well, I mean, I can only speak as a wave
21 shoreline of your half wave on the A block as the 21 modeler and --
22 X-to-Z axis, why wouldn't you have based the A block at 22 Q. I understand.
23 the Y-to-W, made that your northeast-to-southwest axis, 23 A. Okay. I mean, to me, it's done the way I
24 your shore axis for your half plane going out into the 24 would do it, so I'm -- I'm trying -- still trying to
25 Gulf of Mexico, and then picked up at that point with 25 figure out why you want to do it differently. And it's
Page 123 Page 125
1 the full-plane de novo over the Lake Borgne area? Why 1 -- I mean -- I mean, normally you set your -- your
2 didn't you do that? 2 boundary out where you think the biggest waves in the
3 A. Well, I honestly lost you in -- in the middle 3 ocean or sea are coming in, and that is roughly,
4 of that, so -- so I was -- 4 approximately, where this outer boundary running the
5 Q. All right. Let me draw a map. 5 southeast line segment of grid A. Okay. If you can
6 A. All right. 6 see -- if you remember grid A back here, this -- this
7 Q. I'll take a shot at it. 7 southeast line segment, I want to capture all of the
8 A. All right. Good. Good. I was trying to 8 energy coming in here because that's the main area
9 follow, but the Y-to-W, I just -- I mean, if you -- to 9 where -- where as the hurricane's coming in this way,
10 me -- all right. I'm not going to volunteer. I was 10 it's going to be pushing in big waves from the Gulf.
11 getting ready to jump in and volunteer a lot of 11 Now, past that time, when I get into close to
12 information. 12 where you're talking about, you have an extremely valid
13 MR. ROY: Okay. I'm marking my drawing, 13 point. We had to then say, okay, let's go ahead and
14 made entirely by me, as Exhibit 13. And I'm not 14 try to figure out how we're going to get waves to go at
15 proud of my artwork, but it's strictly for 15 this really strong angle to it. And that's why we put
16 illustrative purposes. And, Robin, it is not 16 in the section that was the full-plane Section B. But
17 purported to be to scale. 17 we think that captured most of the processes correctly.
18 (EXHIBIT 13 MARKED) 18 And the fact that it's consistent with the
19 BY MR. ROY: 19 people who did it a different way with the full -- with
20 Q. All right? 20 actually the whole area covered by a full plane, I
21 A. All right. All right. 21 think would somewhat say that, you know, we -- we did
22 Q. But look at that. 22 do it reasonably. Now, if we didn't do it reasonably,
23 A. Yeah, sure. 23 we just ended up by the -- with the right results
24 Q. My sole purpose is to try to give you a 24 accidentally, which I don't think we did.
25 general frame of orientation of a line between A and B 25 Q. All right. Let's talk to some specifics.
32 (Pages 122 to 125)

Page 126 Page 128
1 A. Okay. 1 recognizes that, in an area of fairly uniform nearshore
2 Q. And we're going to get into a lot more 2 water depth adjacent to a real coastline of concern
3 specific later. 3 that you're studying, that where there is a spot such
4 A. All right. 4 as a borrow pit, where fill has been dug out, thus
5 Q. But -- 5 making a hole in the water deeper than the surrounding
6 A. Do you want me to set these back over here? 6 area --
7 All right. 7 A. Okay.
8 Q. One of your conclusions was that there was 8 Q. -- your own STWAVE manual acknowledges that
9 little, if any, wave regeneration over the MRGO prior 9 that borrow site can have an impact on the shoreline
10 to -- 10 and sediment infilling rate from it. Correct?
11 A. Not -- I'm sorry. 11 A. That is correct, yes.
12 Q. Excuse me. -- prior to those waves coming 12 Q. And it also recognized that additional STWAVE
13 into contact with the Reach 2 ESBS earthen berms or the 13 runs would be required in such a situation, doesn't it?
14 levees. 14 A. I -- if you say it does, you're reading from
15 A. I think we have about the appropriate amount 15 it, then --
16 of wave generation. 16 Q. Go to page 57 of your STWAVE user manual, and
17 Q. Which is what? 17 this -- to give you context --
18 A. Which is about a foot. 18 A. Okay. Yes, that's what I'm --
19 Q. At any place -- 19 Q. Sure. I'm going to give you context --
20 A. For that distance at those winds, yeah. 20 A. Sure.
21 Q. Listen to my question. At any place did wave 21 Q. -- and I'm sure you'll look back and see it.
22 regeneration across the MRGO, in any scenario, exceed 22 But context is example 2 -- what is this? Yeah, page
23 one foot in your report? 23 57. The context is example 2, "Wind Wave Generation."
24 A. I would have to -- I haven't done that 24 And if you look on page 55 --
25 comparison. 25 A. Um-hum. (Affirmative)
Page 127 Page 129
1 Q. Okay. No -- 1 Q. -- it actually gives the orientation. The
2 A. If you want me to go and look at everything 2 shoreline is on the right. The wind is coming from the
3 that went -- because we actually had some transects, 3 left. The borrow pit is offshore.
4 and it -- and I would have to go and look at each 4 A. Okay.
5 specific case. 5 Q. In fact, look at page 55. You've got the
6 Q. Okay. But my question -- let me reword it. 6 grid 5, 10, 15.
7 A. Okay. 7 A. I see it.
8 Q. Because in fairness to you -- 8 Q. Is that intended to represent the slope?
9 A. Um-hum. (Affirmative) 9 A. I think it's supposed to be depth. That
10 Q. -- I want to word it in a way that you 10 would be my -- my reading of it, yes.
11 understand and is appropriate. 11 Q. Okay. Is that intended to be meters or feet?
12 A. Right. 12 A. I --
13 Q. Nowhere in your report do you indicate that 13 Q. It could be either. It could be either.
14 waves at any point on Reach 2 regenerated to an extent 14 A. It could be either. Yeah. That's just -- I
15 greater than one foot across the MRGO. 15 don't know.
16 A. To me that sounds about the right amount for 16 Q. Fair enough. Fair enough.
17 generation across that extense of water. 17 A. Right.
18 Q. All right. That expanse of -- expanse of 18 Q. So you're showing -- let's use feet so we're
19 water, what do you call that expanse of water? 19 talking the same language here.
20 A. About 200 meters or so or to a mile. I mean, 20 A. Okay. Okay.
21 somewhere maybe as much as a mile. It depends on how 21 Q. So in this example on page 55, where the
22 different people have been looking at this. 22 water goes from 0 at the shore to, say, in the 15 to
23 Q. We'll come back to that too. 23 20 foot range offshore, and then there's a borrow pit
24 A. Okay. 24 where the water's deeper.
25 Q. Now, your own STWAVE manual, in fact, 25 A. Right.
33 (Pages 126 to 129)

Page 130 Page 132
1 Q. Would that be a fair statement? That's your 1 In other words, if I wanted to study a evolution of a
2 intention with this. Right? 2 beach to say what the eventual impact of this borrow
3 A. That is the intention. 3 site is going to be, it's evolutionary. I have initial
4 Q. All right. And in such an example, the 4 condition. I dig a hole. Okay?
5 impact of that site -- 5 Now, the second time, once -- once the waves
6 A. Um-hum. (Affirmative) 6 start propagating through here, you do all the sediment
7 Q. -- can cause the need for additional STWAVE 7 transport, you may say, okay, this is going to fill in
8 study because an increased depth like that in your 8 here, this is going to erode here, and this is going to
9 example is capable of causing increased wave height. 9 happen here. So now my initial bathymetry that I put
10 Isn't that correct? 10 in this model is no longer appropriate. I need to now
11 A. I'm not sure you're reading that right. I 11 go back and make additional runs to try to make sure
12 mean -- I mean, to me the increase -- the additional 12 that -- that I capture the evolutionary nature of the
13 runs, I don't think are meant -- I'm not sure what the 13 sediment -- of the offshore evolution.
14 implication you're trying to make with additional runs 14 Q. But your context here as far as the STWAVE
15 here. If I go to -- to evaluate the impacts on the -- 15 application is not solely to address sediment infilling
16 the sediment infilling would be required, well, if -- 16 rate. It's also to address the impacts of borrow site
17 if, in fact, the shoreline changes, you can't keep 17 on the shoreline. Isn't that right?
18 running the same model over and over. You have to run 18 A. Well, it's both.
19 a different -- 19 Q. Okay. Let's focus on the --
20 Q. Page fifty -- I didn't mean to cut you off. 20 A. Right.
21 A. That's okay. That's okay. 21 Q. -- impacts of the borrow site on the
22 Q. Page 57? 22 shoreline.
23 A. Um-hum. Right. 23 A. Um-hum. (Affirmative)
24 Q. Go to the second full paragraph on the 24 Q. Is one of the things -- just one of the
25 bottom. 25 things --
Page 131 Page 133
1 A. All right. 1 A. Right, right.
2 Q. You make the statement: "To evaluate the 2 Q. -- that's one of those impacts, potentially,
3 impacts" -- 3 is increased wave height coming across that increased
4 A. Right. 4 section of depth where the borrow pit is?
5 Q. -- "of the borrow site on the shoreline" -- 5 A. Right. And STWAVE should model that
6 A. Right. 6 perfectly fine. I don't understand -- that's the part
7 Q. -- and the rest of the sentence you can read, 7 I'm missing.
8 or the sediment infilling, but I'm talking about the 8 Q. I understand.
9 phrase: "To evaluate the impacts of the borrow site on 9 A. It's just no reason why -- why STWAVE won't
10 the shoreline." 10 model a borrow pit. We do it all the time with it.
11 A. Right. 11 Q. Okay.
12 Q. What did you mean by evaluating by the 12 A. So your -- your -- the implication is that,
13 impacts on the shoreline if you did not mean that the 13 that somehow you run an additional model and that will
14 depth of the borrow pit and the location of the borrow 14 capture it. But, no, it captures it.
15 pit offshore -- 15 Q. Now, let's keep looking at that. "Local wave
16 A. Right. 16 generation" --
17 Q. -- could cause the need for additional runs 17 A. Okay.
18 in that immediate area to reflect that increased water 18 Q. All right? -- "is often an essential
19 depth? Why else would you have made that sentence? 19 process, increasing the wave height nearshore and
20 A. Well, I mean, to me, I don't think it -- I 20 altering wave direction."
21 mean, I think you'd need it because it's changing -- 21 Is that true?
22 Q. What's changing? What's changing? 22 A. That is true.
23 A. The bathymetry. 23 Q. You've told me that you only used 200-meter
24 Q. Which means, in part, depth. Right? 24 squares or 656-foot grids in the STWAVE. And in fact,
25 A. No, no, no. I'm talking about through time. 25 that matches, by the way, what the ADCIRC grids were.
34 (Pages 130 to 133)

Page 134 Page 136
1 A. That's right. 1 A. Yes.
2 Q. You understood that. Right? 2 Q. And that's for this case?
3 A. Yes. 3 A. Right.
4 Q. Would you generally agree that 200-meter or 4 Q. So why wouldn't you use the 25-meter higher
5 656-foot square grids are low resolution? 5 resolution grid-cell spacing in the STWAVE to resolve
6 A. They generally tend to be a little low 6 that bathymetry adjacent to and on both sides of the
7 resolution. 7 MRGO?
8 Q. Would you also agree that a much higher 8 A. You're talking about MRGO in general?
9 resolution grid would be a 25-meter-by-25-meter or 9 Q. Yes.
10 82-foot-by-82-foot grid? 10 A. Okay. Well, to me, the MRGO is actually a
11 A. That is a higher. "Much higher," I don't 11 fairly regular feature. It's not a -- you know, I
12 know. It's higher resolution. 12 mean, you're talking about recent things, very
13 Q. Well, it's a higher resolution by -- 13 irregular. But if you have a channel -- oh, you're
14 A. -- A factor of 4 or so. 14 running out of time.
15 Q. Well, it's more than a factor of 4, isn't it? 15 MR. ROY: All right. Go ahead and change
16 A true factor of 4? 16 your deal. How long are your tapes?
17 A. Oh, okay. Yeah. No, I'm sorry. Doing 17 VIDEOGRAPHER: An hour. Off record at
18 meters. So it's maybe a factor of 10. I don't know. 18 12:30 p.m.
19 You figure the math. 19 (OFF THE RECORD)
20 Q. Well, you tell me what it is -- no, I want 20 (EXHIBIT 14 MARKED)
21 you to tell me. 21 VIDEOGRAPHER: On record at 12:31 p.m.
22 A. How many feet? It's how many -- give it to 22 MR. SMITH: Just before you go on, were
23 me in meters. I got 200 meters, and now you're giving 23 you finished, Don, with your answer --
24 me -- 24 THE WITNESS: No. I was going -- just
25 Q. -- 25 meters. 25 going to answer that the -- there's a specific --
Page 135 Page 137
1 A. -- 25 meters. Okay. So it's a factor of 8. 1 when you have a channel, it's interesting. It's
2 Q. Instead of 200 meters. 2 like a lens, that if I just have something with
3 A. All right. It's a factor of 8. 3 the different capacity of -- different water
4 Q. Isn't high resolution generally required for 4 velocity, which is what you have when you go down
5 thorough STWAVE modeling in the nearshore to define 5 and back up, the waves passing through here on
6 things like reefs and entrance channels at land? 6 the other side, if they do not break, have no --
7 A. Now, are we talking just in general, or we're 7 they don't even know that they've passed over it.
8 talking specific to this case? 8 It's sort of funny. It's -- it's sort of
9 Q. Talking about in general. 9 funny. It's a -- it's like -- it's like they go
10 A. In general, if you have reefs around, you 10 in and they refract this way. Picture it like a
11 need fine resolution. If you're talking about an area 11 -- something with a refractive index like a piece
12 with -- with reefs. 12 of plastic. If I -- if I -- if you run a thick
13 Q. All right. What if you have barely submerged 13 piece of plastic and shine a beam of light
14 land? Isn't that analogous to a reef? 14 through it, because the speed travels a little
15 A. No. 15 different in this, it will bend over this way,
16 Q. It's not. 16 and coming out it will bend over that way. The
17 A. Something totally different. Let me go -- I 17 light will be the same emerging from here as it
18 mean, in this case you're talking about slopes that are 18 was coming in, all other things fact -- factored
19 so gentle. Coming up to that is going to be radically 19 out, it's a slight spacial shift.
20 different. 20 So when you're saying what is the impact of
21 Q. Well, aren't the shallow lands and the 21 the MRGO on waves that go from -- fairly from one
22 marshlands to the east of the Reach 2 of the MRGO, 22 depth to about the same depth on the other side,
23 aren't they part of the bathymetry that you've got to 23 the refraction part and the shoaling part is not
24 input into your STWAVE modeling -- or should -- once 24 really -- I mean, a long linear feature like
25 those lands go under water? 25 that, if it were hummocks, if it were holes, if
35 (Pages 134 to 137)

Page 138 Page 140
1 it were really localized mounds and things, you 1 probably about the right solution.
2 would have a different answer to that. 2 Q. Well, that's the point is that this is with
3 But given that it's just generally a shape 3 your 200-meter-by-200-meter grids.
4 like that, it tends to have very little effect on 4 A. Right. Right. There's a little -- little --
5 the opposite side other than, like you've been 5 little bit of up and down. Now, how real is that, how
6 pointing out, it has some effect on the source 6 unreal is that, I don't know because I -- I haven't
7 terms. Now, the source terms are the wind 7 looked at it. We haven't -- you know, when we look at
8 generation, the regeneration, but you don't need 8 it, you blow it up like that, and it kind of sticks
9 to resolve that. You're -- I mean, the wind is 9 out, but it's a --
10 constant on a scale much bigger than our grids. 10 Q. But we would know the answer if you had run
11 That is what you have to resolve in these 11 this STWAVE full-plane version --
12 things, because that's the only thing that 12 A. Um-hum. (Affirmative)
13 clenches anything. Everything else is -- is an 13 Q. -- in a 25-meter-by-25-meter or even finer
14 internal solution, and because models have to 14 resolution?
15 work from arbitrary solutions, they cannot be 15 A. Yeah. I'm guessing it's maybe about a 10 or
16 dependent on needing finer and finer resolution 16 15 percent difference between peak to -- to trough,
17 for a source integration to actually get the same 17 which is a lot of times we just get into -- into the
18 results. We should get the same results on a 18 range where we just want to say, well -- but that's --
19 200-meter as you get on a 25-meter on a source 19 in the uncertainty of the whole modeling process
20 integration dominated solution. If that made any 20 anyway.
21 sense. 21 Q. Just answer this.
22 BY MR. ROY: 22 A. Sure.
23 Q. Well, as a last question -- and I'm done with 23 Q. What prevented you from running STWAVE in the
24 this area. 24 full-plane version on the grid that you -- you ran it?
25 A. Okay. Okay. 25 A. Um-hum. (Affirmative)
Page 139 Page 141
1 Q. Let me show you Figure 16 -- 1 Q. But instead of using 200-meter-by-200-meter
2 A. Sure. 2 grids, what prevented you from running it in 25-meter
3 Q. -- a blowup -- 3 grids?
4 A. Okay. 4 A. Oh, nothing. We have done it now. We had
5 Q. -- from your report. 5 not done it at that time. We have done it since then.
6 A. Right, right. 6 And the -- like I'm saying, it doesn't change much.
7 Q. You see the red dots that I've put -- 7 Q. There's not --
8 A. I think I -- 8 MR. ROY: Object to the nonresponsiveness
9 Q. -- black arrows next to? 9 of the answer.
10 A. Yep, yep. 10 A. Okay, I'm sorry.
11 Q. Those black -- those red dots that those 11 BY MR. ROY:
12 arrows point to are areas where your modeling showed 12 Q. The question to you, sir, is: In your
13 wave regeneration over the MRGO. Is that correct? 13 report --
14 A. My guess is it's not wave regeneration over 14 A. Right. I know.
15 the MRGO. It's actually because we have -- it's 15 Q. -- there is no reference whatsoever to any
16 probably refraction, localized focusing over -- over -- 16 STWAVE depiction other than the type I've shown you in
17 and we have a -- the bathymetry changes quite a bit. 17 Exhibit 14 --
18 There's channels here. There's all sorts of things 18 A. Right. Right.
19 happening. 19 Q. -- that is in the 200-meter-by-200-meter
20 And when we represent a channel in a 20 resolution. Is that right?
21 discretized sense, this is very typical of what you get 21 A. That is correct.
22 sometimes coming out of it, is you -- you kind of get 22 Q. All right. At the time prior to the giving
23 some pixelization. It's somewhat equivalent to how 23 of your report --
24 well it is a resolution, and -- but it's -- it's kind 24 A. Um-hum. (Affirmative)
25 of like if you smooth along there, you would have 25 Q. -- that this is the -- the deposition is
36 (Pages 138 to 141)

Page 142 Page 144
1 being taken as a result of -- 1 A. I don't know.
2 A. Sure. 2 Q. All right. Well, let's go straight to page
3 Q. Your report's in December, I believe, of '08. 3 23.
4 A. That's right. 4 A. Okay.
5 Q. -- prior to that, there's nothing that 5 Q. And I hope I've given you a page that's
6 presented -- prevented you from running the STWAVE in 6 marked.
7 the full-plane version at a 25-meter-by-25-meter or 7 A. There is a 23 on there, yes.
8 finer resolution if you had chosen to have that done. 8 (OFF THE RECORD)
9 A. If we thought it would make a difference. 9 BY MR. ROY:
10 And I think that's an important point. 10 Q. Page 23?
11 MR. ROY: Thank you. Good place to break 11 A. Yes.
12 for lunch. 12 Q. This is apparently, for lack of a better
13 VIDEOGRAPHER: Off record at 12:37 p.m. 13 word, a PowerPoint graphic that appears in this webinar
14 (OFF THE RECORD) 14 presentation that you and Bruce Ebersole did. Correct?
15 VIDEOGRAPHER: On record at 1:20 p.m. 15 A. Yes.
16 BY MR. ROY: 16 Q. It's entitled "Wave Considerations at
17 Q. All right. Where we left off, Dr. Resio, is 17 Levees."
18 talking about a resolution generally -- 18 A. That is correct.
19 A. That's right. 19 Q. What is the (1)? What is that for?
20 Q. -- just to kind of bookend where we were -- 20 A. I hope there's a 2 somewhere. I don't know
21 A. Um-hum. (Affirmative) 21 what the 1 is for.
22 Q. -- thematically. 22 Q. All right.
23 I want to ask you just a few more questions 23 A. If there's another farther on, I would
24 on that before we move on. 24 hope -- if not, it's -- then I have no idea what that
25 (EXHIBIT 16 MARKED) 25 (1) is. I don't see another one anywhere.
Page 143 Page 145
1 BY MR. ROY: 1 Q. Well, let's look specifically at the -- call
2 Q. There is an ASCE Webinar No. 6 entitled "Wave 2 it the orange lettering. That's how it's showing on my
3 Forces and Overtopping," the paper for which I've 3 copy; which it may not have originally been orange, but
4 marked as Exhibit 16, the authors of which are shown to 4 it looks orange.
5 be Bruce Ebersole and you, Don Resio. 5 A. Sure.
6 A. Okay. 6 Q. Did you get a copy? Okay.
7 Q. Would you look at that and tell me if you 7 It reads, "Resolution of 200 meter -- too
8 recognize it and remember it. 8 coarse to resolve levees (ADCIRC is also too coarse)."
9 A. I do recognize it. I somewhat remember it. 9 That's what it reads?
10 Q. How long ago was that ASCE -- which I presume 10 A. That is what it reads.
11 means -- well, what does ASCE mean? 11 Q. Those were your words and Mr. Ebersole's
12 A. American Society of Civil Engineers. 12 words?
13 Q. Okay. Bruce Ebersole is a member of that? 13 A. That is correct.
14 A. And I am too. 14 Q. What's the context? What were you -- what
15 Q. Okay. Even though you are not a civil 15 resolution? Were you talking about specifically STWAVE
16 engineer? 16 resolution?
17 A. I'm a full member because I've done a lot in 17 A. No. I think we were talking about trying to
18 that field. 18 capture the -- to the best of my recollection, here
19 Q. Okay. In any event, when was this webinar 19 we're addressing trying to get the total setup, the
20 given? 20 total surge right at the levee because --
21 A. I think maybe two years ago. That's my 21 Q. Go ahead. I'm sorry.
22 recollection. About this time of the year, maybe two 22 A. All right. So if you're trying to get the
23 years ago. 23 total wave component of the setup right at the levee,
24 Q. All right. Was it an internal -- only for 24 we have to add in this last little bit that is a
25 members of the ASCE? 25 Boussinesq model in order to actually capture that.
37 (Pages 142 to 145)

Page 146 Page 148
1 And ADCIRC -- there's a lot of wave breaking 1 inputs for the COULWAVE modeling. Is that your
2 in the last 200 meters. Let me -- let me turn around. 2 recollection, or do you have a different recollection?
3 In the last 200 meters, if I have 6 or 7 foot of energy 3 A. I have a different recollection.
4 out here, it's all lost between here and the levee. So 4 Q. That's fine. I'm just trying -- we're just
5 all of that can potentially contribute to wave setup. 5 trying to put the pieces of the puzzle together.
6 The ADCIRC models don't -- class of models, none of the 6 What's your recollection?
7 models, whether you use an SLO8 or there's a SL15, they 7 A. Well, my recollection is that Pat Lynett and
8 don't capture that particular -- they don't capture 8 I discussed for -- again, for a different purpose --
9 that. 9 what we would have to do to have a generic look-up
10 I'll just stop. Period. 10 table that you could use that covered all the
11 Q. But my only question is at page 23 -- 11 dimensions of the problem adequately with the generic
12 A. Okay. 12 profile so we could understand some of the general
13 Q. -- when you say ADCIRC is also too coarse, 13 characteristics of runoff, overtopping, setup at a
14 the context I take that to mean is where you say 14 levee. And we discussed what we needed to run and what
15 "Resolution of 200 meter too coarse to resolve levees," 15 sort of sampling we needed and a lot of different
16 you're referring to some other model than ADCIRC. And 16 issues.
17 all I want to know is what other model are you 17 Q. Did Dr. Ebersole provide to you the scaled
18 referring to other than ADCIRC? 18 hydrographs that you ultimately refer to in your report
19 A. Well, I think we're talking about wave 19 and otherwise relied on?
20 considerations at levees. We're trying to say, How do 20 A. He provided the scale factor that I
21 we get the waves exactly right at the levees? And 21 multiplied the hydrographs that I got from ADCIRC.
22 we're saying that really the boundary condition of that 22 Q. From Westerink?
23 200 meters doesn't give you necessarily a particularly 23 A. From Westerink, that's correct.
24 good way to resolve the waves right at the levees, and 24 Q. All right. That scaled information that
25 the -- and you need to run a Boussinesq to try to get 25 Ebersole gave or otherwise that you obtained from the
Page 147 Page 149
1 that in there. 1 ADCIRC went into the COULWAVE?
2 Q. Do you need to run the Boussinesq at less 2 A. It went into the water levels of the
3 than a 200-meter resolution? 3 COULWAVE, yes.
4 A. Yes, you do. 4 Q. Let's get into COULWAVE. In your report at
5 Q. What do you have to run it at? 5 page 5, you're referring to COULWAVE model --
6 A. Well, we run it at about a 9-meter, which is 6 A. Um-hum. (Affirmative)
7 quite a bit less than the 25 meters. 7 Q. -- as having, quote, been favorably reviewed
8 Q. All right. Thank you for clarifying that. 8 by the National Research Council.
9 Before we move into COULWAVE specifically, 9 Do you see that?
10 some cleanup items. 10 A. Yes, I do see that.
11 A. Okay. 11 Q. I didn't see a cite in your report. Can you
12 Q. Dr. Ebersole's testimony was that you took 12 cite me to the publication of the journal or the press
13 the lead on wave issues -- short wave, wind wave 13 release of the National Research Council that has
14 issues. Is that correct? 14 issued an endorsement of the use of COULWAVE
15 A. That's probably true on what needed to be 15 specifically?
16 done. Yes. 16 A. Well, I think they endorsed -- the whole
17 Q. And specifically the question was asked, 17 study was reviewed by the national academy.
18 "Short wave?" And he responded, "Short wave." 18 Q. The whole IPET study?
19 A. Right. 19 A. The whole IPET study. And our part of it,
20 Q. That's true? 20 they sort of signed off on everything we did, and they
21 A. Well, I think he means short wave as -- 21 had a chance -- and we had very good people on that
22 ADCIRC model is long waves. The surge is considered a 22 committee who I think have very good professional
23 long wave, but I think he's distinguishing between wind 23 qualifications, and they did not raise any issues that
24 waves and ADCIRC-type waves. 24 would have -- that would have said this was not done.
25 Q. Mr. Ebersole indicated that he provided the 25 So we thought it would be logical to keep the
38 (Pages 146 to 149)

Page 150 Page 152
1 same model as opposed to -- there were other Boussinesq 1 of water on the levees, wave setup, and overtopping
2 models. That was really the issue. The issue is not 2 rate for water in passing over the levee crest.
3 whether it's a Boussinesq or it's something else. The 3 A. Right.
4 issue is whether we ran this Boussinesq or some other 4 Q. But it did not estimate the velocities of the
5 Boussinesq. 5 water on the MRGO side of the levee, did it?
6 Q. Like what other Boussinesq? 6 A. Well, we didn't print it out.
7 A. Well, there's a Boussinesq that -- I'm trying 7 Q. How about is it in your report?
8 to remember. It's the one that Okey Nwogu developed at 8 A. It's not in my report.
9 the University of Michigan. It's the other real 9 Q. I don't care what else. I just want to know
10 popular one that other people use. 10 if it's in the report.
11 Q. What are their names? 11 A. It's not in the report.
12 A. Okey Nwogu. That is his name. 12 Q. But what is in your report were the COULWAVE
13 Q. The other -- 13 results for the overtopping rates over the levees, over
14 A. I can't -- it's on the tip of my tongue, but 14 the levee crest, and the velocities on the back side.
15 I can't remember it right now. We actually have it 15 A. That's correct.
16 internally in our own suite of models. And I should 16 Q. Why did you omit from your report any mention
17 remember, but I don't. 17 whatsoever of the velocities that would have been
18 Q. All right. I may be dwelling on semantics 18 estimated by COULWAVE on the MRGO face of the levee?
19 here, but I just want to hear it from you. You're not 19 A. Because when we did these runs for a
20 suggesting the National Research Council has come out 20 different purpose, they weren't there, and I didn't --
21 and expressly blessed the use of COULWAVE, are you? 21 I thought that my role in this was to produce
22 A. No, no. It just said we've already used it 22 overtopping that went to the interior drainage people.
23 for this and it was favorably reviewed. They said, 23 Q. Fair enough.
24 "This all looks good to us." And we were at that 24 A. So I produced that.
25 point -- they did not castigate other models. They 25 Q. Okay. Fair enough. And as far as you know,
Page 151 Page 153
1 simply -- they simply did not issue any warning order 1 that's still what your objective was.
2 of anything we did with the COULWAVE on this. 2 A. Well, some people say they wish this had some
3 Q. Well, they didn't address anything other than 3 more; but at that time, I didn't have it, so I couldn't
4 generically addressing IPET with favorable review. 4 give it to them.
5 Isn't that right? 5 Q. Prior to writing your report, had you chosen
6 A. Yeah. They said -- they said that this 6 to -- let's back up.
7 reflected the state of the art. That was exactly -- I 7 When the COULWAVE model that was done that --
8 believe in our meetings, that's exactly what they said. 8 and all that was done by that fellow over in Texas. Is
9 "This was a good execution of the state of the art." 9 that right?
10 Q. The overall IPET at that time? 10 A. That's correct.
11 A. They did it on a detail basis. You know, so 11 Q. He's not with the Corps. Right?
12 it was the -- not -- the overall IPET was so broad. 12 A. No. No.
13 The Storm, Volume IV, they actually liked what we did 13 Q. Okay. And y'all didn't hire him for this
14 in Volume IV quite a bit. 14 job, did you?
15 Q. Dr. Resio, did the National Research Council 15 A. No. He has not been paid at all for this job
16 brand COULWAVE explicitly as the state-of-the-art 16 because he's not working on it.
17 model? 17 Q. And he's not part of the team?
18 A. No. I don't think I said that. 18 A. No.
19 Q. Thank you. Well, anybody who may read that 19 Q. All right.
20 into it would be reading it wrong. That's not your 20 A. But he has been very gracious about it when
21 intention? 21 I've had discussions with him to go back and say,
22 A. No, that's not my intention. 22 Refresh my memory of what we did on this.
23 Q. All right. I just want to clear it up. 23 Q. I got you.
24 A. Okay. 24 But my point is the COULWAVE modeling that
25 Q. Now, the COULWAVE model estimates velocities 25 you did receive work product from that you incorporated
39 (Pages 150 to 153)

Page 154 Page 156
1 in your report, had you said I want to know what these 1 level that's above the levee crest of 2.8 feet, well,
2 values or these functions were for the wave velocities, 2 then I just interpolate between these two. And that's
3 water velocities, on the MRGO side of the levee itself, 3 what I was doing with that.
4 on the levee, against the levee -- 4 Q. Well, for purposes of your interpolation, is
5 A. Yes. 5 that interpolation reflected in the report?
6 Q. -- COULWAVE itself is capable of generating 6 A. Yes.
7 that, isn't it? 7 Q. What still-water level or levels did you
8 A. Yes. And has since then. I went back and 8 assume?
9 asked him to do it. 9 A. I assumed the adjusted 1.12 factor times the
10 Q. When you say you've gone back and asked him 10 other value; times the other value, the ADCIRC value.
11 since, that's since when? January 1st? 11 Q. Are you talking about the adjustment that Mr.
12 A. Yes. Before we -- well, I think it was like 12 --
13 right about the time we were finishing our reports. 13 A. -- Ebersole.
14 And I just said, "Just for my own edification, could 14 Q. -- Ebersole -- actually, Westerink did, I
15 you do this?" And he did it because he already had all 15 believe.
16 the setups done and it was just computer time. 16 A. I mean, I did it.
17 Q. I understand. I understand. 17 Q. One of them.
18 But at the risk of being accused of being 18 A. One of them. It was actually -- when I got
19 redundant, none of that information is either opined on 19 the numbers, they did not have the adjustment. It was
20 or reflected in your report. That's true? 20 straight out of -- but then I did that adjustment
21 A. That is true. 21 inside what I had.
22 Q. All right. Do you know where this person in 22 Q. Do you know which Westerink ADCIRC run result
23 Texas that did the COULWAVE modeling for purposes of 23 output it was based on?
24 your report, where they obtained the input for the 24 A. I mean, there was only one output that was
25 still-water level for purposes of the modeling? 25 given to us for each case, and then we had -- and I
Page 155 Page 157
1 A. Well, that was the beauty of what we did. We 1 forget. It was -- it came to us in a very strange
2 did not -- we ran for a bunch of different water 2 form, but it was all one -- it was maybe like about
3 levels. COULWAVE is -- you only run for about 20 to 30 3 data for 77 points or 177 points or 277 points; and we
4 minutes typically. You have to run about that much to 4 just -- and we actually went in -- I think it would be
5 get a representative sample of waves. And it's a timed 5 more than that, maybe 1,000 points or so. But we went
6 domain model; and during that amount of time, we 6 in and pulled out that line that was right down the
7 assumed that the water would be about constant. So 7 MRGO for our purposes.
8 what we did was we ran a bunch of different water 8 Q. But can you tell me which -- what was the
9 levels, a bunch of different wave heights, and a bunch 9 specific still-water level that was reported to you
10 of different wave periods; and then that allowed us to 10 from Westerink from the ADCIRC run?
11 then just to -- for any other water level, you can just 11 A. I mean, it's time and space varying. So I'm
12 interpolate between. 12 not sure what you're asking.
13 Q. When you say "you ran," you mean this person 13 Are you asking me -- I mean, there's no one.
14 in Texas? 14 It varies in time and it varies in space, so --
15 A. No. I did that part. I did the 15 Q. But you used an average, didn't you?
16 interpolations and everything. That was -- 16 A. Over 30 minutes.
17 Q. You ran COULWAVE yourself here? I thought 17 Q. Did you use a median still water across the
18 you said all the COULWAVE -- 18 MRGO length?
19 A. I did the interpolations. If he gives me a 19 A. No.
20 whole table, a look-up table of all these results that 20 Q. What did you use?
21 he has generated for fixed water levels, and let's just 21 A. I mean, I used -- across the length of it?
22 say there's a water level that's here and a water level 22 No. We had those 21 points that you see in Figure 1, I
23 let's just say 3 feet and one that is at 1 foot -- 23 think it is. Yes, it is Figure 1. At those 21 points
24 that's probably a little too crude. Well, let's just 24 we actually had ADCIRC -- those are ADCIRC points.
25 say that, 3 and 1. And then I have an actual water 25 Q. All right. Coming from Westerink?
40 (Pages 154 to 157)

Page 158 Page 160
1 A. Coming from Westerink. And we had data every 1 Q. What is that?
2 half-hour at those 21 points. 2 A. This is measurements from a real physical
3 Q. Do you know if Westerink had already adjusted 3 model where we have -- where we are generating -- it's
4 those points himself for whatever purpose prior to your 4 like picture a physical model. You see its depiction
5 receiving them? 5 in here in the top. And we actually had a wave
6 A. It was my understanding he had not. 6 generator -- a mechanical wave generator -- generating
7 Q. Do you know which one of the three Westerink 7 waves; and the waves were propagating and going up the
8 runs of ADCIRC that we know of you received? 8 slope. And that's the data that you see reproduced
9 A. No. I assume -- you know, we waited -- you 9 here.
10 have to understand the way we were doing this. This 10 Q. All right. But I asked you at the beginning
11 is -- we had to wait until he was finished, and then he 11 of this deposition if there was any physical modeling
12 sent us what he thought were his best results; and 12 whatsoever to your knowledge that had been done in
13 that's what we used. So he should be able to provide 13 connection with the study of the effects of the MRGO,
14 that information to you. 14 and you told me no.
15 Q. Would you expect that when ADCIRC results are 15 A. Well, not specific to the MRGO. That's
16 provided to you, is it at least your assumption that 16 generic.
17 they're from all the same run? 17 Q. But that's important for me to know today,
18 A. Yes. I mean, that --I mean, along that 18 the difference between something that may have been
19 stretch there, they were supposed -- I don't know -- 19 generic, off the shelf, preexisting, coming from
20 you know, the prior runs, I'm just not sure about. 20 somewhere else versus what was done in this.
21 When he gave it to me, he was satisfied that it was 21 A. Well, in that context, physical modeling is
22 sufficient for my purposes, I guess. 22 done for generic purposes; and, yes, physical modeling
23 Q. All right. So you relied upon Westerink's 23 was used in this. But I actually thought you were
24 calculation of water level through the ADCIRC which you 24 asking a very specific question: Had we built a --
25 then took and interpolated? 25 because we were talking about building the 17th Street
Page 159 Page 161
1 A. And multiplied it times that one factor and 1 area.
2 then -- that's right. 2 Q. I understand.
3 Q. And why did you multiply it times, what, 3 A. And then you were saying had we built one for
4 1.12? 4 the other, and we hadn't.
5 A. That was based on Bruce Ebersole's thing that 5 Q. So let's go to page 25, then.
6 it looked to him as though the water levels were too 6 A. Okay.
7 low in that area by about 12 percent. 7 Q. This is not data from the MRGO event?
8 Q. Anything else? 8 A. No, no. It's --
9 A. No. 9 Q. What's it from?
10 Q. If you would look at page 25 and 26 of your 10 A. It's from a flume. Okay.
11 report, there are two figures, Figure 8 and Figure 9. 11 Q. Where?
12 A. Okay. 12 A. I'd have to run it down. I don't remember.
13 Q. Let's start with the first figure on page 25. 13 It's a -- I would have to check. I'm sure it's around
14 It looks like -- this is the area I'm looking at over 14 somewhere, and I can -- I'm sure I can find it, but I
15 to the right-hand side in the middle where it's got 15 don't have it at the top of my head.
16 "exp. data," and then underneath that, "one layer of 16 We do these type of things all the time. You
17 Boussinesq"; underneath that, "two layers." Do you see 17 have to understand, this is -- this is what they base a
18 that? 18 lot of overtopping rates on and other things. There
19 A. I do. 19 are a lot of these studies done. So I don't know
20 Q. What is -- the blue circle, and then it's got 20 specifically which one this is. We do a lot of them
21 "exp. data." What's exp. data? 21 here in our own lab.
22 A. Laboratory data, experimental data that's 22 Q. We'll come back.
23 actually measurements in a physical model. 23 A. Okay.
24 Q. That's Westerink? 24 Q. But Figure 8 and Figure 9 on page 25 and 26
25 A. No. 25 of your report --
41 (Pages 158 to 161)

Page 162 Page 164
1 A. Yes. 1 Yes. I will give it to you, but I don't -- but it's
2 Q. -- starting with the premise, is it correct 2 going to take -- you know, it was just requested, I
3 that neither one of these calculations were done based 3 think, when I was on vacation week before last for the
4 upon any real data relative to -- regarding the 4 first time. So I will provide all of that to you.
5 specifics of the MRGO and the overtopping or wave 5 Q. Was there a spectrum of different wave
6 action? 6 amplitudes in your opinion coming across Lake Borgne
7 A. No. That's right. Neither of these -- 7 toward the MRGO at the height of the winds and the
8 neither of these had the -- this is a straight 8 surge?
9 1-to-20 -- 1 to -- I'm trying to remember what the 9 A. Yes.
10 slope was. But you can -- you can -- I mean, I can 10 Q. You relied upon Lynett in Texas to determine
11 look all this up and add it in there. But it's just 11 which layers of COULWAVE to use?
12 something that -- it was just an example. 12 A. Yes. He only used a single -- a one-layer
13 The point I was trying to make was actually 13 Boussinesq.
14 more the same -- using the same setup, monochromatic 14 Q. Do you know which version of COULWAVE was
15 and spectral waves were different. 15 used?
16 Q. All right. 16 A. I should, but I don't think I do. Because he
17 A. So I wasn't getting into a lot of the detail 17 has some versions that he has, and he ran it, and I
18 other than that. 18 don't have it. I do -- I actually have the executable
19 Q. I understand. 19 one. I have the same version. I don't know what
20 A. All right. 20 the -- what the -- what the name for that version is.
21 Q. Now, let's go into one-layer Boussinesq. 21 So I know which version he ran, but I don't know the
22 A. Right. 22 name of it. I have the executable, which I guess you
23 Q. And then what's the difference between one 23 can get too.
24 layer and two layer? 24 Q. Do you know if he used the bottom friction
25 A. The formulation of a Boussinesq -- and it can 25 model?
Page 163 Page 165
1 be done in multi layers, but to date it has been done 1 A. He did have some bottom friction in some of
2 primarily in one layer, which is the depth average 2 his runs and no bottom friction in others of his runs.
3 characteristic. You integrate the momentum and the 3 Q. Does that mean he used two different --
4 forces through the water column and the mass 4 A. No, no, no. In these cases I don't believe
5 conservation, and then the two layer actually allows 5 that he did have bottom friction. I believe he just
6 there to be -- but in doing that, you have to have one 6 left it out.
7 average velocity in a sense. In the two layer, you 7 Q. That's my question.
8 actually are allowed to have some water going toward 8 A. Yeah. Well, okay. I believe there's no
9 the surface at one level and some water going -- just 9 bottom friction in this.
10 a -- what's the right term? -- a shear. You have a 10 Q. As you approached the levees along the MRGO,
11 shear in a two-layer system. 11 I believe you said you're encountering breaking waves
12 Q. Are you familiar with the COULWAVE Code 12 for a pretty good period of time, aren't you?
13 Manual? 13 A. That's correct.
14 A. I haven't -- haven't memorized it. I am 14 Q. What did you say, several hundred yards? I'm
15 somewhat familiar with it. 15 not trying to --
16 Q. And this is generated apparently by your 16 A. Yeah. Ballpark, yeah. I mean, coming up off
17 friend, Lynett. To your knowledge, is it, or do you 17 the deep part onto the shallow part, the waves break
18 know? 18 irregularly. Yes.
19 A. I believe it is. He's one of the main 19 Q. What is "thin film rundown"? Do you know?
20 creators of it. He and Lou from Cornell -- so I think 20 In the context of COULWAVE molding.
21 that's -- I think Pat is the one. 21 A. Thin film rundown? I mean, there is a
22 Q. Does your report in any place indicate 22 real -- when you get thin film in most physics, it's
23 whether -- which of the input options regarding shallow 23 talking about the viscus capillary effect which says
24 water wave equations or what-not were -- 24 that there's some order that will always be there and
25 A. I have that. I have not given it to you. 25 will go down very, very slow. And in numerical models
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Page 166 Page 168
1 you have some effect of it where it actually -- because 1 Q. -- to the extent it wasn't already totally
2 of the way the numerical solutions are there, you end 2 submerged, became submerged. Correct?
3 up leaving a little bit of a thin film behind. 3 A. Yes. Right.
4 Is that what you're -- 4 Q. Okay. But how deep does water have to be
5 Q. Specifically in the context of the COULWAVE 5 above a bar for you to call it a bar?
6 Code Manual -- 6 Stated differently, once water gets on top of
7 A. Right. 7 that band of marsh, why, for analogy purposes to
8 Q. -- what's the significance if the bottom 8 COULWAVE, isn't it the same as a bar? It's a
9 friction model is not used? 9 substantially shallower depth than Lake Borgne, and
10 A. You get a little bit higher. I mean, it's -- 10 it's -- it comes back into the MRGO. So when you have
11 you get -- just the bottom friction, you get -- now, he 11 a comparably shallower water there than you do on
12 may have used some friction up there. He didn't use 12 either side of it, why isn't it analogous to a big
13 any on the section coming into there. I can ask. 13 sandbar?
14 Q. In Boussinesq models such as COULWAVE, are 14 A. Well, remember my boundary condition is in
15 you familiar with the term "behind the bar"? A wave 15 the middle of the channel. So I'm only going up a
16 field behind the bar? 16 slope. I'm not coming down into it. I'm going up the
17 A. I am familiar with wave fields behind the 17 slope and then up to the levee and then up, and so I
18 bar. Now, presumably they're talking about the 18 don't think I'm coming -- I don't think I would be
19 nonlinearities. Are you talking specifically about 19 crossing anything that's analogous to a sandbar.
20 that? 20 Q. Tell me, your boundary of COULWAVE is --
21 Q. I'm so much more simplified than that. All I 21 A. -- in the middle --
22 want to know is what bar are you talking about. 22 Q. -- in your understanding, in the middle of
23 A. That's a nearshore bar. 23 the MRGO.
24 Q. Do they serve Budweiser? 24 A. Yes.
25 A. It's a nearshore bar. 25 Q. Okay. Now I understand your point. I got
Page 167 Page 169
1 Q. Like a sandbar? 1 you.
2 A. Sandbar, yeah. 2 Well, but you assumed a shelf.
3 Q. Okay. That's all I need to know. 3 A. Um-hum. (Affirmative)
4 A. Yeah. 4 Q. In fact, you called it a generic shelf
5 Q. So when you talk about "behind the bar," are 5 200 feet long. And at what evaluation?
6 you talking about toward, shall we say, the deeper 6 A. It went up to about 9 feet.
7 water or toward the shore side? Which is behind the 7 Q. Okay. A 9-foot high shelf 200 feet in width
8 bar? 8 generic the entire length of the MRGO Reach 2.
9 A. It's behind in the sense of waves, so it's 9 Correct?
10 the shore side. 10 A. That is correct.
11 Q. The shore side of the bar? 11 Q. All right. Now, certainly you know that
12 A. Yes. 12 there are areas of the MRGO where there's considerably
13 Q. For your calculations of wave velocity to 13 less shelf, considerably more shelf --
14 ultimately be accurate, don't you need to consider the 14 A. Yes.
15 wave field that is behind the bar in the COULWAVE 15 Q. -- or, for that matter, considerably
16 modeling? 16 shallower water?
17 A. I mean, there is no bar. There's no sandbar 17 A. Oh, yes, yes.
18 in this case. So I'm not sure -- are you talking about 18 Q. And certainly many areas where the shelf is
19 like behind the levee? The levee might appear to be a 19 not totally flat as you assume where there's an
20 bar, but I don't think there's a wave field behind it. 20 inclination?
21 Q. Well, let's -- actually, you raise a good 21 A. This is true.
22 point. Within a very short period of time the marsh 22 Q. Yet you made the call --
23 itself, to whatever extent it existed between Lake 23 A. Right.
24 Borgne and Reach 2 of the MRGO -- 24 Q. -- to assume a 9-foot high shelf 200 feet
25 A. Right. 25 from the toe of the levee to the edge of the MRGO
43 (Pages 166 to 169)

Page 170 Page 172
1 totally flat? 1 gigantic computer exercise, and we were not convinced
2 A. That's right. 2 it would provide that much better accuracy. And that's
3 Q. Where in science, the literature, 3 the issue that you were raising is one of accuracy --
4 peer-reviewed articles, do you get the right to make 4 is how accurate is it.
5 those calls as a matter of science? 5 Q. All right. Well, let's talk about what you
6 A. Well, I am very old. That's a joke. 6 did.
7 I think you always have to make 7 A. Okay.
8 approximations, and I think sometimes this is -- in 8 Q. I have taken the liberty of blowing up Figure
9 situations like this, every model that is run has 9 23 --
10 approximations. They don't -- there's no such thing as 10 A. All right.
11 first principles in any of these models. So it's 11 Q. -- from your report.
12 always trade-offs. Whether or not you -- I mean, like 12 MR. ROY: And I'm going to label it
13 Professor Bea, he only runs one profile. And, you 13 Exhibit 17, and I'm going to hand it to you. And
14 know, we tried to say, Well, let's at least look at all 14 I will hand your esteemed lawyer more paper, a
15 the variability that could occur if we looked at lots 15 copy of it, and I'll keep a copy of it.
16 of different profiles and heights. 16 (EXHIBIT 17 MARKED)
17 And when you look at it in that context, you 17 A. Nice paper.
18 always have to make such judicious choices because a 18 BY MR. ROY:
19 Boussinesq is a very, very, very slow model -- not as 19 Q. Now, in terms of the distance along the
20 slow as LS-DYNA, but a very, very slow model. So you 20 profile feet --
21 cannot run it site specific. You know, it's just too 21 A. Um-hum. (Affirmative)
22 long, too tedious, and too computationally impossible 22 Q. -- you've got an elevation scale on the left
23 to do it for this case unless somebody said you need 23 in feet, one on the right in feet.
24 it. And I'm not sure it would increase the accuracy at 24 A. That's correct.
25 all. 25 Q. So is it your intention to illustrate to
Page 171 Page 173
1 Q. But is the ultimate answer to my question 1 scale the bottom, the generic bottom, of the MRGO
2 that what you just told me in the sense that it cannot 2 30 feet deep? Correct?
3 run site specific, it's got to run with the generic? 3 A. Yep.
4 A. No, I did not say that. 4 Q. And you've done that. All right. So I'm
5 Q. All right. Well, tell me what you said. I 5 going to write on here "bottom of MRGO."
6 could tell you if I had the realtime, but go ahead. 6 Have I labeled where you've intended the
7 A. All right. The -- what I was trying to say 7 bottom of MRGO to be?
8 is that if you run -- you can run one or two sites and 8 A. I believe that is, yes.
9 just run it site specific. We did that. We ran five 9 Q. All right. And that's 30 feet?
10 different sites for Katrina. In this case we were 10 A. Yes.
11 going to be running -- and that was very long and very 11 Q. And then what is this slope that traverses
12 tedious. And so that -- 12 from approximately the 250 foot --
13 Q. Now, bookmark that. I'm going to let you 13 A. Right at 300, something to the --
14 continue. 14 Q. 300. I'm sorry.
15 A. Okay. 15 A. 300 to the 600 column.
16 Q. Just bookmark that in your report. 16 Q. Yeah. 300 to the 600.
17 Do you report those five sites? 17 A. Right.
18 A. Not in this report, no. 18 Q. What is that slope?
19 Q. That's what I wanted to know. Go on. 19 A. That's just the -- what's supposed to be a
20 A. So -- but they are reported in IPET. 20 natural slope coming up to the little shelf area there.
21 Q. I understand that. 21 Q. And your understanding, it had that
22 A. And if we then have to run six different -- 22 inclination shown here?
23 well, we didn't know how many alternatives, but let's 23 A. Yes.
24 just say at least six alternatives, and we had to run 24 Q. Okay. And then at the very top between the
25 21 points along there. It was just going to become a 25 top of the MRGO and the levee, I'm going to write the
44 (Pages 170 to 173)

Page 174 Page 176
1 word "levee" and ask you if I have labeled the levee 1 level.
2 correctly. 2 Q. I understand that.
4 Q. The distance from the toe on the MRGO side of 4 Q. What I'm trying to do --
5 the levee to where the MRGO water edge would be, that 5 A. Yeah.
6 is your 200-foot generic shelf? 6 Q. -- is a little bit before that.
8 Q. All right. I'm going to write "200-foot 8 Q. Is the shelf intended to reflect a 9-foot
9 shelf." 9 elevation above the mean still-water level?
10 Have I labeled what you've intended to be the 10 A. It is if you apply it to a levee with the
11 200-foot shelf in that drawing? 11 height that this is, that this has.
12 A. Yes, you have. 12 Q. When you did your -- we had no problem going
13 Q. All right. Now, the levee, how high is this 13 along. I asked you if this was the bottom of MRGO --
14 levee? 14 A. Right.
15 A. If I remember right, you know, I looked -- I 15 Q. -- 30-feet depth. You said yeah, we assumed
16 had it, I think 17 1/2 feet. I mean, I can measure it 16 that.
17 on here, but if I did it right, it should be right at 17 A. Right.
18 17 1/2 feet. It's in here, I believe, correctly. So 18 Q. When I asked you was that the inclination of
19 I'm not sure what the -- well, anyway. 19 the side of MRGO --
20 Q. All right. Well, is your input -- assumption 20 A. I said yes.
21 for the interpolation was 17 1/2 feet? 21 Q. -- you said yes, that's what we assumed.
22 A. Yeah, yeah. It's not -- it's a funny number 22 When I asked you was that the 200-foot shelf, you said
23 because you have to under- -- 23 yes. When I asked you if that was the levee, you said
24 Q. Wasn't it lower? Wasn't 17 1/2 feet the 24 yes.
25 designed height, but elevation was reduced? 25 It's a simple question. This shelf, for
Page 175 Page 177
1 A. Yes. But you have to remember we're using 1 purposes of your calculations, is intended and was
2 this in a different sense. You're trying to interpret 2 calculated --
3 it in a site-specific sense. Remember, we are -- you 3 A. Right.
4 know, we're putting in -- the key parameter to us is 4 Q. -- by you to be 9 feet higher than the mean
5 the difference, the freeboard between the height of the 5 still-water level of the MRGO. Is that right?
6 levee -- we're applying this to levees all up and down. 6 A. And for all the runs we did, it was at
7 There's some places where the levees are 19 feet or 20 7 9 feet. If that's what you're asking, 9 foot is
8 feet. There are other places where the levees are at 8 9 foot. Yes.
9 13 feet or 12 feet. And what we're trying to do is we 9 Q. All right.
10 actually moved the water level relative to the top of 10 VIDEOGRAPHER: Off record at 2:11 p.m.
11 this. So it's almost as though -- you know, it shows 11 (OFF THE RECORD)
12 up as being 9 foot here, but presumably if this whole 12 VIDEOGRAPHER: On record at 2:12 p.m.
13 thing goes down, it's actually a little bit lower. 13 BY MR. ROY:
14 This shelf, I'm sorry. This thing. I'm sorry. 14 Q. All right, when the court reporter had to
15 Q. Okay. That's the one other component I 15 change his tape, we had just been talking about a
16 haven't asked you about here in Exhibit 17. 16 9-foot elevation of the shelf --
17 A. Right. 17 A. Um-hum. (Affirmative)
18 Q. You assume that this shelf, 200-foot shelf on 18 Q. -- that you assumed above the mean
19 Exhibit 17, is 9 feet above the average sea level? 19 still-water level. All right. And before we get to
20 A. What gets preserved in this -- okay, the way 20 the next question that we were talking about,
21 this happens is you have this particular thing, and now 21 Mr. Smith, when we were off the record -- let me
22 you're going to raise the water levels relative to this 22 just -- I just want to get the orientation right.
23 levee and -- okay. Now, the key reference to anything 23 Look at what I've drawn on here, please.
24 else in the whole system is going to be the relative 24 Relative to the 9 feet to the mean still-water level in
25 freeboard between the crest of this levee and the surge 25 the MRGO --
45 (Pages 174 to 177)

Page 178 Page 180
1 A. Right. 1 me illustrating it.
2 Q. -- do I have the references relative to each 2 Q. Okay. So the water level would actually
3 other generally correct? 3 be -- well, back up. The shelf would actually be
4 A. I think so. 4 higher --
5 Q. All right. Now, and we're going to come 5 A. Nine feet. Like I said, I believe it is --
6 back. 6 Q. This shows 7 even though I've marked it 9.
7 MR. ROY: Robin, I think we're going to 7 A. That is exactly right.
8 have to exchange these drawings to reflect -- 8 Q. But it should be 9?
9 since I'm now holding what is in effect the real 9 A. It should be -- well, I'm like 99 percent
10 modified Exhibit 17. 10 sure that for some reason -- I don't know where the 7
11 BY MR. ROY: 11 came from.
12 Q. But let's go back to what Mr. Smith was 12 Q. I got you.
13 talking to you about and I was talking about. 13 A. It's like a brain hiccup.
14 A. Sure. It looks like -- 14 Q. So the 7 in your report on page 45 to the
15 Q. In the report on page 45, you have the -- 15 best of your knowledge is a mistake?
16 well, it's a reference to a 7-foot elevation. 16 A. That is the best of my knowledge.
17 A. Right, um-hum. 17 Q. All right. Now, the reference points that
18 Q. Now, is this a 9-foot high shelf above mean 18 were chosen were the reference points from the IPET
19 still-water level, or is it a 7 foot that you assumed? 19 study, the cross-sections, if you will, of the MRGO?
20 A. I thought it was 9, you know, but now that I 20 A. I think when we did that we just used some
21 look at the report, this is clearly 7. But I think 21 four different transects and picked a number and -- is
22 it's 9; I think it's supposed to be 9. 22 that what you're asking? I'm not sure what you're
23 Q. All right. 23 asking. I mean --
24 A. I'm, like, pretty confident. 24 Q. Let me give you an example.
25 Q. You think -- 25 A. Right.
Page 179 Page 181
1 A. I've got the input. I've got the real 1 Q. Let me -- do you recognize this format here
2 inputs, and it was being done late at night. And I 2 that I'm showing you?
3 have a feeling it's supposed to be 9. It does say 7. 3 A. Looks like some LIDAR. Is that what that is?
4 Q. All right. So when we talk about mean 4 I mean, I --
5 still-water level, we're talking about where the water 5 Q. That's correct. I'm just asking if you've
6 is without this big storm, without a big surge. It's 6 ever seen --
7 kind of just the average of a normal tide, kind of 7 A. -- way too much LIDAR. Okay.
8 where you normally find the water level. Right? 8 Q. Are you familiar with that format?
9 A. Right. 9 A. I mean, it's pretty straightforward. Yes.
10 Q. All right. Okay. Now, let's do substitute. 10 MR. ROY: All right, let me mark that.
11 Hand me your Exhibit 17, and let me put the correct 11 What is next, 18? 19? Eighteen. I'll mark this
12 sticker on here since it's now marked. 12 as Exhibit 18 to your deposition.
13 A. When you get the inputs from Professor 13 A. Okay.
14 Lynett, you'll have what it is. So it's not -- I'm not 14 (EXHIBIT 18 MARKED)
15 trying to -- 15 BY MR. ROY:
16 Q. All right. So Exhibit 17 is your Figure 23 16 Q. Now, I ask you, from looking at this, does it
17 with the markings that I've made on it to reflect the 17 appear to you that the diagonal line that's green and
18 discussion you and I have had. 18 blue running across from the top left to the bottom
19 A. Right. 19 right is a LIDAR representation of the section of the
20 Q. Are those markings more or less accurately in 20 MRGO and that the yellow and black is the transect
21 place to reflect the exchange you and I have had as to 21 line? You're familiar with that, aren't you?
22 heights and widths and depths? 22 A. Yes. Right.
23 A. Right, right. Of course, I mean, with the 23 Q. And that the transect information is in the
24 caveat that the actual line here is 7 feet. Because I 24 graphing on the right. Correct?
25 drew this. This is not out of his input file; this is 25 A. Yes.
46 (Pages 178 to 181)

Page 182 Page 184
1 Q. Assuming this is correct -- 1 A. -- how high that levee is.
2 A. Um-hum. (Affirmative) 2 Q. -- how high that levee is. Right?
3 Q. All right. Then let's -- starting at the 3 A. Right.
4 left and work toward the MRGO, on the left, it shows 4 Q. All right. But what you can tell me is that
5 the levee at 17 1/2 feet. Correct? 5 at the apparent toe of the levee -- which would be at
6 A. Yes, it does. 6 approximately the, what, 35 foot, 30 foot?
7 Q. It shows from the crest of the levee down to 7 A. I'd say about 35 to 40 feet, maybe. I don't
8 the toe of the levee -- 8 know.
9 A. Um-hum. (Affirmative) 9 Q. -- that it's 5 feet high.
10 Q. -- something less than 50 feet? 10 A. That's what it looks like, yes.
11 A. Yes. 11 Q. And that from that point on, it decreases
12 Q. And at the toe of the levee, what does it 12 over the next 100 feet.
13 show the elevation to be? 13 A. A little bit, yeah. It goes down to maybe
14 A. I'm going to say -- 14 4 feet.
15 Q. At the 50-foot mark. 15 Q. Okay. But no matter how you would average
16 A. At the 50-foot mark, about 7 foot, a little 16 them over that distance, you don't come anywhere near
17 under 7 foot. 17 anything as high as 7, 8, or 9 feet as an average
18 Q. All right. And can we agree that it averages 18 height of that bar, do you?
19 down over the next 100 feet? 19 A. For these two profiles, you certainly do not.
20 A. Yes. I was waiting for you to stop. 20 Q. All right. Do you know of any -- any --
21 Q. And the lowest point it gets to as it 21 places on the Reach 1 of the MRGO, the relevant section
22 averages down is what? In the neighborhood of 3 feet, 22 we're dealing with relative to the flooding -- alleged
23 2 1/2 feet? 23 flooding -- of St. Bernard Parish, et al., do you know
24 A. Three feet. Yes, pretty much so. 24 of any section where if you did a similar transect
25 Q. Okay. So if you averaged the elevation of 25 using actual survey or actual LIDAR data --
Page 183 Page 185
1 that above mean still water, you end with something 1 A. Right.
2 considerably less than either 7 or 9 feet, don't you, 2 Q. -- that you end up with a true average of a
3 for the bar? 3 200-foot width bar between the total levee and the
4 A. Yes. 4 MRGO?
5 (EXHIBIT 19 MARKED) 5 A. I mean, there's some because we've seen them;
6 BY MR. ROY: 6 and, in fact, in the paper that we were talking about
7 Q. I'm going to show you another such LIDAR 7 you looking at, there were some examples of that. As
8 transect so I can understand your thought process. 8 to where we got those numbers from -- now, there's some
9 Once again, starting from the left -- 9 higher, some lower -- I would suggest that on figure --
10 A. Um-hum. (Affirmative) 10 excuse me -- Exhibit 18 that if you moved your line
11 Q. And by the way, the one we just looked at -- 11 farther to the north, since this is color-coded, that,
12 A. Right. Exhibit 18? 12 in fact, the toe of the levee would probably be
13 Q. That's right. It is from station 390. 13 substantially higher than you have it here because
14 A. Okay. 14 you're hitting into the blue area.
15 Q. The one we're showing you now, Exhibit 19, I 15 Do you have -- I mean, I can't see the scale
16 suggest to you is at station 490. 16 on this. But you see what I'm talking about? You see
17 A. Okay. 17 the green area at the toe of the levee? Okay. I'll
18 Q. Now, we can't see or we don't know one way or 18 just do it exactly like this. If you look right here
19 another whether we can see the top of the crest of the 19 coming up along this transect, you're coming down
20 levee on the left. Correct? We don't know whether it 20 rather into blue, you're coming down into a green
21 continues to -- 21 color. Now, when you're coming down into the green
22 A. Oh, right, right. Okay. Yes. 22 color, you're going to get a different answer.
23 Q. We can't -- based on this information I 23 This is -- I mean, you know, I agree there's
24 present to you, in fairness, I can't say and you can't 24 a lot of variability here, and you need to capture all
25 tell me -- 25 that variability; and maybe we should run some
47 (Pages 182 to 185)

Page 186 Page 188
1 additional sensitivity studies to say, okay, how much 1 mean, you can get some very slight, like
2 of a difference does it make to run some of these 2 one-in-a-thousand slopes in that area.
3 different things. We had not done that, and maybe we 3 Q. But this isn't one-in-a-thousand slopes that
4 should do that. 4 we're looking at that I'm showing you.
5 Q. Well, do the blue areas on the LIDAR that 5 A. No.
6 you're holding in your hand as Exhibit 18 as well as 6 Q. What are those slopes?
7 the preceding, what does the blue reflect? 7 A. I don't know; I didn't calculate it. But I'm
8 A. I assume those were depth -- this was 8 just saying that I believe what that was trying to
9 color-coded for depth. That's the traditional way of 9 reflect was that when we looked at some, there were
10 doing this. 10 some places where you had hummocks off of there, and
11 Q. All right. 11 you actually had -- leaving a little pile of vegetation
12 A. And so if you go, like I say, slightly to the 12 and different things that were higher than right next
13 north on here, you're going to get a higher toe to the 13 to it, a little slough close to it. So there's a lot
14 levee. But that's what I'm saying; I don't have these 14 of -- I mean, there's -- when we were trying to be
15 things committed to memory. 15 generic -- now, like I say, I think we ought to run
16 Q. And I'm not trying to give you a math test. 16 some sensitivity, and we can run some slopes, and we
17 I'm just trying to understand your thought process. 17 can run some other cases. Those are -- I think we can
18 A. Right. 18 do that within the framework that you're looking at
19 Q. And the problem I've got is using the 19 here quickly, and then we have the answers.
20 analysis of just these two -- and, granted, maybe we 20 I mean, I'll volunteer here -- and I usually
21 could take others and the same result wouldn't be true. 21 don't like to do this. But the -- I mean, in the end
22 But using these two, certainly if you just use the 22 it's really the consequences of it. It's truly the
23 color coding that is apparently the LIDAR coding and 23 consequences. It's not the fact that you have
24 average -- just did a rough back of the envelope in the 24 something different. It's like, okay, I can say
25 back of your mind, you still don't come anywhere near 25 something is different, but the question becomes one of
Page 187 Page 189
1 an average of either a 7-, 8-, or 9-foot shelf. 1 is this -- the consequences, are they 5 percent
2 A. Yes. 2 difference in the overtopping rates or 1 percent
3 Q. That's true, isn't it? 3 difference or a 50 percent difference. And we really
4 A. I think you're right for these two examples. 4 ought to resolve which it is. I'm betting on the 5, 6,
5 Q. I understand. 5 7 percent, but we'll see.
6 A. Okay. 6 Q. You and Ms. Smith have actually published an
7 Q. All right. Now, in both of the examples we 7 article modeling the physics of -- I'm sorry. You and
8 looked at -- perhaps one more so than the other, but 8 Dr. Westerink published an article in modeling physics
9 nevertheless in both of them -- there was an incline of 9 in storm surges. If you want to look at it, you're
10 the shelf -- 10 welcome to. I don't think this is controversial.
11 A. Yes. 11 A. This one is fairly recent, so I still
12 Q. -- between the toe of the levee and the MRGO. 12 remember it.
13 Correct? 13 Q. But you make the statement --
14 A. That is correct. 14 A. Um-hum. (Affirmative)
15 Q. It was not perfectly level. 15 Q. -- do you not, that along the Gulf -- the
16 A. Right. 16 U.S. Gulf Coast, observations have suggested that each
17 Q. Your generic modeling and assumptions assumed 17 14 1/2 kilometers of wetlands leads to a one-meter
18 not only a 9-foot elevation of the 200-foot wide shelf 18 decrease in maximum surge level? Is that correct?
19 above mean height of the MRGO water -- 19 A. That is a direct quote. If you show me
20 A. Right. 20 where, I can probably find it.
21 Q. -- but that it was totally flat. Correct? 21 Q. We'll find it for you.
22 A. Right. 22 A. That's okay. It sounds about right. That
23 Q. That's a bit unusual to find a totally flat 23 sounds -- I thought --
24 surface in an area where waves run up, isn't it? 24 Q. I think it's page 34.
25 A. I mean, with vegetation, not as much. I 25 A. In the figure. Okay. Yeah. Okay. No, no,
48 (Pages 186 to 189)

Page 190 Page 192
1 it's not that figure. 1 Correct?
2 MR. SMITH: Yeah, it is. Don, it's right 2 A. Well, I have some that snuck out without it,
3 here. 3 but --
4 A. Okay. It's next to the figure. Okay. 4 Q. -- you're supposed to get it?
5 One-meter decrease in 14.5 kilometers of wetlands. 5 A. -- you're supposed to get it. There's a big
6 Yes. 6 difference. Sometimes I'd just plain forget, and it
7 BY MR. ROY: 7 goes through and gets published; and nobody really
8 Q. Now, the quote is in the top left corner. 8 comes after me and grabs me.
9 Have you got it? 9 Q. In that same article on page 33 --
10 A. I see it. I found it. 10 A. Okay.
11 Q. All right. Now -- 11 Q. -- you make the statement: "On the other
12 A. Or actually, Robin found it. 12 hand, the more serious threats to the levees in St.
13 Q. -- your reference is footnote 2. 13 Bernard and Plaquemines Parish and potential problems
14 A. Okay. 14 in the canals were not fully appreciated."
15 Q. In footnote 2 is the Corps of Engineers, U.S. 15 Now, I know you're not a levee expert, but
16 Army Engineers District, New Orleans Interim Survey 16 I'm just trying to understand. What was the context of
17 Report, Morgan City, Louisiana, and vicinity, Serial 17 the statement "were not fully appreciated"? I mean,
18 No. 63, U.S. Army Engineers District, New Orleans, 18 I --
19 November 63. 19 A. Which -- here again --
20 A. Okay. 20 Q. Let me show you exactly where it is. You
21 Q. That's a bona fide site? 21 shouldn't have to look for it. We should have it
22 A. I'm assuming it is. I mean, we had the -- 22 marked.
23 Q. Reliable information? 23 A. I just -- sometimes it gives me a context,
24 A. Reliable information as far as we know it. 24 what was I really talking. I mean, I --
25 Q. Okay. 25 Q. Look right here, the very bottom right.
Page 191 Page 193
1 A. Yes. Maybe not be the smartest way to 1 A. Okay. Okay.
2 present that data, but it was in there. 2 Q. Under the "vulnerable New Orleans" --
3 Q. Let me ask you this. Let me ask you this. 3 A. Right.
4 There's a note in here -- and I'm just curious. Right 4 Q. -- go to the very last four lines --
5 above the footnotes on page 38, it says "Both authors 5 A. Right.
6 were supported in part by the systemwide water resource 6 Q. -- the right-hand column.
7 program of the U.S. Army Corps of Engineers. The chief 7 A. Yeah, yeah. Okay.
8 of engineers has granted permission for publication of 8 And what we were -- what we were trying to
9 the contents of this article." 9 get across -- and I'll put it on the record -- is that
10 A. Right. 10 sometimes you don't always know what you don't know.
11 Q. My question is: Does the chief of engineers 11 And I don't -- I think that the Corps of Engineers did
12 have to grant you permission to publish articles? 12 not know some of the things it thought it knew with
13 A. That's boilerplate, but actually he has 13 respect to the design of these levees, the elevations,
14 delegated that responsibility to, like, lab directors 14 the flood walls, and things that we need to improve.
15 and things who then, on his behalf, states that in 15 Q. To your knowledge, prior to Hurricane
16 these articles. So this is actually Dr. Houston, who 16 Katrina, had the impact of wave velocity upon the Reach
17 is the lab director here at ERDC, who is the person who 17 1 -- Reach 2 levees on the Lake Borgne side of those
18 is delegated to say -- say that on his behalf. 18 levees --
19 Q. Let me state it a different way. 19 A. Right.
20 A. Okay. 20 Q. -- the MRGO side, had the Corps ever studied
21 Q. Regardless of who has to put their seal of 21 the effect of wave velocities on that side of the
22 approval on any article you wish to publish while you 22 levees?
23 are or were an employee of the Corps of Engineers -- 23 A. Not to my knowledge. But that would be the
24 A. Right. 24 District doing that, so they could have done it. You
25 Q. -- you have to get a superior to approve it. 25 should probably ask somebody in the District that
49 (Pages 190 to 193)

Page 194 Page 196
1 question, because I haven't, and the researchers up 1 A. Yes.
2 here I do not think have done that -- or had done that. 2 Q. The 3.28 feet was me anecdotally adding --
3 Q. Are you aware of any such study by anyone 3 doing the computation between the two.
4 that was done prior to Katrina? 4 A. Okay.
5 A. I am not aware of it. That's what I'm 5 Q. The meter conversion.
6 saying, but that doesn't -- you should probably ask 6 A. Right.
7 somebody else that one too. 7 Q. But, in fact -- well, do you know? Is it
8 Q. All right, let's go to page 12 of your 8 within your area of expertise to know what other types
9 report. Now, at page 12 of your report, you make the 9 of vegetation that do live in a south Louisiana marsh
10 statement, "Plaintiffs' wave report dubiously assumes 10 such as those marshes, if it's healthy, that, in fact,
11 that a segment of the Reach 2 levee would have been 11 are higher than Spartina?
12 shielded from hurricane winds by cypress trees if the 12 A. I'm sure there are some, but I made the
13 MRGO had not been constructed." 13 caveat at the beginning of this I'm not a biologist, so
14 Do you see where you say that? It's the 14 ...
15 heading A. 15 Q. That's other people?
16 A. Oh, yeah, yeah. Okay. I do. Yeah, yeah, 16 A. Yes.
17 yeah. I passed right by the bold part. Sorry. 17 Q. I mean, if I were to tell you that, you know,
18 Q. No problem. 18 Rousseaus are typically as tall as 3 meters or
19 Now, about five lines down, you make the 19 9.84 feet and are common -- or were common --
20 comment, "It appears to be drawn from a 1930s cypress 20 throughout that area --
21 tree map instead of the 1950 habitat map available -- 21 A. Um-hum. (Affirmative) I would let the
22 data available from just before the MRGO construction." 22 biologists discuss that.
23 A. Right. 23 Q. That's good. All right. But you do make
24 Q. Do you see that? 24 this comment, though. So when you made the comment
25 A. Yes. 25 Spartina is typically not taller than one meter, that
Page 195 Page 197
1 Q. Let me ask you: And that's the basis of that 1 was just parenthetical? You happened to be familiar
2 opinion that you give there. Right? 2 with Spartina?
3 A. Yes. 3 A. I'm familiar with it, yes. And there is some
4 Q. All right. If -- I'm not asking you to 4 of it down there. There's some good stretches of it.
5 agree. It is or it isn't. 5 So I just took that.
6 A. Um-hum. (Affirmative) 6 Q. But you're not holding yourself out in any
7 Q. But I'm asking you if, in fact, due to 7 way as an expert to say it should have been or was not
8 regrowth between '32 and '58 and/or inaccuracies in the 8 the right coefficient of friction for the right
9 map in the '50s, if in fact, for whatever reason, the 9 vegetation. That's a battle between the people
10 1932 land use map actually in part relied upon by 10 plotting what was really there and what is there?
11 plaintiffs' expert is in fact closer to the reality of 11 A. Well, I mean -- I mean, divide it into two
12 1958 vegetation and forestation along the MRGO, then 12 parts.
13 your criticism expressed on page 12 of your report 13 Q. For vegetation?
14 would no longer be valid. 14 A. If somebody specifies a vegetation, I would
15 A. It would certainly be reduced, because the 15 like to enter into the friction coefficient; but if
16 other part of that is that in really, really high 16 someone says -- someone else should say what the
17 winds, a lot of the canopy is blown off the trees, and 17 vegetation is there.
18 you end up with a -- some momentum coming into the 18 Q. That's my point.
19 water column as opposed to the reduction. 19 A. Yes.
20 Q. In reference to a vegetation height of 2 20 Q. Okay. That's good. But you do make the
21 meters for marsh vegetation that's referred to in one 21 point at the bottom of page 13 that cypress trees
22 of our expert reports, the wave reports, your response 22 usually have a height of approximately 5 meters.
23 at page 13 of your report is to the effect that 23 A. Um-hum. (Affirmative)
24 "Spartina is typically not taller than 1 meter" or 24 Q. Do you see where you say that?
25 3.28 feet. Correct? 25 A. On which page did you say?
50 (Pages 194 to 197)

Page 198 Page 200
1 Q. Top of page 14. 1 A. I was trying to say, you know, when I'm down
2 A. Oh, top of page 14. 2 there looking at the vegetative height, I don't see the
3 Q. Yeah. Bottom of 13 and top of 14. 3 100-foot tall vegetation; I see it's pretty short. And
4 A. Right. That's a ballpark. 4 I was trying to gauge some of that, and it just doesn't
5 Q. What type of cypress trees are you talking 5 seem as tall as the 80 to 100 feet that you're talking
6 about? There's mature cypress trees. 6 about.
7 A. Well, you're talking -- I mean, in the swamps 7 Q. Let's put it in the perspective of what the
8 with a lot of -- quite a -- I mean, these are from 8 plaintiffs' experts allege was there prior to the
9 different things that I've seen. So, I mean, I don't 9 construction of the MRGO that was either blown up by
10 see any huge mature cypress trees in a lot of these 10 the Corps of Engineers or destroyed due to increased
11 areas. 11 salinity and what-not corrupting of the marshes and the
12 Q. But my question is to you: You make the 12 swamps in the construction --
13 statement -- I just -- I want to know about the 13 A. Right.
14 statement. 14 Q. -- of MRGO. That's one of our allegations.
15 A. Right. 15 You know that, don't you?
16 Q. You said categorically, "cypress trees 16 A. I mean, I don't really --
17 usually have a height of approximately 5 meters" -- 17 Q. But you have heard that talked among the
18 A. Right. 18 group, haven't you?
19 Q. -- 16.4 feet. 19 A. I have heard it talked a little bit.
20 A. Yeah. 20 Q. All right. All I am saying is that if in
21 Q. You make that statement. Right? 21 fact it is ultimately determined that mature stands of
22 A. Right. 22 cypress forest existed in particular areas, you're not
23 Q. All right. You don't say cypress trees 23 suggesting that anyone should assume they were only 5
24 typically in that area. You don't say cypress trees 24 meters tall, are you?
25 typically in Mississippi, Florida, Jamaica, wherever. 25 A. In a totally different environment than it is
Page 199 Page 201
1 You just say -- 1 now, I'm just saying --
2 A. Right. So I should modify that. 2 Q. Sure. Before the MRGO, before --
3 Q. No, I'm not asking you to modify it. I just 3 A. I don't know. I mean --
4 want to know what cypress tress -- what type of cypress 4 Q. I'm asking you to assume it. You're not
5 trees are you talking about? 5 trying to tell us that cypress trees in a healthy
6 A. The cypress trees that I have seen in this 6 environment are going to tap out at 5 meters tall, are
7 area. 7 you?
8 Q. All right. Are you talking about cypress 8 A. No, no. That's not --
9 bald, common bald cypress? 9 Q. That was not your intention.
10 A. Yeah. I'm talking about the cypress that is 10 A. No, that was not. It was sort of like --
11 really under the -- that is along these areas that are 11 Q. I just want to understand what you said.
12 very stressed. They're not -- 12 A. Right.
13 Q. Well, would it surprise you to know that the 13 Q. All right. Now, let's go to your generic
14 common bald cypress averages -- well, matures -- 60 to 14 profiling and modifying -- modeling assumptions. The
15 100 feet tall? 15 fundamentals of your modeling --
16 A. Oh, of course not. Yeah, they would, and 16 A. Page?
17 they probably do back on the other side back on the -- 17 Q. I'm not on a page right now.
18 Q. Pond cypress can get to be 80 feet tall. 18 A. Oh, that's okay. If you're not on a page,
19 A. Okay. 19 then I'm with you.
20 Q. Willows, sweet gum, 70 to 80 feet. 20 Q. The -- three of the fundamentals of your
21 I mean, my point is: You're not trying to 21 modeling are going to involve your water level, your
22 suggest that one should assume that if there were 22 boundary conditions, and actually your grid resolution.
23 cypress trees, that they were only 5 meters tall? 23 Correct?
24 A. Yeah. I was trying -- 24 A. Say that one more time, please.
25 Q. You didn't mean to do that. 25 MR. ROY: Can you read the question back.
51 (Pages 198 to 201)

Page 202 Page 204
1 COURT REPORTER: "QUESTION: Three of the 1 admission. And you've told me effectively -- not these
2 fundamentals of your modeling are going to 2 words, but the impression I get is that Dr. Lynett has
3 involve your water level, your boundary 3 basically been a good Samaritan and hasn't charged
4 conditions, and actually your grid resolution. 4 anything, and he's just been a good guy doing this
5 Correct?" 5 stuff and furnishing you information and computations.
6 A. So you're saying three different aspects of 6 Right?
7 it? 7 A. This is true.
8 BY MR. ROY: 8 Q. All right. That's good.
9 Q. Yes. 9 Now, if the Corps of Engineers had wanted to,
10 A. Okay. Yes, three different aspects certainly 10 couldn't it have said to Dr. Lynett, Take the time. We
11 are there. 11 will pay you. Run every single one of these
12 Q. There are three fundamental aspects. They 12 computations in their entirety and give us the
13 may not be the only ones. 13 information.
14 A. Right. 14 There's nothing that prevented you from doing
15 Q. But there are three fundamentals. 15 that. Right?
16 A. Certainly, yes. 16 A. The time constraints did. We did not get --
17 Q. All right. At page 44 you seem to be 17 we would not have finished in time. We simply --
18 explaining why you chose not to make separate 20-minute 18 Q. Well, how long --
19 computer runs for each of six scenarios for 21 separate 19 A. -- would not have finished in time.
20 points along Reach 2, for 95 time steps each, and for 20 Q. Well -- so you're saying that whatever
21 20 minutes of simulated time for each process. 21 computer he's got could only run one run at a time?
22 A. Right. 22 A. What I'm saying is that as it was, we almost
23 Q. And you make the statement, quote, it was 23 didn't have enough time even doing it the way we did
24 decided -- I inserted the word "quote," so I want to 24 it, because by the time they finished the surge model
25 make sure I'm reading it right. 25 runs and all the other different runs and we got all
Page 203 Page 205
1 A. Sure. 1 the runs put together, we didn't have much time.
2 Q. Seven lines from the bottom, page 44, "It was 2 Q. Other than time --
3 decided that it would be more efficient to develop a 3 A. Other than time.
4 suitable look-up table," T-A-B-L-E -- 4 Q. -- there's no reason, if you had wanted to,
5 A. Right. 5 you couldn't have said, Give me the specifics of random
6 Q. -- "from a set of runs than to keep the 6 points or compute them all.
7 Boussinesq code over and over." 7 That's a function of time and money.
8 A. Right. "To keep running." I think you may 8 A. Right.
9 have -- 9 Q. Correct?
10 Q. But I have two questions. 10 A. Of course.
11 Right, "to keep running the Boussinesq code 11 Q. In your modeling, the characteristics of the
12 over and over." 12 levee along the MRGO Reach 2 remain the same, don't
13 A. That's correct. 13 they?
14 Q. All right, the two questions here: You say 14 A. Yes.
15 it was decided. 15 Q. Height, crest, breadth, angle of the toe, the
16 A. Um-hum. (Affirmative) 16 whole nine yards.
17 Q. I want to know by whom. You? 17 A. In that modeling.
18 A. Probably, mainly by me, but it was also -- I 18 Q. Yes.
19 discussed it with Professor Lynett in terms of being a 19 A. The application of it is a little different.
20 good tool for estimating overtopping and velocities and 20 Q. Okay. And to close the circle of the
21 setup at a levee. 21 discussion, the exhibit that we went over earlier,
22 Q. Let me just stop right here. 22 specifically Exhibit 17, before I wrote anything on
23 A. Um-hum. (Affirmative) 23 it --
24 Q. I keep hearing Dr. Lynett's name, although 24 A. Right.
25 his name is not referred to in your report by your own 25
52 (Pages 202 to 205)

Page 206 Page 208
1 Q. -- was the generic representation of your, 1 A. I do not have it in here.
2 quote, generic profile for your Boussinesq simulation 2 Q. Well, earlier I asked you if you had
3 with COULWAVE. 3 generated any other report other than that one, and you
4 A. Yes. Well, what I thought it was at that 4 told me no.
5 time. I think it's 2 foot taller now. And I will get 5 A. I didn't generate it. It was back part of
6 the -- and he'll give you all the information as soon 6 the other study. But we do have it available if you
7 as I have time to actually sit down and pull it all 7 want it.
8 into the file. 8 Q. Part of what other study?
9 Q. None of the COULWAVE calculations in any way 9 A. Remember I told you that the original study
10 were derived from underlying inputs of actual survey 10 of what -- of how to do all this was done before we
11 measurements of either levee height or shelf or 11 ever started this.
12 elevation of shelf along the MRGO Reach 2. Correct? 12 Q. For IPET?
13 A. As I said -- I mean, obviously, we did 13 A. No, no. It was done post-IPET but before we
14 something we thought was close. 14 got involved with this with Professor Lynett. And we
15 Q. You made the choices -- 15 did -- we did a number of things. I said, "Well, just
16 A. Yeah. 16 test -- test this, test this, test this, and let me --
17 Q. -- that you did. 17 and tell me how the results come out," and it would
18 A. Yeah. Right. 18 guide us in picking some of the values of these things.
19 Q. I'm just trying to establish -- 19 And I do have a report describing some of those tests.
20 A. You're saying is it -- is there a particular 20 Q. A report dated before this report?
21 profile that looks exactly like that -- 21 A. Yes, it is.
22 Q. No, sir. 22 Q. A report to who?
23 A. -- probably not. 23 A. It was just an informal report. It was just
24 Q. I'm just asking you that you did not rely 24 a -- it was really not a report. It's really just --
25 upon actual survey or LIDAR data -- 25 he sent me, "Here's what I found out."
Page 207 Page 209
1 A. Um-hum. (Affirmative) 1 Q. Okay. So this is something from Lynett to
2 Q. -- to establish the reference points. 2 you?
3 A. Okay. 3 A. Yes.
4 Q. That's true, isn't it? 4 Q. Okay. I'm talking about you. You don't have
5 A. It's probably fair enough to say. 5 any other report you've authored?
6 Q. All right. Now, at page 44 of your report 6 A. No. I agree. I do not have any report that
7 you state, "Sensitivity tests were performed" -- 7 I've authored.
8 A. Yes. 8 Q. And nowhere in your report have you described
9 Q. -- "to ensure that this representation would 9 what sensitivity tests were performed.
10 produce accurate results when the Boussinesq model was 10 A. This is correct.
11 applied." 11 Q. You do agree that the velocity and volume of
12 Do you see that? 12 wave-induced overtopping on the Reach 2 levees was one
13 A. Yes. 13 of the factors that contributed to the destruction of
14 Q. When -- and you consider yourself a 14 those levees in some places.
15 scientist. Right? 15 A. That -- the wave -- the combined waves and
16 A. I try to be. 16 overtopping.
17 Q. What does the word "ensure" mean to you as a 17 Q. I was coming to overtopping.
18 scientist? 18 A. You were kind of -- I mean, the waves and --
19 A. Try your best to make sure it happens. 19 Q. In fairness to you -- there's no ambiguity
20 Q. In your report take me to the page or pages 20 here --
21 where you specifically describe the exact sensitivity 21 A. Right.
22 test that you performed. 22 Q. -- you believe that wave overtopping and/or
23 A. I have a separate report if you would like 23 the surge overtopping --
24 it. 24 A. Right.
25 Q. We're talking -- 25 Q. -- of the levees were forces -- someone else
53 (Pages 206 to 209)

Page 210 Page 212
1 will characterize to what extent and how -- but were 1 VIDEOGRAPHER: Off record at 3:01 p.m.
2 forces contributing to the demise of the levees. 2 (OFF THE RECORD)
3 Right? 3 VIDEOGRAPHER: On record at 3:19 p.m.
4 A. I mean, presumably, yeah. That's the main 4 BY MR. ROY:
5 source of -- but, again, that kicks it back over into 5 Q. Dr. Resio --
6 Ebersole part of it. 6 MR. ROY: Let's be sure we didn't leave an
7 Q. That's fine. You're not a levee -- 7 unanswered question.
8 A. Yeah. That's -- I'm trying to think of the 8 Can you either show me or read back.
9 right -- I don't want to get it -- because no matter 9 COURT REPORTER: "QUESTION: Would it
10 what I say, it will be construed to be different -- 10 surprise you to know along the Reach 2 in places,
11 Q. Well, that's fine. 11 there are actually -- the levee -- there was
12 A. -- than -- 12 actually a part of the levee up to 22 feet in
13 Q. I mean, all I'm saying is if you're not going 13 height in 2002?
14 to come to court and give expert opinions about these 14 "ANSWER: No, it would not surprise me."
15 things, these volumes, these velocities, caused 15 MR. ROY: So he answered it.
16 damage -- 16 (OFF THE RECORD)
17 A. No. 17 (EXHIBIT 20 MARKED)
18 Q. -- to levees. That's somebody else to 18 BY MR. ROY:
19 extrapolate? 19 Q. I have shown you figure 24 from your report,
20 A. Yes. You can kick me out of that one. 20 and I've marked it Resio 20 and it's before you. I
21 Q. All you're going to say is there were volumes 21 have modified it by placing blue letters in several
22 going across the top at this rate -- 22 locations A through J. So when you and I are talking
23 A. Right. 23 and for purposes of the record, without me standing up
24 Q. -- and velocities on the back side at this 24 and holding up to the camera and so forth, we know what
25 rate? 25 points we're referring to. Okay?
Page 211 Page 213
1 A. And the crest, yes. 1 You recognize figure 24 from --
2 Q. Okay. 2 A. Yes.
3 A. Was this an exhibit that got handed to me? 3 Q. -- your report.
4 Q. We never marked it, but I need to. 4 A. Right.
5 A. That's fine with me, then. I'll just pass it 5 Q. It's entitled "Snapshot of Water Surface from
6 back to you if you want it. 6 Boussinesq Simulation of Generic Profile. The green
7 Q. You want a souvenir? 7 spikes denotes strong wave breaking episodes."
8 A. That's all right. I think I have a few. 8 A. Right.
9 Q. Would it surprise you to know that along the 9 Q. Now, is this intended to be the actual
10 Reach 2 in places, there are actually -- the levee -- 10 representation, a snapshot, of -- to scale -- of what's
11 there was actually a part of the levee up to 22 feet in 11 going on --
12 height in 2002? 12 A. Well, I think --
13 A. No, it would not surprise me. They were 13 Q. -- at the MRGO and the MRGO levees?
14 quite variable. There were also some very low parts. 14 A. No. Well, I think from somewhere over here,
15 THE WITNESS: Can I go ahead and take a 15 it is. I think from back that way, it's not.
16 break just because we're -- I know we've got 16 Q. From the left side of the drawing?
17 probably a couple more minutes now. Isn't that 17 A. Left side, it's not.
18 right on that? 18 Q. Well, let's start on the left side.
19 VIDEOGRAPHER: Yeah. About ten minutes. 19 Where I've drawn the letter A in blue, you
20 THE WITNESS: Yeah. So why don't we go 20 see that 0 to the right?
21 ahead and take a break because it's 3:00 and I've 21 A. I do, and I don't know what that is.
22 been going for about an hour and forty-five 22 Q. That was going to be my question. What is
23 minutes. 23 that?
24 MR. ROY: Go ahead. 24 A. Let me see if it's a better . . .
25 THE WITNESS: Thank you. 25 Q. Could that be the mean still-water height
54 (Pages 210 to 213)

Page 214 Page 216
1 assumption -- 1 Q. All right. Okay. Now, so where I've drawn a
2 A. No. 2 C, the D, and the E, then the distance between C and
3 Q. -- of 0? 3 D --
4 A. No, because it's -- I mean, you can see the 0 4 A. Right.
5 is clearly a 0 with a line through it. It's that 5 Q. -- would be one meter. Correct?
6 greenish line down at the bottom. This is the 0 down 6 A. The distance between what?
7 here. And -- 7 Q. C and D.
8 Q. Stop if you would. 8 A. Yes, I found it. Yes, that would be one
9 A. Okay. 9 meter in the vertical.
10 Q. The green line across the bottom that has a 10 Q. As best you can see the distance on the grid
11 letter C through it, an I, and a J written by me -- 11 between D and E, that linear square side line would be
12 A. Yes. Right, right. 12 100 meters.
13 Q. -- that's the line that is the mean -- 13 A. Is 100 meters. That's correct.
14 A. That's the still-water level before it's any 14 MR. SMITH: Do you want to look on here?
15 surge there. 15 It looks like it's 50 on the digital copy.
16 Q. All right. I am going to write "still-water 16 THE WITNESS: Okay. That's what I'm
17 level." And if you would, hand me your drawing and let 17 saying. I can't quite read it on here.
18 me just draw it on there, too, so that it's correctly 18 MR. SMITH: Well, it's pretty hard to read
19 labeled. 19 on the digital too.
20 A. Okay. 20 MR. ROY: You can read it?
21 Q. All right, have we got it labeled right where 21 MR. SMITH: It's a little clearer on the
22 you want it? 22 digital.
23 A. I believe so. 23 A. (Reviews document) Yeah, I think -- I think
24 Q. All right. So that's 0. 24 that is 50. Yeah.
25 A. Right. 25
Page 215 Page 217
1 Q. Okay. So where the letter A is, whatever 1 BY MR. ROY:
2 that 0 is to the right, we don't know what that is? 2 Q. So it's 50 --
3 A. No, I don't know. 3 A. -- meters.
4 Q. That's good. That's good. 4 Q. Fifty meters. All right.
5 Was this figure 24 generated by you? 5 A. I can read it on that. Thank you.
6 A. No, no. Took it out of a -- out of some 6 Q. All right. So the grids going up or down are
7 stuff he sent me. In fact -- 7 a meter. The grids going left and right are 50 meters.
8 Q. Stuff who sent you? 8 A. Right.
9 A. Some files. Some files that were old files, 9 Q. Okay. At the point that's marked with the B,
10 not -- nothing recent, but this was actually the height 10 is that just a centering?
11 in meters relative to the 0 is the actual left-hand 11 A. No. I think it's actually where -- the way
12 side. The right-hand side -- excuse me, the Y axis. 12 these things run is you have -- is you actually have a
13 The X axis is a scale, and I don't remember what it 13 place you drive the water surface, and you let it go in
14 was -- and you probably can read it. I thought it came 14 both directions. And the reason why is to let the
15 across better than this, but it didn't. 15 reflections that come off of the levee go back and
16 Q. Well, let's just orient ourselves on here 16 propagate into what's called the sponge layer over here
17 first, and then I've got questions about this. 17 that absorbs all that energy.
18 A. Sure. 18 So you don't -- if you remember, we had in
19 Q. The still-water level is the 0 water line. 19 Professor Bea's, you had all this other motions there
20 It's the mean still-water level going up or down. Each 20 that were due to reflections of his basically boundary
21 line up, each line down is a meter. Right? 21 condition, and that slope is to keep that from
22 A. That's correct. 22 happening here. So I believe B is where the actual
23 Q. Each grid to the right, is that a meter? 23 center of the MRGO is assumed. And everything else is
24 A. No. No. I think it's 100 meters, but I 24 just fictitious sponge layer absorbing area.
25 can't quite read it. 25 Q. You assume a generic width of the MRGO as
55 (Pages 214 to 217)

Page 218 Page 220
1 what? 1 Q. Okay.
2 A. 200 meters, approximately, if I remember 2 A. Right.
3 right. I mean, it's on here. Well, it's a little over 3 Q. So --
4 20 meters on there. But, again, that's just 4 A. Or 2.8. I forget what that is in meters.
5 illustrations. 5 It's 2.8 ballpark.
6 Q. The levee that you have scaled in place here 6 Q. So in feet, your assumption, what's the
7 is how high? 7 equivalent of 2.3 meters?
8 A. Meters, 5-point something meters. Do you 8 A. 2.3 meters times 3.3 is going to be -- hold
9 want an exact number? I thought it was about 17 1/2 9 on. And I'm just making it approximate. It's going to
10 foot, so 5.2 meters maybe. I don't know. 5.3 meters. 10 be about 7.5 feet. And again, we're rounding off all
11 Q. What would that be in feet? 11 sorts of things here, so, you know, if I'm within a
12 A. Do you want me to do the calculation 12 half-foot, then we'll call it. Or I can get a
13 longhand? 13 calculator out of my briefcase and I can do these
14 Q. Would you? I just want to you to tell me in 14 things a little better.
15 feet -- 15 Q. Now, wherever you have used an elevation of
16 A. All right, let me see. 16 the ledge between the toe of the levee and the MRGO
17 Q. -- and in meters what you scale this to be. 17 that's in the framework in your report, you called it
18 A. 5.3. It's all done in meters internally, and 18 7 feet, but verbally today --
19 I have to report in feet. I'm just going to round it 19 A. Yeah, it's 9.
20 off. If it were 5.3 only -- if it were 5.4, then 20 Q. -- you've told us 9 feet.
21 that's pushing up towards about 17 1/2. 21 A. And you can see the 9 here.
22 Q. Okay. Check the vertical scale. You had 22 Q. If it's 9 feet, then you're assuming a 15 1/2
23 told me earlier it was one meter. Do you still believe 23 foot -- 16 1/2 foot, actually -- crest height of a
24 it's a one-meter vertical scale? 24 levee. Right?
25 MR. SMITH: You can look at it. The 25 A. I don't know. I'd have to -- again, what is
Page 219 Page 221
1 numbers go up by one. 1 5.3, 5.4 meters. That's about the height of this. If
2 A. They go up by one, yes. 2 you go across the axis, it's 5.3, 5.4. That's over
3 BY MR. ROY: 3 17 feet. So I think if it's 5.4 meters, I believe
4 Q. So did I understand you to say 2.3 -- is that 4 you're up towards 17 1/2. Five meters, isn't that
5 what you said in feet? 5 right about 16.5?
6 A. 5.3. 6 Q. The 9 feet of the shelf is basically the
7 Q. Okay. 7 distance from point I, which is still-water level --
8 A. Oh, you're talking about -- that's the 8 A. Right.
9 elevation of the top of the levee. 9 Q. -- up to the horizontal line at point F.
10 Q. The elevation of the levee from the toe -- 10 A. That's correct.
11 from G to N? 11 Q. All right. That's 9 feet?
12 A. Oh, you're talking about the toe of the 12 A. Right.
13 levee. 13 Q. Then from the G up to H, the top of the levee
14 Q. From G to N. 14 shown here --
15 A. Oh, I don't know. Just -- you'll have to 15 A. Right.
16 subtract. The top -- the crest of the levee is about 16 Q. -- you told me we've got another 17 1/2 feet.
17 17 1/2 feet. 17 A. No, no. You said it was 2.3 meters.
18 Q. I understand. 18 Q. That's what you had told me.
19 A. Okay. 19 A. Well, I didn't remember doing that.
20 Q. But on the scale of this here that you're 20 Q. Well, tell me what it is. I thought you
21 reporting -- 21 looked to see.
22 A. I'm going to -- I mean -- 22 A. No, I don't think so. But it looks to me
23 Q. -- would be approximately 2.3 meters? 23 like even if it just went from the two-meter level to
24 A. Right. On top of the 9 feet that it's 24 H, it's going to be maybe 2.4ish meters. And then
25 raised. 25 you've got maybe -- let's just say 2.7, 2.7. And I'm
56 (Pages 218 to 221)

Page 222 Page 224
1 rounding off to 3.3 times it. I get about 8.9 feet. 1 Q. Take a look at page 45 of your report, the
2 Plus about 9. That's a little too much, but I rounded 2 last paragraph, first three lines.
3 it up. I missed it a little to the high side this 3 A. Right.
4 time. I was a little bit too low last time. 4 Q. Okay. You say, "The incident wave boundary
5 Q. The I and J, you've got spikes denoting 5 was specified in a region that was 30 feet deep and
6 strong wave-breaking episodes. Why is there one at the 6 allowed to run up to the beginning of our generic shelf
7 I location? 7 over a distance of 300 feet."
8 A. Because this real steep front phase is 8 A. Right. And I believe if you look on this,
9 actually wave breaking going on there inside the toe. 9 it's about 300 feet from the base of this. That's what
10 Q. Okay. And is there no wave breaking 10 I'm trying to say. Now, if we want to change the
11 whatsoever under your analysis with these assumptions 11 words, but from here to here, I believe that's about
12 at all between the toe of the levee and the edge of the 12 300 feet.
13 MRGO at point F? 13 Q. So you're talking about, then, 300 feet
14 A. I mean, this is a snapshot. So at this 14 vertical.
15 particular time that's where the breaking is. 15 A. Yes.
16 Q. All right. If you -- go ahead. 16 Q. Slight angle?
17 A. I'm sorry. If you're asking about what's 17 A. Well, 300 foot horizontal that you're running
18 happening at some other time, this breaking will in 18 up. I mean, there is 300 feet from here to there. And
19 fact propagate across there. So the breaking gets 19 I believe if you kept coming back down to the bottom of
20 initiated. And then actually, as you've seen white 20 this, that's what it was too.
21 caps and waves, it continues to break. So it's not 21 Q. You're on Exhibit 17.
22 like there's one place where the waves break. 22 A. Yes.
23 Q. So it starts at point F? 23 Q. On Exhibit 17 I'm going to write the letter A
24 A. It may not have even started. Well, it would 24 next to the line you're pointing to. And that's on
25 probably start somewhere coming up this slope. 25 your figure 23 in your report. You're saying that line
Page 223 Page 225
1 Q. All right. And then working its way to the 1 is supposed to be 300 feet?
2 right -- 2 A. It covers 300 feet of horizontal distance.
3 A. Right. 3 Q. How is that possible if the MRGO is only
4 Q. -- until finally it's coming across the top 4 assumed to be 30 feet deep? And then look at the scale
5 of the levee across the back? 5 on the bottom.
6 A. I think for this particular wave it looks 6 A. It says -- well, I mean, you've got -- I
7 like it's going to keep breaking for a while. 7 mean, I'm looking at this and I see about 300 feet
8 Q. All right. I understand. 8 here, and it looks like the top of it is 600 feet. To
9 Now, for purposes of this you assumed the 9 me it looks like 300 feet.
10 incident wave boundary was 30 feet deep, and it is 10 Q. How tall is the levee in that?
11 allowed to run up beginning on the generic shelf over a 11 A. Well, I mean, it could be any height. I'm
12 distance of 300 feet. Correct? 12 not to the levee on this. I'm talking about from
13 A. Okay. If I remember right, yes. 13 here -- from here to here is 300 feet. From here to
14 Q. That's what's in your report. 14 here is 300 feet. It's about 300 right here and it's
15 A. I know. And that's what I'm saying. If I 15 about 600 over here.
16 remember it right, that is what it is. 16 Q. All right. Why don't you, if you would, just
17 Q. So one end of the 3- -- where is the 300 feet 17 draw lines with 300, 600, so -- you know, arrows
18 closest to the levee? Where is -- if you were to drive 18 pointing each way -- so we'll know what your reference
19 a stake and say this is where that edge of the 300 feet 19 is.
20 is. 20 A. There's 300 approximately and there's 600.
21 A. I thought that was supposed to be 200 feet, 21 Is that what you wanted?
22 but the runoff, I believe, was this slope coming -- you 22 Q. Yeah.
23 see that long linear slope from the bottom to the top. 23 A. Okay.
24 I believe that's the 300 foot maybe. I don't -- you 24 Q. All right. Now, how did you choose 300 feet
25 know -- 25 for your generic distance that you're going to carry
57 (Pages 222 to 225)

Page 226 Page 228
1 this? 1 Q. Up near the top of the paragraph do you see
2 A. Well, I didn't actually. I mean, I talked 2 where you say "Incident waves were run for a number of
3 about it with Pat Lynett, but Pat came up with that 3 significant wave heights (0, 2, 4, 6, and 8 feet) and a
4 generic profile, and I was just trying to report to you 4 number of spectral peak wave periods (6, 8, and 12
5 what he had used back in that study. So it seemed 5 seconds)"?
6 sensible. I didn't have any reason to question it, and 6 A. Um-hum. (Affirmative) Yes, I do.
7 so I didn't. 7 Q. "And a number of relative freeboards (-4, -2,
8 Q. Nowhere in your report are the -- is the 8 0, and 2 feet)."
9 reasoning or the assumptions given or the underlying 9 A. That is correct.
10 scientific basis for making that 300 foot -- 10 Q. All right. Were run by whom?
11 A. No. 11 A. By Lynett before -- again, back to the, as I
12 Q. -- distance? 12 said, were run before we ever started this study.
13 A. No, it's not in the generic sense. 13 Q. Where are the results reported in your report
14 Q. Well, in any sense. It's not listed. 14 for each of those parameters, that is, significant wave
15 A. It's a generic profile. I'm just trying 15 heights of 0, 2, 4, 6, and 8; a number of spectral peak
16 to -- well, it's just not made; you're right. 16 wave periods 6, 8, and 12 seconds; and a number of
17 Q. And you then make the comment that -- once 17 relative freeboards, -4, -2, 0, and 2 feet?
18 again referring to the incident wave boundary -- "was 18 A. I don't believe they are reported in the
19 set in a manner that allowed reflected waves to pass 19 report. It was just used -- it was an input to the
20 back through this boundary location rather than to be 20 program that I could put it in an appendix.
21 rereflected." 21 Q. When you talk about relative freeboards of
22 A. Right. That's the -- 22 -4 feet, -2 feet, 0 feet, and I presume that's +2 feet,
23 Q. Did you tell Lynett to do that? 23 each of those are relative to the top of your generic
24 A. That's how he normally runs -- that's the 24 levee?
25 normal running. 25 A. Yes.
Page 227 Page 229
1 Q. Did you tell Lynett to do that? 1 Q. What are you relying upon to even input an
2 A. I agreed it should be done that way, yes. We 2 assumption of spectral peak wave periods of as high as
3 discussed it needs to be done that way or otherwise you 3 12 seconds? Where is that coming from?
4 get all sorts -- all sorts of nasty reflections. 4 A. Hurricanes in general have that. I mean,
5 Q. When you get reflection, do you get different 5 they do. I see you're nodding -- you're shaking your
6 directional energies coming out of the waves? 6 head. But hurricanes in general have peak periods up
7 A. All of this is unidirectional, so we're 7 to 16 seconds. So it's not unusual at all to need
8 not -- so if you're asking did we have different 8 something that would have the capability of handling
9 directions being considered here, they're not. It's 9 such a wave.
10 the same as Professor Bea's. His was unidirectionally. 10 Q. Are you aware whether or not any of the
11 Q. When did you realize that what you told us in 11 ADCIRC modeling or the STWAVE modeling superimposed on
12 your report as being the height of your generic shelf 12 the ADCIRC of Westerink done for this litigation with
13 on page 45 as being 7 feet flat with an elevation of 13 your team -- do you know what the highest spectral wave
14 7 feet, when did you decide or realize that that was an 14 peak period was that they reported?
15 error and it should have been 9 feet? 15 A. For specifically along this reach?
16 A. Probably about an hour ago, an hour and a 16 Q. Yes.
17 half. I didn't know it. Actually, if you had asked 17 A. Okay. Specifically along this reach, it's
18 me, I thought it was 9 feet in the report. 18 pretty low, maybe 6 to 7 seconds would be my -- just
19 Now, why it's 7 feet in the report, I don't 19 real quick -- I can find it real quick. It's -- yeah.
20 know. Why I drew it 7 feet in the report must have 20 That's probably a good guess, 6 to 7 seconds.
21 been some early conversion -- everything that Pat does, 21 Q. What page are you on?
22 he does metric, so I'm always converting meters to 22 A. I'm on 26.
23 feet. And I goofed up. 23 Q. Page 26?
24 Q. Look at page 47 of your report. 24 A. Yeah. If you look at figure 26-- I'm sorry.
25 A. Okay. 25 Page 54, figure 26. And I have it in --
58 (Pages 226 to 229)

Page 230 Page 232
1 Q. All right. Well, if that's the highest, 1 Q. In any of the modeling that you did. Yeah,
2 then why would you -- why would you want these 2 STWAVE.
3 assumptions going in of 12-second spectral peak wave 3 A. STWAVE -- it varies from place to place.
4 periods when you know they don't even get as high as 8? 4 It's the same bathymetry that -- I mean, you can look
5 A. Well, it's not an assumption, first of all. 5 at the bathymetry that Westerink had, and that's what
6 That's a misnomer just to call it an assumption. It 6 it is. So at different transects, it's different. And
7 is, in fact, simply what cases we ran. We ran six 7 you can . . .
8 seconds, which is very relevant for this. 8 Q. At the peak wind condition during the two
9 Had you been down in Plaquemines Parish, you 9 hours of peak winds of Katrina, how high -- and I don't
10 would have wanted the eight seconds. Or -- and -- or 10 want to get into semantics whether it was surge wave
11 the -- maybe even if you go far enough down to Venice 11 height water from -- if you're using for purposes of
12 or something, you might have wanted the 12 seconds. So 12 this discussion, a marsh elevation of zero.
13 it was intended to be a more broad application. Now, 13 A. Okay. All right. Fair enough. Fair enough.
14 that's why they were run to cover that much of a range. 14 Q. What was the height, approximately, of the
15 But you only used the part of it that is actually 15 water?
16 there. So in this case, if it's six seconds, it's six 16 A. In different places where you -- I mean, you
17 seconds. If it's seven seconds, it's interpolated 17 can see it on this figure. It's -- say, ballpark, 17
18 between six seconds and eight seconds. 18 to 18 feet, maybe 19, even, in places here.
19 Q. On page 54 where you talk about in Figure 26, 19 Q. So depending on where you were on Reach 2,
20 maximum surge levels -- 20 somewhere 15 to 19 feet?
21 A. Okay. 21 A. Fair enough.
22 Q. -- aren't you -- and isn't your maximum 22 Q. And we'd then need to put the wind-generated
23 basically an averaged maximum surge level based on the 23 waves on top of that. Right?
24 information you've been telling me? 24 A. Yes, we do.
25 A. You mean like 30-minute average? 25 Q. Let's just talk about the 15 to 19 feet.
Page 231 Page 233
1 Q. Yeah. At least. 1 You're calling that "surge elevation"?
2 A. Well, I mean, it's not more than that. It's 2 A. Well, it's the still-water level. And it's a
3 a 30-minute average, yes. 3 surge. It's depth. It's anything you want it to be.
4 Q. A 30-minute average across the length of a 4 (OFF THE RECORD)
5 generic MRGO levee with a generic shelf, a generic 5 THE WITNESS: While you guys are hunting,
6 wave, a 30-foot generic water depth, and a static 6 I'm going to just step out to the bathroom.
7 width. 7 VIDEOGRAPHER: Off record at 3:54 p.m.
8 A. It's a generic at the boundary, I'm assuming. 8 (OFF THE RECORD)
9 It's the -- it's exactly at the boundary, and it is 9 VIDEOGRAPHER: On record a at 3:58 p.m.
10 the -- it's a specific point. It's not an -- it's not 10 BY MR. ROY:
11 averaged spatially. It is averaged in time for 30 11 Q. Okay, is it your understanding that Lake
12 minutes. If you went to another point in either 12 Borgne has an average mean still-water depth of about 9
13 direction from there, you would get a different number. 13 or 10 feet?
14 It would be something different. 14 A. Vaguely, yes.
15 Q. Earlier today I asked you if it was your 15 Q. Does it do violence to your recollection?
16 belief that waves regenerated crossing the MRGO, and I 16 Let's put it like that.
17 believe you told me even at the widest point, it 17 A. No, it does not do violence to my
18 wouldn't exceed it a foot. Is that correct? 18 recollection.
19 A. That's the impression I gave, yes. 19 Q. All right. That's good.
20 Q. All right. What depth -- if you know. If 20 And so I'm clear, if in fact the marsh area
21 you don't, don't answer -- what elevation at mean 21 between the MRGO and Lake Borgne is -- call it a
22 still-water level did you give for the marsh between 22 one-foot elevation above sea level. I mean, that you
23 MRGO and Lake Borgne? 23 take your 15- to 19-foot surge, stack it on top of
24 A. I mean, between the MRGO and the Lake Borgne 24 that, if you took one foot off, then basically we're --
25 in the STWAVE? 25 well, first you're basically stacking that on top of
59 (Pages 230 to 233)

Page 234 Page 236
1 the average depth of Lake Borgne until you get to the 1 average surge.
2 marsh. Right? 2 A. Okay.
3 A. That's correct. 3 Q. -- we've got an approximate depth of about
4 Q. All right. And then on top of that you've 4 25 feet across the Lake Borgne fetch.
5 got whatever your wave's height is. Correct? 5 A. Yes.
6 A. Okay. 6 Q. With prevailing winds from the east or
7 Q. So peak waves in Lake Borgne at the period of 7 northeast angled essentially perpendicular against
8 peak winds, can you tell me what your belief is they 8 MRGO.
9 were? What height? 9 A. Okay.
10 A. I mean, I can look here and I can give you 10 Q. At the peak time.
11 what they were in our runs. Is that what you're asking 11 A. Okay.
12 me to do? 12 Q. That's what it was as your understanding.
13 Q. You're talking about the generic runs? 13 Correct?
14 A. No, no, no. The peak waves would have been 14 A. Yeah. The winds were coming almost
15 out of the input in Lake Borgne or STWAVE. Is that 15 perpendicular to it, yes.
16 what you're asking me to look at, what the -- 16 Q. All right. So would the appropriate, then,
17 Q. This is from your modeling. 17 calculation to figure the fetch and the wave be figure
18 A. Right. 18 1-37? 1-37 on page 59?
19 Q. Let me ask you this: Are you familiar with 19 A. For a 25-foot --
20 the Shore Protection, Planning and Design manual? 20 Q. 1-37 on page 59.
21 A. Yes. 21 A. Right. Right.
22 Q. "Technical Report" -- 22 Q. Forecasting curves for shallow water waves
23 A. An oldie but goodie, yes. 23 constant depth of 25 feet.
24 Q. Thirtieth -- Third Edition, 1966? 24 A. Okay. Let's make that assumption for now.
25 A. Okay. 25 Q. All right. So we know that the fetch in that
Page 235 Page 237
1 Q. Are the tables shown at page 58, 60, 61, and 1 distance is, from our earlier discussion, at least
2 so forth, have they ever been withdrawn or declared by 2 25 miles, maybe more. So you take the maximum here --
3 the Corps to be null, void, ab initio, invalid, or 3 A. Um-hum. (Affirmative)
4 otherwise improper? 4 Q. -- wouldn't you? What would that be? The
5 A. I mean, I don't think they have, but I'm not 5 far right with 100-mile-an-hour winds?
6 sure -- I don't see anybody using them, but I don't 6 A. Ten -- I'm trying -- let's see. We've got
7 think they've ever been withdrawn for sure. 7 the fetch in feet, so you're saying it's 20 miles.
8 Q. Okay. 8 Let's just say -- what's -- times 5,000. That's
9 A. I think it's just based on data, I believe, 9 100,000, so it would be 10. It would in fact be the
10 and extrapolation. Good old Munk Reichschneider 10 far right, yes.
11 (phonetic). 11 Q. All right. And 100-mile-an-hour winds I
12 Q. Well -- 12 don't believe anybody's disputed as being the peak
13 A. But that's okay. I mean -- yeah. I mean, 13 winds. Are you aware of anybody saying they weren't
14 they're probably reasonably relevant, I would think. 14 around 100 miles an hour?
15 Q. When constant depth is used here -- 15 A. I always do meters per second. Meters per
16 A. Um-hum. (Affirmative) 16 second were about 40 meters per second. So if somebody
17 Q. -- is it the constant depth of the 17 else wants to convert that to miles per hour, that's
18 combination of the mean still-water height plus the 18 about what they were. I know that that's an issue
19 surge plus the waves? 19 because I know they're higher in the Vrijling where you
20 A. No, it's not plus the waves, but it is plus 20 have about maybe 9 to 10 meters per second faster in
21 the other two. 21 that than we did.
22 Q. All right. So if Lake Borgne is in the 9 to 22 Q. At 100 miles an hour --
23 10 constant bottom -- 23 A. Okay. Right. Right.
24 A. Um-hum. (Affirmative) 24 Q. -- on this table --
25 Q. -- 15 foot -- let's just use that as an 25 A. Right.
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Page 238 Page 240
1 Q. -- with the fetch across Lake Borgne -- 1 running a model to somewhat do that. If you can reduce
2 A. Um-hum. (Affirmative) 2 it to some sort of simple generic thing, I can probably
3 Q. -- with our assumed constant water depth 3 check with you.
4 derived by the 10-foot average depth plus the 15-foot 4 Q. Well, take a look at figure I-38.
5 surge -- 5 A. Okay.
6 A. Sure. Right. 6 Q. Depth of 30 feet.
7 Q. -- the Corps of Engineers' own manual 7 A. Okay.
8 projects waves of 9 feet. Is that correct? 8 Q. Over a width of 2000 feet. If you had no
9 A. I mean, yeah, yeah. That's what it predicts, 9 waves whatsoever, the beginning of your wave starts
10 yes. 10 2000 feet across the 30-foot water.
11 Q. Now, wave height is affected by water depth, 11 A. Okay.
12 is it not? 12 Q. According to the Corps' own table at
13 A. Everything else being held the same, it kind 13 100-mile-an-hour winds, what wave height are you going
14 of can be, depending on a lot of other factors, yes. 14 to get?
15 Q. Well, as these waves rolled across the area 15 A. If I'm interpreting this right -- which, you
16 of the marsh, by my calculation, assuming a 15-foot 16 know, I'm not a big nanogram guy here -- 3 feet -- or
17 surge, there's 14 to 15 feet of water depth under the 17 is it 4 feet?
18 waves -- 18 Q. I believe it's 4 feet.
19 A. Okay. 19 A. Four feet, all right.
20 Q. -- above the marsh. 20 Q. That's if it started at 2000 feet.
21 A. Okay. 21 A. 2000 feet. Right, given that this is still
22 Q. So in some areas there's a little bit of 22 valid. Yeah, you'd get 4 foot.
23 marsh, and in some areas there's more marsh. Do you 23 Q. Well, are these tables still valid, or do you
24 agree? 24 know?
25 A. Yes. 25 A. I honestly don't know. But I mean,
Page 239 Page 241
1 Q. So without arguing, for the sake of 1 they're -- I mean, I would have to compare it to modern
2 discussion -- 2 predictions and I could tell you. But, I mean, I don't
3 A. Um-hum. (Affirmative) 3 know -- okay, I'm sure you're, you know -- so you're
4 Q. -- whether there's enough marsh to cause 4 saying that you get 4 feet of wave -- worth of wave
5 these waves of 9 feet to break substantially before 5 energy, if you want to put it that way, as over that
6 getting into the depth of the MRGO -- 6 distance.
7 A. Um-hum. (Affirmative) 7 Q. Let's do this if we could. Give me that over
8 Q. -- would you assume that these waves would 8 there.
9 lose even half of their height before they got to the 9 A. Sure. Sure.
10 MRGO along Reach 2? 10 MR. ROY: And what I'm going to do, Madam
11 A. I hate to assume. I mean, you know, that's 11 Court Reporter, is I'm just going to take --
12 why we have models is to try to get away from doing 12 rather than burden you with this whole thing,
13 what you're doing right now. But I don't know -- it 13 we're just going to take -- I'll just mark and go
14 depends what it crosses over. It depends on a lot of 14 over the series of tables we were looking
15 different things. It depends on -- you know, one of 15 through, starting at page 57, 58, 59.
16 the differences, certainly, is that the -- back in the 16 A. Yeah. Under the assumptions you've listed,
17 '60s everybody thought that the wave heights became a 17 that might not be a bad estimate.
18 higher fraction of the depth. 18 MR. ROY: I'm going to show them as
19 So as an example here, you have different 19 Exhibit 21.
20 depths and things where you're getting 9 feet in 20 (EXHIBIT 21 MARKED)
21 25 feet of water, and I'm not sure you get the same in 21 MR. ROY: Robin, might I suggest that we
22 today's model. 22 go off the record and take a little break.
23 But, anyway, you can continue on. I'm just 23 VIDEOGRAPHER: Off the record at 4:12 p.m.
24 saying, you know, you're asking me to sort of give 24 (OFF THE RECORD)
25 confirmation to something that I -- that would require 25 VIDEOGRAPHER: On the record at 4:33 p.m.
61 (Pages 238 to 241)

Page 242 Page 244
1 BY MR. ROY: 1 mean, at some point in time the differentiation between
2 Q. Dr. Resio, your team concluded in IPET, did 2 a wave and a surge merge. Correct?
3 it not, that there were 15-, maybe 16-foot -- 16-second 3 A. Yeah. There's a pretty good gap. But yes,
4 waves? 4 it does. Infragravity is what's in that gap.
5 A. Yes. In the -- particularly in the southern 5 Q. All right. At page 12 of your report you
6 part. 6 make this statement: "In general, the plaintiffs' wave
7 Q. All right. But including the other part too. 7 report is technically sound and utilizes modeling
8 I mean -- 8 technologies which are generally accepted for
9 A. Yeah, that's right. There were some. 9 applications of the type described."
10 Q. All right. For the section we're talking 10 A. Yes.
11 about today on MRGO, at Reach 2 MRGO, you found some 11 Q. You believed that when you wrote that on page
12 15- and 16-foot -- 15- and 16-second waves in the IPET 12 12 of your report. Right?
13 analysis. Correct? 13 A. Yes.
14 A. That is correct, yes. 14 Q. Do you still believe that to be true?
15 Q. All right. That is not correct under -- as I 15 A. I still believe it to be true.
16 read your report now and from our discussions today, in 16 Q. I'm not trying to be picky with this next
17 fact, I believe on the relevant section of Reach 2 of 17 question, but I am confused.
18 MRGO facing Lake Borgne, the highest would have been in 18 A. Okay.
19 the neighborhood of six seconds. Is that right? 19 Q. Your sole source of income for at least the
20 A. Somewhere six to seven, yes. 20 last five years -- I mean, I don't care about
21 Q. Okay. What happened? That's a huge 21 investments. That's not what I'm talking about -- but
22 difference. I mean, it's a function of more than 22 from work, your time has been as a full-time employee
23 200 -- even 250 percent difference. What happened? 23 of the Corps. Right?
24 A. Okay. I think if you look very closely to 24 A. That is correct, yes.
25 the spectra, wave spectra, you still have energy at 25 Q. The work you did -- the work you did to
Page 243 Page 245
1 those long periods. It didn't go away. It's the same 1 prepare for and generate the report of yours, which is
2 amount of energy coming in there. It's just the 2 attached to this deposition, was done as a full-time
3 spectral peaks denote where the highest energy is at a 3 employee of the Corps.
4 particular frequency as far as the spectral peak 4 A. Yes.
5 frequency would be the frequency of the highest energy. 5 Q. All right. I'm confused. At page 4 you say,
6 And with the wind generation that we get in the 6 "I have received no compensation for my work on this
7 full-plane version oblique to the area just as you 7 report."
8 described, we're getting -- that now becomes the 8 A. I mean --
9 dominant frequency. So you may still have this other 9 Q. You're not suggesting you did this outside
10 energy there, but now we have a source of energy that 10 the scope of your employment, are you?
11 is higher coming from the opposite direction -- not the 11 A. No, no, no. I guess I meant --
12 opposite. From -- well, it's coming from a different 12 Q. You were compensated. You have salary.
13 angle and coming more or less straight out of the east. 13 A. Yeah. I mean, I compensated -- yes. If you
14 Q. But functionally, too, it's not being long 14 consider that I didn't get anything extra for it.
15 waves in effect over the same period -- the same 15 Q. That's fair enough.
16 distance, if you will, there are more waves than as 16 A. My salary is covered every year.
17 opposed to a long wave. Is that correct? 17 Q. I got you. Your intention there was simply
18 A. It is more -- 18 to say you didn't get paid extra.
19 Q. A 16-second wave -- 19 A. Right.
20 A. Right. 20 Q. All right. You address in your report at
21 Q. -- is going to be a much longer -- 21 page 28 the large variability of the levee crest
22 A. Oh, yes. 22 elevations along Reach 2, seen in this figure you refer
23 Q. -- a much longer wave -- 23 to --
24 A. Yes. 24 A. Right.
25 Q. The higher the number of seconds gets -- I 25 Q. It was decided -- we've talked about that, it
62 (Pages 242 to 245)

Page 246 Page 248
1 was not very representative to talk about a single 1 USACE, the field experimental conditions for either
2 value for the levee crest elevation each of these 21 2 gently sloping beach conditions or low wave height
3 points. Consequently, it was decided to characterize 3 conditions?
4 each of the 21 by three different levee crest 4 A. They were definitely -- they were no levees.
5 elevations. And you go into 25 percent lowest, 5 So in relative to a levee, the slopes were definitely
6 50 percent, and then 25 percent of the highest. 6 considerably less.
7 A. That's correct. 7 Q. Analogous to a beach or --
8 Q. Nowhere in this report do you give any 8 A. A beach, exactly.
9 basis -- scientifically or statistically or 9 Q. -- the shore of a lake.
10 literature -- supporting same for making that 10 A. Yes.
11 particular division of 25, 50, and 25 percent. 11 MR. ROY: Madam Court Reporter, look at
12 A. That is correct. 12 his résumé. I'm sure we attached -- I'm sure
13 Q. In the context of the four corners of the 13 Exhibit B is attached. I want to make sure it
14 report, if it had been 10 percent, 90 percent, and 14 is.
15 5 percent, there's nowhere in the report to be able to 15 COURT REPORTER: I think his résumé is one
16 judge why those figures are better or worse than the 16 page.
17 figures you used. Right? 17 MR. ROY: The actual next -- Exhibit 3.
18 A. Right. I mean, you do have to multiply it 18 THE WITNESS: Oh, this is the report.
19 times its appropriate percentage, of course. But, yes, 19 MR. ROY: It is. It is.
20 you're right. If I had done -- 20 BY MR. ROY:
21 Q. As long as they total 100? 21 Q. Okay. Dr. Resio, you've attached Appendix B
22 A. Right. You got it. Right. 22 to your report. It's part of Exhibit 3 to your
23 Q. I think at page 31 of your report you make a 23 deposition. Take a look at it.
24 statement -- I'm wrong, it's not page 31. Maybe we 24 A. Okay.
25 don't need the page. Let's try this. 25 Q. This is the list of articles that you have
Page 247 Page 249
1 A. Okay. 1 listed as a partial list of COULWAVE publications
2 Q. In your report you talk about COULWAVE having 2 supporting the application of COULWAVE as it's applied
3 been validated. Do you recall that discussion 3 in your report. Is that right?
4 somewhere? 4 A. Yes.
5 A. Yes, I do. 5 Q. Every single one of these publications is
6 Q. All right. Inside the report itself, 6 coauthored by P. Lynett. Is that correct?
7 anywhere within the four corners, is there the analysis 7 A. It could be. I didn't check.
8 in writing that you performed to validate your 8 Q. Why don't you check.
9 extrapolation of lab results to prototype hurricane 9 A. (Reviews document) Yes, that does look to be
10 conditions? 10 true.
11 A. Specifically to hurricane conditions? I'd 11 Q. So the articles in support of this
12 have to look. I mean, I did -- there's a lot of 12 application of COULWAVE is by one person. His own
13 references, and I'm not sure if some of those 13 articles, in effect.
14 references actually talk about waves comparable to the 14 A. The developer of the code, yes.
15 ones that we're dealing with here or not, and we -- 15 Q. Now, you have characterized waves that
16 there are some prototype data sets that are referenced, 16 developed during Hurricane Katrina and documented those
17 but I don't know whether they go into this range. 17 characterizations in your expert report. Where in your
18 Q. All right. You do make some references to 18 report do you specifically address your validation --
19 some technical papers -- 19 your validation -- of those characterizations of waves?
20 A. Um-hum. (Affirmative) 20 A. You mean the validation of the Boussinesq?
21 Q. -- some peer-reviewed, published -- in which 21 Q. Yes.
22 the Corps of Engineers' field experimental data are 22 A. Okay. To a scientist, the -- it's really
23 used to evaluate COULWAVE. Do you remember that? 23 important to have this validation in peer-reviewed
24 A. I remember that, yes. 24 journals. So when I look at what goes out in
25 Q. Weren't almost all, if not all, of those 25 peer-reviewed journals, that tends to be taken as a
63 (Pages 246 to 249)

Page 250 Page 252
1 good representation of the state of the art. If 1 proprietary codes that you have trouble. The Danish
2 somebody puts it there -- because anybody can write in 2 have one, MIKE -- it's in their MIKE 21 series. But I
3 and say, "I'm sorry, but this is totally wrong," and 3 can't look at it, so I don't know what's under the
4 there is a lot that goes on. If you try to publish 4 hood, so I don't know what's in it. But SWAN and WABED
5 something that -- let's just say you could sneak it by 5 and STWAVE are the three that typically get used by a
6 an unsuspecting reviewer, there's going to be too many 6 lot of different people.
7 good people reviewing it. 7 Q. So SWAN, like STWAVE, is internationally
8 So I have always taken that if something is 8 recognized in the oceanographic and coastal science
9 published in a peer-reviewed journal, that that is what 9 wave analysis community --
10 I will take as validation to anything, a model -- 10 A. Yes, it is.
11 Q. Where in your report do you find -- do you 11 Q. -- as being legitimate tools to use in
12 show us the validation of your characterizations of 12 performing analyses such as you have attempted to
13 waves? 13 perform in your report. Correct?
14 A. Well, I don't. I mean, I simply refer to 14 A. Yes, it is.
15 some publications that if -- I mean, they're -- if you 15 Q. All right. Likewise, you have chosen
16 read between -- now, if you do not take prototype, you 16 COULWAVE, which, apparently, as you tell us, is
17 can see on the figures 8 or 9 that we were discussing 17 developed by Dr. Lynett in Texas. It is apparently
18 once earlier that the -- I believe it was 8 and 9, if 18 preferred to be used here. But there are other --
19 memory -- yes, that this is validation of COULWAVE 19 other modeling software available that are alternate to
20 against laboratory data. But it is laboratory scale 20 that used elsewhere in the world. Is that correct?
21 data. But one of the nice things is that if a model 21 A. Yes. As long as it's a Boussinesq class, I
22 runs at laboratory data -- laboratory scale, excuse 22 would have no argument against it.
23 me -- and prototype scale, then you know you're getting 23 Q. Is Finel one of those?
24 the physics somewhat right. So you can see figures 8 24 A. Finel would be one, yes.
25 and 9 actually have in it comparisons of quite varying 25 Q. Finel is a generally accepted --
Page 251 Page 253
1 boundary conditions running over a slope, and they 1 A. Right.
2 emulate the breaking and propagation quite nicely. 2 Q. -- Boussinesq-type --
3 Q. Now, here at the Corps and you -- you-all 3 A. Right.
4 like to use STWAVE. You developed it initially, and 4 Q. -- program that is comparable to, but
5 Ms. Smith has picked up the mantle from you and 5 different from --
6 continued with it. Correct? 6 A. Yes.
7 A. Such as it is, yes. 7 Q. -- your COULWAVE?
8 Q. That's effectively the Corps' and your 8 A. This is true. Absolutely.
9 proprietary program available to the public -- 9 Q. But the general purpose and overriding theme
10 A. It's available to the public. It's not 10 of why you would apply it is the same.
11 proprietary if it's available to the public. 11 A. That is correct.
12 Q. Internally developed, let's say. 12 Q. And shades of emphasis or color as to whether
13 A. Yes, that it is. 13 you get more out of one than the other or less out of
14 Q. All right. Internally developed, the 14 one than the other or something extra from the other --
15 continuum of which is continually modified by internal 15 the overarching intent and scientific accepted
16 individuals. Right? 16 throughout the world is the same?
17 A. Yeah. Absolutely. 17 A. Very similar, yes.
18 Q. All right. Now, there are other wave 18 Q. All right. And the last question I have for
19 programs, analysis models, out there in the world, are 19 you, just to be sure, that on page 56 you refer to a
20 there not? 20 "complete set of outputs for Boussinesq simulations
21 A. Absolutely. 21 (the times series of half-hourly overtopping rates,
22 Q. And what are some of them? 22 velocity information, and setup) was provided to the
23 A. Well, there's one called WABED. There's one 23 interior drainage group for their utilization." And
24 called SWAN. Those are probably the only two I would 24 you mention Fitzgerald '08. Correct?
25 say are in the well-used class that I'm -- there's some 25 A. That's correct.
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Page 254
1 Q. But you did not furnish the complete set of 1 CERTIFICATE OF DEPONENT
2 outputs with your report or describe them individually 2 I, DONALD RESIO, deponent in the
3 in the report. Is that correct? 3 deposition taken in the herein styled and numbered
4 A. That is correct. I possibly should have. 4 cause, certify that I have examined the foregoing
5 Q. In your report you give opinions about the 5 pages, being the total number of pages relating to
6 my testimony, as to the correctness thereof, and
6 primary mode of failure in breaching of levees were
7 that after reading said pages, and subject to any
7 certain things. If I understand your testimony today, 8 corrections I may have attached hereto as a
8 it is not your intent to opine as to why a levee 9 Deponent's Corrections Sheet, I find them to
9 failed. That is for someone else to do. Correct? 10 contain a full, true, and correct transcript of
10 A. That is correct. 11 the testimony as given by me.
11 Q. And to the extent any such statements were 12 This the ______ day of ___________,
12 made, they're made outside of your expertise and intent 13 2009.
13 and scope of your report, which was to do the two 14 ____________________________
14 things we talked about earlier, which is to measure DONALD RESIO
15 surge height and velocity going over the top of the 15
16 levee and, secondly, to measure the back side 16 STATE OF MISSISSIPPI
17 velocities. 17 COUNTY OF __________
18 SUBSCRIBED AND SWORN TO BEFORE ME, the
18 A. That's correct.
19 undersigned authority, on this the _____ day of
19 Q. All right. 20 _______________, 2009.
20 MR. ROY: I have no other questions. 21 ____________________________
21 MR. SMITH: Thank you. No questions. NOTARY PUBLIC
22 VIDEOGRAPHER: End of deposition. The 22
23 time is 4:54 p.m. 23 My Commission Expires:
24 (DEPOSITION CONCLUDED AT 4:54 P.M.) 24
25 * * * * * * 25
1 CERTIFICATE OF COURT REPORTER 1 DEPONENT'S CORRECTION SHEET

2 I, SHARRON F. ALLEN, Certified Shorthand 2
3 Reporter and Notary Public in and for the State of 3 PAGE LINE CORRECTION
4 Mississippi at large, hereby certify that the 4 ___________________________________________________
5 foregoing pages contain a full, true, and correct 5 ___________________________________________________
6 transcript of the proceedings as taken by me at 6 ___________________________________________________
7 the time and place heretofore stated in the 7 ___________________________________________________
8 aforementioned matter and later reduced to 8 ___________________________________________________
9 ___________________________________________________
9 typewritten form by me to the best of my skill and
10 ___________________________________________________
10 ability.
11 ___________________________________________________
11 I further certify that I placed the
12 ___________________________________________________
12 witness under oath to truthfully answer all 13 ___________________________________________________
13 questions in this matter under the authority 14
14 vested in me by the State of Mississippi. 15 ______________________________
15 I further certify that I am not in the DONALD RESIO
16 employ of or related to any counsel or party in 16
17 this matter and have no interest, monetary or 17 STATE OF MISSISSIPPI
18 otherwise, as to the final outcome of this 18 COUNTY OF __________
19 proceeding. 19 SWORN AND SUBSCRIBED TO BEFORE ME, this
20 WITNESS MY SIGNATURE AND SEAL, this the 20 the ______ day of ________________, 2009.
21 19th day of February, 2009. 21
22 _______________________ ______________________________
SHARRON F. ALLEN, CSR, RPR 22 NOTARY PUBLIC
23 CSR NO. 1144 23
24 My Commission Expires: 24 My Commission Expires:
25 November 5, 2011 25
65 (Pages 254 to 257)

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ab 235:3 76:19 91:13,15 102:4,9 104:11,21 al 184:23 209:22
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absorbing 217:24 ADCIRC-type 142:21 149:6 allow 23:10 5:19 39:4 52:7,11
absorbs 217:17 147:24 169:3 172:21 allowed 111:13 62:1 64:14 65:7
absurd 87:4 add 8:3 45:11 177:17 182:2,9 155:10 163:8 67:7 98:16 136:23
academia 32:6 145:24 162:11 183:10 189:14 223:11 224:6 136:25 138:2
academy 149:17 added 25:9 115:9 195:6 196:21 226:19 140:10,21 141:9
accepted 244:8 adding 196:2 197:23 203:16,23 allowing 81:15 171:1 185:22
252:25 253:15 additional 25:9 207:1 228:6 allows 163:5 212:14 231:21
accessed 80:9 91:2 128:12 130:7 235:16,24 237:3 alter 75:10,11 255:12
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accuracy 74:16 132:11 133:13 247:20 altering 133:20 212:15
170:24 172:2,3 186:1 affirmatively alternate 121:25 answers 188:19
accurate 167:14 address 108:24 103:22 104:6 252:19 anticipated 38:4
172:4 207:10 132:15,16 151:3 afford 5:21 alternatives 171:23 anticipating 39:12
accurately 179:20 245:20 249:18 aforementioned 171:24 anybody 23:7
accused 154:18 addressing 77:11 255:8 alters 75:11 41:21 44:14 46:5
achieve 34:16 109:5 145:19 agency 18:11 20:24 ambiguity 209:19 47:11 61:20 80:25
acknowledges 151:4 ago 14:21 22:2 amended 6:8,13 85:10 151:19
128:8 adequately 148:11 46:11 72:8 143:10 AMERICA 1:19 235:6 237:13
acronym 25:11 adjacent 128:2 143:21,23 227:16 American 50:16 250:2
acting 35:19,21 136:6 agree 6:10,18 78:20 51:8 143:12 anybody's 237:12
37:21 adjusted 64:9 94:22 95:21 amount 67:22 anyway 140:20
action 1:4 4:5 156:9 158:3 100:18 101:20,23 111:12 126:15 174:19 239:23
162:6 adjustment 72:18 102:10 105:4 127:16 155:6 apologize 10:17
actual 59:9 116:12 156:11,19,20 107:1 116:23,24 243:2 20:12 24:23 42:12
155:25 179:24 administration 116:25 117:12 ample 84:11 79:19
184:25,25 206:10 16:17 119:23 134:4,8 amplitudes 164:6 apparent 48:1
206:25 213:9 admission 204:1 182:18 185:23 analogous 135:14 184:5
215:11 217:22 advice 34:15 195:5 209:6,11 168:12,19 248:7 apparently 18:19
248:17 affect 72:20,22,24 238:24 analogy 168:7 27:20 31:13 32:3
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ADCIRC 31:4 40:8 Affirmative 11:21 agreeing 6:20 analysis 53:3 86:7 163:16 186:23
40:17,19,20 45:24 47:5 48:17 53:9 ahead 29:24 40:12 100:18 101:5 252:16,17
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68:4,14,24 69:16 75:7 79:12 80:23 136:15 145:21 251:19 252:9 APPEARANCES
69:25 73:6,13,21 87:13,16 88:20 171:6 211:15,21 Andry 1:13,13 4:21 1:9
89:12,25 95:17 211:24 222:16 4:21 appears 83:10

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appendices 53:7 arbitration 30:19 18:6,12,15,23 176:15,21 177:18 163:2,7 175:19
appendix 2:6,7,8 arbitrator 30:15 20:22 178:19 187:17 179:7 184:15,17
53:12 54:10 55:1 area 13:20 15:14 artwork 123:15 217:23 223:9 185:2 186:24
55:12,16 56:8 16:19 37:14 39:1 ASCE 143:2,10,11 225:4 238:3 187:1 230:25
57:5,9 228:20 61:2 67:24 87:17 143:25 assumes 194:10 231:3,4 233:12
248:21 96:8 97:25 99:2,6 Ashley 1:10 4:19 assuming 9:6 46:15 234:1 236:1 238:4
application 2:13 99:7,11 115:2 94:7 88:23 89:3 113:15 averaged 182:25
70:14 107:9,10 123:1 125:8,20 aside 77:23 121:4,5 182:1 230:23 231:11,11
132:15 205:19 128:1,6 131:18 asked 6:21 14:21 190:22 220:22 averages 182:18,22
230:13 249:2,12 135:11 138:24 18:14 19:1 47:13 231:8 238:16 199:14
applications 107:2 159:7,14 161:1 56:6 90:20 107:7 assumption 64:7 Awarded 14:13
122:11 244:9 173:20 185:14,17 114:16 147:17 65:8 116:3 158:16 aware 37:9 38:18
applied 207:11 187:24 188:2 154:9,10 160:10 174:20 214:1 61:19 80:10 194:3
249:2 196:8,20 198:24 175:16 176:13,18 220:6 229:2 230:5 194:5 229:10
apply 176:10 199:7 217:24 176:22,23 208:2 230:6 236:24 237:13
253:10 233:20 238:15 227:17 231:15 assumptions 64:10 axis 96:12,15
applying 175:6 243:7 asking 5:12 16:1 187:17 201:14 102:22 107:22
appreciate 10:23 areas 38:19 110:25 36:25 41:16 45:9 222:11 226:9 109:11,19 111:4
76:8 93:4 111:3 139:12 61:11 66:7 72:14 230:3 241:16 112:24,25 114:4
appreciated 192:14 169:12,18 186:5 77:15 82:14 83:3 asymmetry 117:20 116:20 117:17
192:17 198:11 199:11 85:23 86:22 93:8 118:22 120:14 118:19 120:12
approach 75:15 200:22 238:22,23 157:12,13 160:24 Atlantic 20:18 122:22,23,24
approached 165:10 arguing 239:1 177:7 180:22,23 attached 6:21 7:8 124:15 215:12,13
approaching 47:25 argument 252:22 181:5 195:4,7 7:16 245:2 248:12 221:2
appropriate 64:25 army 1:22 4:8 199:3 201:4 248:13,21 256:8 A&M 43:13 44:8,9
68:3 122:10 24:20 25:3 33:14 206:24 222:17 attempted 23:21 45:18 94:14
126:15 127:11 33:16,17 34:22 227:8 234:11,16 252:12 A-to-B 124:9
132:10 236:16 35:2,4,8 37:10 239:24 attorneys 4:15 5:9 a.m 1:23 4:10
246:19 80:1 190:16,18 aspect 52:2 64:7 attributable 120:25 48:22,24 91:18
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115:11 arrow 104:19 assignment 46:10 audio 4:16
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approve 191:25 225:17 59:13 authored 76:14 B 1:13 96:4,7 98:1
approximate 220:9 art 65:19 151:7,9 assignments 59:7 209:5,7 99:4 102:3 103:4
236:3 250:1 assistant 32:19 authority 255:13 111:18,25 113:13
approximately article 81:25 82:2 36:5,7 256:19 123:25 125:16
10:7 19:9 21:7,9 83:8 94:12 118:10 Associate 32:19,20 authorized 33:14 217:9,22 248:13
21:10 102:15 119:22 120:16 32:22,23 authors 143:4 248:21
110:11 125:4 121:6,10,12,13,13 Associates 4:12 191:5 bachelor 10:23
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225:20 232:14 articles 10:8,12 186:8 199:22 194:22 208:6 31:14 32:4 43:22
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bad 73:11 241:17 248:2,7,8 145:18 158:12 bold 194:17 125:2,4 146:22
bald 199:9,9,14 beam 137:13 180:15,16 207:19 bona 190:21 168:14,20 201:22
ball 18:1 beauty 155:1 216:10 255:9 bookend 142:20 202:3 217:20
ballpark 28:18 Bea's 217:19 betray 28:2 bookmark 171:13 223:10 224:4
58:16 93:9 165:16 227:10 better 144:12 172:2 171:16 226:18,20 231:8,9
198:4 220:5 began 26:3 213:24 215:15 Borgne 77:12 78:7 251:1
232:17 beginning 35:20 220:14 246:16 96:8 97:25 99:5 Boussinesq 2:13,21
Baltimore 29:2 79:14 160:10 betting 189:4 99:14 101:6 103:4 45:16,21 54:5
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bar 166:15,16,18 224:6 240:9 75:17 85:12,17 123:1 124:17,17 146:25 147:2
166:22,23,25 begins 39:1 85:14 96:6,24 110:17 124:19 164:6 150:1,3,4,5,6,7
167:5,8,11,15,17 behalf 191:15,18 125:10 168:12 167:24 168:9 159:17 162:21,25
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183:3 184:18 belief 231:16 234:8 240:16 233:12,21 234:1,7 170:19 203:7,11
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162:3 183:23 174:18 180:5 52:25 70:17 96:10 bother 59:17 bracket 118:14,14
230:23 235:9 188:8 209:22 139:17 140:5 bottom 15:18 89:2 brackets 119:19
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breaks 85:17 87:11 87:17 88:6 115:19 156:25 167:18 141:6 177:15 Civilian 35:24
briefcase 220:13 127:19 145:1 170:23 171:10 224:10 claimants 29:16
briefing 82:15 168:5 169:22 230:16 changed 12:8 24:21 clarification 79:5
bring 97:24 107:20 220:12 230:6 cases 5:11 28:9 29:19 clarifying 147:8
broad 23:19 32:12 233:21 51:21 90:14 165:4 changes 130:17 class 146:6 251:25
51:25 102:19 called 13:10 16:9 188:17 230:7 139:17 252:21
151:12 230:13 17:22 25:16 35:11 castigate 150:25 changing 17:4 classification 21:23
broadened 59:14 36:10 169:4 casting 82:7 23:22 131:21,22 cleanup 147:10
broke 88:14,15 217:16 220:17 Cat 101:19,22,24 131:22 clear 5:14 19:1
brought 40:12 251:23,24 catching 114:2 channel 91:16 77:9 120:20
95:14 calling 64:10 66:1 categorically 136:13 137:1 122:13 151:23
Bruce 37:22 42:3 233:1 198:16 139:20 168:15 233:20
42:10 143:5,13 calls 170:5 cause 130:7 131:17 channels 135:6 clearer 216:21
144:14 159:5 camera 212:24 239:4 256:4 139:18 clearinghouse
Budweiser 166:24 Canadians 122:1 caused 210:15 characteristic 17:24
build 27:14 76:20 canal 1:2 4:3 59:22 causing 130:9 163:3 clearly 178:21
107:11 60:4,6 caveat 179:24 characteristics 214:5
building 60:23 canals 53:25 54:6 196:13 44:24 148:13 clenches 138:13
160:25 59:23 60:1,10 cells 117:2,14 205:11 clients 28:11
buildup 97:20 192:14 118:17 120:6,10 characterizations climate 23:19,22
built 27:7 61:1 Canal/MRGO center 25:14 80:2 249:17,19 250:12 32:13
73:12 160:24 78:11 91:16 217:23 characterize 210:1 close 53:24 59:25
161:3 canopy 195:17 centering 217:10 246:3 92:11 125:11
bunch 155:2,8,9,9 capability 229:8 certain 5:11 107:14 characterized 188:13 205:20
burden 241:12 capable 130:9 110:23 254:7 249:15 206:14
bushes 89:22,23 154:6 certainly 5:20,20 charge 34:11 closely 242:24

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closer 68:12 109:19 94:10 115:13 company 26:19 66:8 245:14

195:11 124:17 127:23 27:22 28:19,24 conclusions 38:18 considerably
closest 223:18 150:20 161:22 29:3,7,8,13,18 72:21,23 73:2,24 169:12,13,15
coarse 145:8,8 178:5 184:16 comparable 247:14 75:12 126:8 183:2 248:6
146:13,15 186:25 208:17 253:4 concrete 60:23 considerations
coast 20:17,18 210:14 217:15 comparably 168:11 89:22 144:16 146:20
81:14 85:14 113:2 comes 40:19 65:23 compare 241:1 condition 132:4 considered 37:2
113:18,19 189:16 87:18 88:18 91:1 compared 107:17 146:22 168:14 62:21 67:16
coastal 15:16 21:23 91:2 168:10 192:8 comparison 126:25 217:21 232:8 147:22 227:9
27:22 29:3 31:18 coming 24:11 70:2 comparisons conditions 30:14 considering 9:25
31:22,25 34:9,11 74:12 75:21 85:12 250:25 60:3 63:9,15 106:11
52:4,5,8,9,11 91:14 92:12 97:21 compensated 115:11 201:22 consistent 101:23
107:2,9,10 122:11 99:18 106:2 245:12,13 202:4 247:10,11 115:16 125:18
252:8 108:14 110:6,23 compensation 248:1,2,3 251:1 Consolidated 1:3
coastline 108:20 111:10,11,11,12 245:6 conference 51:10 4:4
109:5 110:5,9 113:18,24,25 complete 253:20 82:12 121:24,25 constant 63:10
128:2 114:21 115:5,7 254:1 confidences 28:2 64:12 85:11
coauthored 249:6 124:18 125:3,8,9 completely 86:21 confident 178:24 138:10 155:7
code 69:21 118:1 126:12 129:2 complicated 41:11 Confidential 91:21 235:15,17,23
163:12 166:6 133:3 135:19 component 145:23 92:7,8 236:23 238:3
203:7,11 249:14 137:16,18 139:22 175:15 confidentiality constraints 204:16
codes 252:1 157:25 158:1 components 85:8 94:23 constructed 61:1
coding 186:23,23 160:19 164:6 114:1 confirmation 61:16 194:13
coefficient 89:21 165:16 166:13 computation 196:3 239:25 construction
197:8,15 168:16,18 173:20 computational confirms 116:1 194:22 200:9,12
coffee 49:3 185:19,19,20,21 119:15 confused 87:22 construed 210:10
coincidence 83:13 195:18 209:17 computationally 244:17 245:5 consult 28:1
coincidental 83:4 222:25 223:4,22 170:22 confusing 34:23 consulting 27:22
college 21:6 224:19 227:6 computations confusion 79:19 31:25
colleges 17:24 229:3 236:14 204:5,12 connected 96:21 contact 44:16
colon 20:10 243:2,11,12,13 compute 42:2 connecting 108:3 126:13
color 185:21,22 commence 15:4 205:6 connection 8:15 contain 255:5
186:23 253:12 comment 194:20 computed 40:8 11:18 46:13 62:5 256:10
color-coded 185:11 196:24,24 226:17 106:22 160:13 contents 2:1 191:9
186:9 commerce 30:20 computer 45:13,14 Conner 1:20 4:12 context 16:16,17,18
column 83:7 163:4 Commission 45:23 67:21 4:13 60:5 120:18,20
173:15 193:6 255:24 256:23 117:23 154:16 consequences 128:17,19,22,23
195:19 257:24 172:1 202:19 75:12 188:22,23 132:14 145:14
combination committed 186:15 204:21 189:1 146:14 160:21
235:18 committee 35:10 concentration Consequently 165:20 166:5
combined 209:15 35:13 149:22 15:13 246:3 170:17 192:16,23
come 10:5 30:18 common 196:19,19 concern 128:2 conservation 163:5 246:13
33:5 40:22,22 199:9,14 concerned 108:13 consider 24:2 28:6 continually 251:15
48:20 58:14 66:5 commonality 83:25 108:21 115:1 68:20 75:15,16 continue 171:14
68:10 76:20 77:21 communicating concluded 3:3 106:10,13,16 239:23
82:17 85:12,13 122:4 242:2 254:24 115:10 117:3 continued 251:6
92:23,23 94:6,8 community 252:9 conclusion 58:25 167:14 207:14 continues 88:17

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183:21 222:21 240:12 244:23 165:13 168:2 163:12 164:11,14 creators 163:20
continuing 44:23 245:3 247:22 169:9,10 172:24 165:20 166:5,14 crest 70:24 77:5
continuum 251:15 251:3,8 173:2 174:3,7 167:15 168:8,20 78:16 86:23 152:2
contract 21:22 correct 7:2,5,6 178:3 179:11 206:3,9 247:2,23 152:14 156:1
contractors 28:3 10:14,22,25 12:16 181:5,24 182:1,5 249:1,2,12 250:19 175:25 182:7
contrary 80:11 14:11,12 15:7 183:20 187:13,14 252:16 253:7 183:19 205:15
contribute 99:9 19:14,24 20:1 187:21 189:18 Council 149:8,13 211:1 219:16
146:5 22:19 25:12,20,21 192:1 195:25 150:20 151:15 220:23 245:21
contributed 83:17 26:6 27:18,23 201:23 202:5 counsel 255:16 246:2,4
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contributing 83:16 32:2,5 33:4,6,7 206:12 209:10 country 30:19 crosses 239:14
210:2 35:25 39:8,25 215:22 216:5,13 45:22 crossing 168:19
controversial 40:6 41:19,20 221:10 223:12 COUNTY 256:17 231:16
189:10 42:23 43:2 44:5 228:9 231:18 257:18 cross-check 9:8
convene 35:10 44:12 49:19,20,23 234:3,5 236:13 couple 211:17 10:9
convenience 118:8 49:25 50:1,3,5,7,9 238:8 242:13,14 course 11:4 16:11 cross-sections
convenient 98:18 50:11 51:14 52:15 242:15 243:17 63:4 101:12 180:19
119:2 52:16 53:6 55:11 244:2,24 246:7,12 179:23 199:16 crude 155:24
converge 37:18 59:4 61:6 62:1,3,7 249:6 251:6 205:10 246:19 CSR 1:24,25
conversion 196:5 62:8,11,13 63:24 252:13,20 253:11 courses 11:22,23 255:22,23
227:21 65:11 66:20 67:11 253:24,25 254:3,4 11:24 12:2,3,15 cup 49:3
convert 39:6 46:12 67:17,18 68:6 254:9,10,18 255:5 12:22 13:12,19,22 curious 191:4
47:10 237:17 69:1,1,9 70:25 256:10 14:2 15:20 16:6 curriculum 7:1
converting 49:11 71:5 72:21 73:7 correcting 90:10 coursework 11:19 15:20
227:22 74:13 76:9,17,22 CORRECTION court 1:1 3:4 4:7,11 curves 236:22
convey 59:19 77:3,13,16 78:4,9 257:1,3 48:18 51:21 customs 5:18
convinced 172:1 79:18 81:8,19 corrections 256:8,9 177:14 202:1 cut 130:20
copies 8:15 10:12 84:6 86:8,11 correctly 121:5 210:14 212:9 cuts 58:17
copy 48:10 103:15 89:14,19,20 90:2 125:17 174:2,18 241:11 248:11,15 CV 2:4
103:15 114:15 90:11 94:15 95:22 214:18 255:1 cypress 194:12,20
145:3,6 172:15,15 95:23 96:13,14,17 correctness 256:6 cover 106:21 197:21 198:5,6,10
216:15 96:23,25 97:1,6,8 corresponds 230:14 198:16,23,24
Cornell 163:20 97:14,16,21 98:1 114:15 coverage 117:16 199:4,4,6,8,9,10
corner 102:5 113:4 98:2,5 99:20 corrupting 200:11 118:18 120:6,10 199:14,18,23
190:8 100:16 101:6,9,14 COULWAVE covered 32:15 200:22 201:5
corners 113:13 104:14,23,24 45:16,23 46:1,4 67:22 116:3
246:13 247:7 105:1,12 107:13 70:3,6,8,22 71:9 125:20 148:10 D
Corps 1:22 4:8 108:17,18 109:12 71:12,16 72:24 245:16 D 1:16 216:2,3,7,11
24:20 25:3,22 112:9,10 114:4,9 75:4 76:21,23 covers 26:24 32:13 damage 30:10
26:4 28:14 32:4 114:23 116:13,14 78:25 79:17 91:11 106:4,20,22 225:2 116:12 210:16
33:6,15,18,23 116:16,17 122:14 91:12,17 147:9 co-author 119:7,8 Danish 252:1
34:4,24 35:22 122:15 128:10,11 148:1 149:1,3,4,5 co-authored 76:15 data 70:19 72:17
36:22 37:2,10 130:10 139:13 149:14 150:21 co-leader 59:8 107:13 157:3
80:1 81:22 153:11 141:21 144:14,18 151:2,16,25 co-leads 52:21 158:1 159:16,21
190:15 191:7,23 145:13 147:14 152:12,18 153:7 55:19 159:21,22,22
193:11,20 200:10 148:23 152:15 153:24 154:6,23 co-led 52:22 160:8 161:7 162:4
204:9 235:3 238:7 153:10 162:2 155:3,17,18 created 20:16 46:4 184:25 191:2

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194:22 206:25 109:12 120:11 derived 206:10 difference 85:10 96:17 105:12,19
235:9 247:16,22 delegated 191:14 238:4 111:1 140:16 106:3,22,22
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date 4:9 163:1 Delft 30:16 31:15 207:21 254:2 162:23 175:5 117:17 118:18
dated 208:20 31:17 115:15 described 31:22 186:2 189:2,3,3 120:11 122:14
dates 18:5 demise 210:2 46:11 47:10 49:14 192:6 242:22,23 133:20 231:13
day 8:8 14:22 47:20 denote 243:3 49:18 66:13 67:2 differences 239:16 243:11
88:1 255:21 denotes 213:7 88:4 209:8 243:8 different 29:12 directional 227:6
256:12,19 257:20 denoting 222:5 244:9 33:25 36:12 43:11 directions 30:5
days 97:21 dense 89:23 describing 208:19 57:24 62:21 63:5 81:16 217:14
DC 1:18 department 1:17 description 79:9 71:24 85:5 88:5 227:9
de 112:11 123:1 14:24,25 16:7,8 design 3:2 27:6,8 110:25 115:3,20 directly 44:10
deadline 46:8 16:11 17:5,11,12 27:10 193:13 117:9 119:9 99:17 120:23
deal 75:18 136:16 33:12 46:15 234:20 125:19 127:22 director 34:20
dealing 40:16 departments 16:8 designated 11:12 130:19 135:17,20 35:17,19,20,21
65:10 113:7 dependent 138:16 16:19,25 37:14 137:3,3,15 138:2 36:5,5,7,9 191:17
184:22 247:15 depending 232:19 designed 174:25 148:2,3,8,15 directors 191:14
Dean 52:21 238:14 destroyed 200:10 152:20 155:2,8,9 disadvantage
death 29:16 depends 32:12 destruction 209:13 155:10 162:15 116:25 117:3
decades 31:19 127:21 239:14,14 detail 36:3 59:18 164:5 165:3 119:14
December 142:3 239:15 59:23 103:10 170:16 171:10,22 disadvantages
decide 227:14 depiction 141:16 151:11 162:17 175:2 180:21 116:15 117:12
decided 98:13 160:4 detailed 12:11 185:22 186:3 118:13 119:12,13
202:24 203:3,15 deponent 256:1,2 59:25 188:12,24,25 120:5,9
245:25 246:3 Deponent's 256:9 details 30:21,24 191:19 198:9 discrepancy 18:9
decision 98:7,11 257:1 deteriorate 88:18 200:25 202:6,10 discrete 38:19 39:1
declared 235:2 deposition 1:7 2:3 determine 110:10 204:25 205:19 discretized 139:21
decrease 189:18 3:3 4:2 5:25 6:8 116:12 164:10 210:10 227:5,8 discuss 196:22
190:5 6:14 7:24 8:6 determined 40:24 231:13,14 232:6,6 discussed 38:14,16
decreases 184:11 58:1 141:25 98:25 200:21 232:16 239:15,19 148:8,14 203:19
deep 165:17 168:4 160:11 181:12 develop 73:14 243:12 246:4 227:3
173:2 223:10 245:2 248:23 203:3 252:6 253:5 discussing 250:17
224:5 225:4 254:22,24 256:3 developed 31:9 differentiation discussion 73:16
deeper 128:5 depth 70:6 81:18 69:21 76:11 244:1 95:14 179:18
129:24 167:6 101:13 128:2 107:12 150:8 differently 85:4 205:21 232:12
DEFENDANT 1:5 129:9 130:8 249:16 251:4,12 124:25 168:6 237:1 239:2 247:3
defendants 29:16 131:14,19,24 251:14 252:17 difficulty 17:3 discussions 153:21
Defense 33:12 133:4 137:22,22 developer 69:21 119:15 242:16
define 135:5 163:2 168:9 117:25 249:14 diffraction 117:19 disk 8:14,16,20,25
definitely 248:4,5 176:15 186:8,9 developing 104:9 118:20 120:13 9:1 10:11
degrade 88:21 231:6,20 233:3,12 development 9:13 dig 132:4 displayed 64:8
degree 10:21 13:21 234:1 235:15,17 25:14 80:2 digital 216:15,19 disputed 237:12
14:10 16:25 17:9 236:3,23 238:3,4 devoted 24:13 216:22 dissipates 90:13
18:6 19:23 118:18 238:11,17 239:6 diagonal 181:17 dimensions 148:11 dissipating 90:3,8
degrees 17:8,24,25 239:18 240:6 Diagram 2:17 direct 81:24 189:19 90:11
18:5,5 106:5,11 depths 179:22 dialogue 8:8 directed 53:16 distance 89:14
106:12,15,17 239:20 differ 115:23 direction 39:21 97:18 102:10

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174:4 184:16 257:15 E 1:10 216:2,11 251:8 73:24 125:23
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237:1 241:6 Dr 4:2 5:8 6:25 237:1 250:18 efficient 203:3 ends 39:1
243:16 21:21 38:9 39:10 254:14 effort 37:23 90:20 energies 227:6
distinguishing 39:24 40:2,8,13 early 21:11,14 eight 27:24 29:9 energy 88:13,13,21
147:23 41:19,21 43:1,5 31:14 59:7 76:12 31:4,5,6,8,9 90:2,3,8,12,13
District 1:1,1 4:6,7 44:13 47:2 49:4 227:21 230:10,18 117:18 118:19
190:16,18 193:24 65:20 68:2,21,24 earth 13:14,16 Eighteen 181:11 125:8 146:3
193:25 69:15 72:17 74:22 earthen 77:12 78:8 either 9:4,21 12:8 217:17 241:5
divide 197:11 94:11,14 142:17 116:8 126:13 36:4 38:3 72:17 242:25 243:2,3,5
divided 37:3 147:12 148:17 east 113:25 135:22 76:14 81:13 83:10 243:10,10
division 34:12,13 151:15 189:8 236:6 243:13 129:13,13,14 engineer 49:25
246:11 191:16 203:24 easterly 114:1 154:19 168:12 50:2,4 52:4,6,8,10
divorce 26:10,11 204:2,10 212:5 Eastern 1:1 4:7 183:2 187:1 200:9 52:12,12 80:2
Doctor 74:17 242:2 248:21 eastmost 102:5 206:11 212:8 143:16
document 6:18 7:3 252:17 easy 79:20 231:12 248:1 engineering 13:1
7:14 80:4 216:23 draft 59:7 eat 93:5 element 98:14 25:14 31:18 47:6
249:9 drainage 37:22 Ebersole 37:11,23 elements 48:8 52:5,9
documented 71:2 152:22 38:7 42:3,10,14 elevation 172:22 engineers 1:22 4:8
249:16 253:23 42:22 43:3 44:14 174:25 176:9 24:20 25:3,23
documents 44:6 draw 104:19 123:5 52:14 55:17 56:21 177:16 178:16 28:24 33:15 36:22
81:23 214:18 225:17 56:22 71:3 143:5 182:13,25 187:18 37:3 80:1 81:22
doing 27:13 29:9 drawing 107:23 143:13 144:14 206:12 219:9,10 143:12 190:15,16
30:4,6 31:21 123:13 174:11 147:25 148:17,25 220:15 227:13 190:18 191:7,8,11
37:19 41:1,4,9 213:16 214:17 156:13,14 210:6 231:21 232:12 191:23 193:11
42:5 44:25 54:1 drawings 178:8 Ebersole's 145:11 233:1,22 246:2 200:10 204:9
57:21,24 59:17,24 drawn 177:23 147:12 159:5 elevations 67:14 238:7 247:22
82:23,24 96:2 194:20 213:19 Economics 14:5 193:13 245:22 englobo 6:22 95:2
100:15 113:22 216:1 edge 87:12 88:7 246:5 enhanced 101:12
134:17 156:3 drew 179:25 97:10,12 101:16 emerging 137:17 enlargement 95:15
158:10 163:6 227:20 102:1 106:6,7 emphasis 253:12 ensure 207:9,17
186:10 193:24 drive 217:13 109:25 115:16,19 employ 255:16 enter 197:15
196:3 204:4,14,23 223:18 169:25 174:5 employed 24:9 entered 25:25
221:19 239:12,13 dry 88:19 222:12 223:19 employee 191:23 entire 33:16,17
Dolan 21:22 dubiously 194:10 edification 154:14 244:22 245:3 106:10 110:17
domain 155:6 due 113:25 119:1 Edition 234:24 employees 35:22 169:8
Domains 2:14 195:7 200:10 Edwards 1:11 employment 27:21 entirely 123:14
Domengeaux 1:11 217:20 effect 39:8 47:9 245:10 entirety 204:12
dominant 243:9 dug 128:4 89:18 90:1 138:4 emulate 251:2 entitled 121:21
dominated 138:20 duly 5:4 138:6 165:23 enclosed 112:17 143:2 144:16
Don 92:22 93:11 duration 67:15 166:1 178:9 114:21 122:11 213:5
136:23 143:5 99:22 193:21 195:23 encompasses 32:11 entity 18:21 23:1
190:2 dwelling 150:18 243:15 249:13 encountering entrance 135:6
Donald 1:7 2:4,5 dynamics 13:3 20:4 165:11 envelope 186:24

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environment evaluation 2:9 48:3 215:12 250:22 25:5 F 1:24 221:9

200:25 201:6 52:19 169:5 executable 164:18 experimental 222:13,23 255:2
environmental event 143:19 161:7 164:22 159:22 247:22 255:22
17:5 20:3,8,9 events 40:16 execution 151:9 248:1 face 104:18 152:18
51:20,24 52:1,3 eventual 132:2 executive 36:10 expert 2:5 51:12,15 facility 36:13
environments everybody 9:24 exercise 39:3 172:1 66:10 68:11,12,21 facing 104:17
21:23 25:6 29:21 115:15 exhaust 93:3 73:24 76:2,3,6,24 242:18
episodes 213:7 239:17 exhibit 2:3,4,5,6,7 77:10 98:25 fact 7:2,12 18:25
222:6 everybody's 49:2 2:8,9,10,11,13,14 192:15 195:11,22 19:2 29:23 47:23
equation 44:20 93:6 2:15,17,18,19,20 197:7 210:14 75:14 99:14
equations 117:7 evolution 25:8 2:21,22,23,24 3:1 249:17 107:16 111:4
118:3 163:24 132:1,13 6:6,7,23 7:8,9,12 expertise 30:2 37:8 115:5 117:21
equilibrium 15:15 evolutionary 132:3 7:17,18 18:10 37:15 87:18 196:8 125:18 127:25
20:14,15 132:12 20:3 48:12 55:3 254:12 129:5 130:17
equivalent 139:23 evolved 47:21 55:22,23,24 56:14 experts 37:10,10 133:24 137:18
220:7 exact 20:15 23:24 57:6,7 58:2,3 78:2 38:23 200:8 169:4 185:6,12
ERDC 4:9 25:8,10 53:19,19 79:4 79:22,23 82:4,5 Expires 255:24 188:23 195:7,9,11
36:5 191:17 207:21 218:9 94:22 95:4,24 256:23 257:24 196:7,10 200:21
erode 132:8 exactly 66:7,15 96:2 98:4 101:17 explain 5:17,20 215:7 222:19
erosion 71:3 73:22 82:10 90:21 103:13,15 108:1 16:12 74:17 230:7 233:20
erroneous 72:18,18 98:12 108:11 109:11,20,21 explaining 202:18 237:9 242:17
error 227:15 146:21 151:7,8 110:8 112:4 explicitly 151:16 factor 134:14,15,16
errors 72:16 180:7 185:18 114:14 119:18,20 exposed 99:25 134:18 135:1,3
ESBS 126:13 192:20 206:21 123:14,18 124:9 expressed 77:10 148:20 156:9
ESQUIRE 1:10,10 231:9 248:8 124:12 136:20 78:6 195:13 159:1
1:13,16,17 Examination 2:2 141:17 142:25 expressly 150:21 factored 137:18
essential 43:9,10 5:6 143:4 172:13,16 extend 99:8 factors 209:13
133:18 examined 5:4 175:16,19 178:10 extending 124:16 238:14
essentially 236:7 256:4 179:11,16 181:12 extends 96:11 failed 254:9
establish 97:7,24 example 38:7 65:16 181:14 183:5,12 extense 127:17 failure 254:6
98:8 104:25 122:20 128:22,23 183:15 185:10 extent 38:24 60:18 fair 6:4 59:5 67:7
206:19 207:2 129:21 130:4,9 186:6 205:21,22 68:23 72:11,14 73:4 88:10 94:25
established 84:2,8 162:12 180:24 211:3 212:17 73:20 99:21 129:16,16 130:1
esteemed 172:14 239:19 224:21,23 241:19 110:23 127:14 152:23,25 207:5
estimate 49:15 examples 185:7 241:20 248:13,17 167:23 168:1 232:13,13,21
152:4 241:17 187:4,7 248:22 210:1 254:11 245:15
estimated 152:18 exceed 126:22 Exhibits 7:20 extra 245:14,18 fairly 23:10 109:25
estimates 57:20 231:18 exist 31:6 253:14 111:14 128:1
70:22 71:1 78:22 excellent 67:3 existed 71:22 extrapolate 210:19 136:11 137:21
79:10 151:25 exception 122:11 167:23 200:22 extrapolation 189:11
estimating 203:20 excess 102:16 exp 159:16,21,21 235:10 247:9 fairness 127:8
estuaries 122:12 exchange 178:8 expanse 127:18,18 extremely 73:10 183:24 209:19
et 184:23 179:21 127:19 125:12 falls 87:14
Europeans 30:17 excluded 112:21 expect 158:15 E-ber-sol 42:11 familiar 8:25 10:17
evaluate 130:15 excuse 29:2 68:22 experience 23:6 E-R-D-C 25:11 17:23 31:14 37:11
131:2,9 247:23 69:19 113:2 51:22 99:16 82:2,14,15,22
evaluating 131:12 126:12 185:10 Experiment 24:20 F 86:7 163:12,15

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DONALD RESIO February 9, 2009

UNITED STATES DISTRICT COURT

IN RE: KATRINA CANAL BREACHES

REPRESENTING THE PLAINTIFFS

ROBIN D. SMITH, ESQUIRE

REPRESENTING UNITED STATES OF AMERICA

ALSO PRESENT: Jeff Conner, Videographer

Taken at the instance of the Plaintiffs

REPORTED BY: SHARRON F. ALLEN, CSR, RPR

JOHNS PENDLETON COURT REPORTERS 800 562-1285

27 (Pages 102 to 105)

28 (Pages 106 to 109)

29 (Pages 110 to 113)

30 (Pages 114 to 117)

31 (Pages 118 to 121)

32 (Pages 122 to 125)

33 (Pages 126 to 129)

34 (Pages 130 to 133)

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64 (Pages 250 to 253)

1 CERTIFICATE OF COURT REPORTER 1 DEPONENT'S CORRECTION SHEET

65 (Pages 254 to 257)

A 74:3,12,22 76:2,6 97:19 100:14 air/sea 32:14 and/or 195:8

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

closer 68:12 109:19 94:10 115:13 company 26:19 66:8 245:14

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

environment evaluation 2:9 48:3 215:12 250:22 25:5 F 1:24 221:9

JOHNS PENDLETON COURT REPORTERS 800 562-1285

166:15,17 181:8 221:3,6,11,16 229:24,25 230:19 fit 32:8 51:2 88:21