KTR00161

WESTERINK (VOL I), JOANNES
1/27/2009
Page 1
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
IN RE: KATRINA CANAL BREACHES CIVIL ACTION

CONSOLIDATED LITIGATION NO. 05-4182 K2
JUDGE DUVAL
PERTAINS TO: MRGO AND ROBINSON
(No. 06-2268)
(V O L U M E I)
Deposition of JOANNES J. WESTERINK,
Ph.D., given at the offices of the United
States Department of Justice, 400 Poydras
Street, 9th Floor, New Orleans, Louisiana
70130, on January 27th, 2009.
REPORTED BY:
JOSEPH A. FAIRBANKS, JR., CCR, RPR
CERTIFIED COURT REPORTER #75005
Johns Pendleton Court Reporters 800 562-1285

1/27/2009
Page 2 Page 4
1 REPRESENTING THE PLAINTIFFS: 1 REPRESENTING THE U.S. ARMY CORPS OF ENGINEERS.
2 BRUNO & BRUNO 2 CORPS OF ENGINEERS, OFFICE OF COUNSEL
3 (BY: JOSEPH M. BRUNO, ESQUIRE) 3 (BY: DAVID DYER, ESQUIRE)
4 (BY: SCOTT JOANEN, ESQUIRE) 4 7400 Leake Avenue
5 855 Baronne Street 5 New Orleans, Louisiana 70118-3651
6 New Orleans, Louisiana 70113 6 504-862-2843
7 504-525-1335 7
8 - AND - 8 ALSO PRESENT:
9 THE GILBERT FIRM, LLC 9 TIANA CHRISTOPHEHR, ESQ.
10 (BY: ELISA GILBERT, ESQUIRE) 10 RICHARD PAVLICK, ESQ.
11 325 E. 57th Street 11 SANDY OLINDE
12 New York, N.Y. 10022 12
13 212-286-8503 13 PARTICIPATING VIA I-DEP:
14 - AND - 14 ERIC GOLDBERG, ESQ.
15 ELWOOD C. STEVENS, JR., APLC 15 BRANDAN O'BRIEN, ESQ.
16 (BY: ELWOOD C. STEVENS, JR., ESQUIRE) 16 CHARLES LANIER, ESQ.
17 1205 Victor II Boulevard 17 ASHLEY PHILEN, ESQ.
18 Morgan City, Louisiana 70380 18 KARA MILLER, ESQ.
19 - AND - 19 ELISA GILBERT, ESQ.
20 ANDRY LAW FIRM 20 JOE BRUNO, ESQ.
21 (BY: JAY ANDRY, ESQUIRE) 21 JAMES PARKERSON ROY, ESQ.
22 610 Baronne Street 22 MATTHIAS KOK, ESQ.
23 New Orleans, Louisiana 70113 23
24 504-586-8899 24 VIDEOGRAPHER:
25 - AND - 25 GILLEY DELORIMIER (DEPO-VUE)
Page 3 Page 5
1 DOMENGEAUX, WRIGHT, ROY & EDWARDS 1 EXAMINATION INDEX
2 (BY: JAMES PARKERSON ROY, ESQUIRE) 2
3 556 Jefferson Street, Suite 500 3 EXAMINATION BY: PAGE
4 Lafayette, Louisiana 70501 4
5 337-233-3033 5 MS. GILBERT .................................7
6 - AND - 6 EXHIBIT INDEX
7 SHER, GARNER, CAHILL, RICHTER, KLEIN & 7
8 HILBERT, L.L.C. 8 EXHIBIT NO. PAGE
9 (BY: MATTHEW CLARK, ESQUIRE) 9 Exhibit Westerink 1 ..........................7
10 909 Poydras Street, 28th Floor 10
11 New Orleans, Louisiana 70112 11
12 504-299-2100 12
13 13
14 REPRESENTING THE UNITED STATES OF AMERICA: 14
15 UNITED STATES DEPARTMENT OF JUSTICE, 15
16 TORTS BRANCH, CIVIL DIVISION 16
17 (BY: ROBIN SMITH, ESQUIRE) 17
18 (BY: JACK WOODCOCK, ESQUIRE) 18
19 (BY: MICHELE GREIF, ESQUIRE) 19
20 P.O. Box 888 20
21 Benjamin Franklin Station 21
22 Washington, D.C. 20044 22
23 202-616-4289 23
24 24
25 25
2 (Pages 2 to 5)
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1 STIPULATION 1 Q. Is that your report, your CV?
2 IT IS STIPULATED AND AGREED by and 2 A. It is my CV, yes.
3 among counsel for the parties hereto that the 3 Q. Can you briefly for the record just go
4 deposition of the aforementioned witness may be 4 through your professional background?
5 taken for all purposes permitted within the 5 A. Okay. I'm trained as a civil
6 Federal Rules of Civil Procedure, in accordance 6 engineer. Bachelor's in civil engineering with
7 with law, pursuant to notice; 7 a concentration in mathematics; Master's in
8 That all formalities, save reading 8 civil engineering, both bachelor's and Master's
9 and signing of the original transcript by the 9 from the State University of New York; Ph.D. in
10 deponent, are hereby specifically waived; 10 civil engineering, specializing in
11 That all objections, save those as to 11 computational fluid mechanics and hydrodynamics
12 the form of the question and the responsiveness 12 from Massachusetts Institute of Technology in
13 of the answer, are reserved until such time as 13 1984. I've been a -- through that process, I
14 this deposition, or any part thereof, is used 14 was a research assistant through my Master's
15 or sought to be used in evidence. 15 and my Ph.D. programs; Assistant Professor at
16 16 Princeton, and then Texas A&M, and later at
17 17 University of Notre Dame; Associate Professor
18 * * * 18 at the University of Notre Dame and now
19 19 Processor at the University of Notre Dame; and
20 20 I have concurrent appointment as full professor
21 21 in the math department.
22 JOSEPH A. FAIRBANKS, JR., CCR, RPR, 22 Anything else you want me to --
23 Certified Court Reporter in and for the State 23 Q. Can you just turn for a moment to
24 of Louisiana, officiated in administering the 24 your -- obviously these are your referenced
25 oath to the witness. 25 technical reports and trade journal
Page 7 Page 9
1 JOANNES J. WESTERINK, PH.D. 1 publications. I would just like to skip
2 156 Fitzpatrick Hall of Engineering, Notre 2 through to your sponsored research section.
3 Dame, IN 46556, a witness named in the above 3 A. Okay.
4 stipulation, having been first duly sworn, was 4 Q. Can you describe for the record the
5 examined and testified on his oath as follows: 5 process of obtaining sponsored research, as a
6 EXAMINATION BY MS. GILBERT: 6 general proposition.
7 Q. Is it Professor or Dr. Westerink? 7 A. The typical process is to write a
8 A. Anything you want. I'll go by 8 proposal to a sponsoring agency and to -- which
9 Joannes. 9 typically gets peer reviewed, and then you
10 Q. Okay. We had this conversation, so I 10 obtain funds and fulfill the obligations and
11 will try to say Joannes. I'm going to ask that 11 the research that was defined in the proposal.
12 we mark first your CV which is part of your 12 Q. And for how long have you been
13 report Exhibit 1. I'm going to ask you to take 13 obtaining sponsored research?
14 a moment and look at this and identify this for 14 A. Probably my first grant was about
15 the record -- 15 roughly twenty-three years ago or so.
16 A. Okay. 16 Q. And were you already out of -- you
17 Q. -- if that's your full report. 17 already had your Ph.D. at that time?
18 (Exhibit Westerink 1 was marked for 18 A. That's a sponsored project that I was
19 identification and is attached hereto.) 19 involved in as principal investigator. I
20 A. Yep. This is the report that I sent 20 believe it was from the National Science
21 in. 21 Foundation. Obviously, as a part of the
22 EXAMINATION BY MS. GILBERT: 22 engineering school training you are very
23 Q. And starting at Page 244 is your CV, 23 integrally involved in sponsored research, the
24 Appendix A? 24 concept being that sponsored research is --
25 A. Yes. 25 drives the knowledge base in engineering. And
3 (Pages 6 to 9)
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1 so graduate students are involved in that, as 1 expedite this a little bit, just out of
2 well. 2 curiosity is pollution a mechanism that affects
3 Q. So what was your graduate thesis in -- 3 transport of ocean circulation?
4 your Ph.D. thesis in? 4 A. Typically, there is not enough -- are
5 A. In computational fluid mechanics, 5 not enough pollutants that on a large scale you
6 developing a circulation model -- coastal 6 affect the currents in the ocean, i.e., in a
7 circulation model. 7 very, very near field situation you might, but
8 Q. Can you describe for me what a coastal 8 in a large scale sense you typically do not
9 circulation model means in layman's terms? 9 affect the surface water elevations or the
10 A. Okay. You define the movement of 10 currents in the ocean by adding pollutants.
11 water in terms of what the surface elevations 11 Q. Okay. Now, reviewing your sponsored
12 are and what the currents are. And then you 12 research I see that you have -- maybe we can
13 might also be interested in the transport 13 just go through some of these together. In
14 processes that are typically driven by the 14 1989, the U.S. Army Corps of Engineers
15 circulation. 15 sponsored some research on waterway experiment
16 Q. What does that mean, transport 16 station.
17 processes that are driven by the circulation? 17 Did that have anything -- oh, it's New
18 A. The temperature of the water, the 18 York -- I'm sorry. Was that related to the New
19 salinity of the water, pollutants that might be 19 York area or does that have anything to do with
20 discharged into the water, what their fate is 20 the Louisiana area? The very -- it's Item
21 and what their concentrations and/or 21 Number 5.
22 characteristics are. 22 A. No, that is strictly in the New York
23 Q. And how they affect the movement? Is 23 area.
24 the objective to determine how those affect -- 24 Q. And then Item Number 7, the U.S. Army
25 A. They can affect the movement, and so 25 Corps of Engineers sponsored another study with
Page 11 Page 13
1 it can be a two-way loop feedback, or you might 1 a storm surge application of DRP Circulation
2 just be interested in if you discharge 2 Model to the Gulf of Mexico. Is that the
3 something into the ocean where does it go and 3 Louisiana area or was that the entire coast
4 how does it affect the quality of the water 4 from Texas to Florida?
5 for -- obviously for recreational purposes, for 5 A. That was gulf-wide, and if I recall
6 the health of the ocean, for fisheries, et 6 correctly some of the applications we looked at
7 cetera. 7 were in Texas. DRP stands for dredged research
8 Q. And the first sponsored research, is 8 program. Those were studies to look for the
9 that referred to -- the first one that you just 9 long-term fate of dredge disposal so that you
10 mentioned on National Science Foundation while 10 did not impact the environment by -- through
11 you were pre doctorate, is that the one that 11 the dredging operations which then -- which
12 you received in '87 through '89 on Improved 12 then would -- basically, you'd have to dispose
13 Computations for Convection Dominated 13 of the dredge material, and so the obviously
14 Turbulence Flow Patterns using a -- 14 environmental impact was an important component
15 A. Actually, I was the principal 15 to the operations.
16 investigator. I've only listed -- you 16 Q. Is that for the pollutants in the
17 typically only list what you were the principal 17 dredge material or just the actual removal of
18 investigator on. 18 the material?
19 Q. And when you're principal investigator 19 A. No, the impact is from the pollutants
20 you already have your Ph.D.; is that correct? 20 in the dredge material.
21 A. Almost always, yes. 21 Q. On Item Number 8 is another study that
22 Q. Okay. So these are all post doctorate 22 was funded by the U.S. Army Corps of Engineers,
23 studies. 23 $375,302 to study two-dimensional and
24 A. That is correct, yes. 24 three-dimensional tidal and storm surge
25 Q. Okay. All right. Just to sort of 25 circulation computations for Western Atlantic
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1 shelf and the Gulf of Mexico. 1 two-dimensional and three-dimensional
2 A. Uh-huh. 2 component?
3 Q. And did that have to do with the 3 A. Yes.
4 Louisiana coast area? 4 Q. What was the name of that program?
5 A. That had to do with the entire U.S. 5 A. It's ADCIRC.
6 eastern seaboard and the entire Gulf Coast. 6 Q. Was that the very first version of
7 Q. And can you describe what 7 ADCIRC?
8 two-dimensional and three-dimensional tidal and 8 A. Let's see. Probably ADCIRC first came
9 storm surge circulation computations is? 9 out, I believe, in '88 or '89, so.
10 A. Sure. Well, the title -- you have the 10 Q. Did you develop the very first ADCIRC?
11 tides. 11 A. Yes. Actually, together with a
12 Q. Uh-huh. 12 colleague Rick Luettich at University of North
13 A. Basically which are astronomically 13 Carolina.
14 forced. They cause motion, obviously, in the 14 Q. I see here your Item Number 3 which
15 waters of the ocean, and they're an important 15 was also funded by the U.S. Army Corps of
16 component or can be an important component to 16 Engineers Waterway Experiment Station,
17 water motion and elevation along the coast. So 17 development of a two-dimensional numerical
18 it's of significant interest. 18 model for estimating the long-term fate of
19 Storm surge is the water levels that 19 dredge material.
20 are driven up in a storm and can be a high wind 20 Is that the item where the first
21 event or a hurricane, and that's the combined 21 ADCIRC was developed?
22 effect of all the other processes and how high 22 A. That's probably correct, yes.
23 the water goes during such a wind-driven event. 23 Q. Okay. And so ADCIRC is -- was there
24 Q. And were you developing a computer 24 any predecessor for ADCIRC?
25 program or were you developing just 25 A. Actually, I did develop previous
Page 15 Page 17
1 mathematical equations -- 1 models the ADCIRC, and there are other models
2 A. We were developing computer programs. 2 that were predecessors to ADCIRC, as well,
3 And then the second part of your question was 3 developed by others, yes.
4 two-dimensional versus three-dimensional? 4 Q. But ADCIRC was essentially your baby
5 Two-dimensional is when you make the assumption 5 with Proffesor Luettich?
6 that there's very little variability in the 6 A. Luettich. That is correct, yes.
7 currents over the vertical. 7 Q. And what changed about the ADCIRC from
8 Q. Over the vertical that what you said? 8 the first development and -- well, I guess the
9 A. That's right. Over the vertical, from 9 one that's on your CV that we just referred to,
10 the top of the water surface down to the 10 Item No. 3 to Item No. 8; what if anything
11 bottom. 11 changed about the ADCIRC during the course of
12 And three-dimensional actually looks 12 that research?
13 at the variability of the currents or of the 13 A. Well, there's -- as these models
14 velocities or the speed of the water over that 14 evolve there's essentially three things that
15 vertical. 15 change. There's one, you add more physics,
16 Q. So two-dimensional is just one point 16 more capabilities to compute more processes.
17 to another point, and three-dimensional is with 17 Obviously, the physics of the ocean is very
18 regard to the elevations within that realm? 18 complicated. And you start with a foundation,
19 A. Two-dimensional described the 19 and then you start building in complexity.
20 horizontal variability, and three-dimensional 20 The second development that -- the
21 describes the horizontal and the vertical 21 second component that we spend a lot of time is
22 variability. 22 the algorithms. And the algorithms essentially
23 Q. And in 1990 through 1994, did you 23 convert the partial differential equations
24 develop a computer program that could calculate 24 which are the mathematically formulated
25 the storm surge circulation in a 25 description of the physics into discreet
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1 algebraic equations that can be solved on a 1 A. We had -- we basically developed the
2 computer. And those are the algorithms. And 2 capability to make finer grids and to ensure
3 the algorithms actually have to evolve because 3 that the long waves that we computed on those
4 of our increasing tendency to have finer and 4 grids had more accurate phase propagation
5 finer grids. 5 characteristics, that means that the wave would
6 And then the third thing that changes 6 get to where it was going more accurately than
7 is computer science. And obviously computer 7 it did before.
8 technology has been evolving very rapidly both 8 Q. Okay.
9 in terms of how fast things can be computed and 9 A. And there are several papers in my
10 the very nature of how they're computed. And 10 vita that describe the aspects of that
11 so in order to have a successful code you have 11 particular research.
12 to be pushing all three aspects that I just 12 Q. And then again, I see that you
13 mentioned in order to be able to improve the 13 received a grant from the U.S. Army Corps of
14 end result. 14 Engineers in 1991, tidal predictions in
15 Q. And is there any quantifiable 15 Galveston. Is that just taking that model and
16 distinction that you can say that the first 16 applying it to Galveston using the Gulf of
17 ADCIRC provided that the -- that was added to 17 Mexico model? Galveston Bay, rather?
18 it by the second one, Item Number 8 here? 18 A. That was a small study that refined
19 A. Oh. You know, it's a very rapidly 19 the Galveston Bay area in one of our grids, and
20 evolving process. It keeps on changing. It's 20 was done for a navigation study so that they
21 just like going from, you know, a Ford Model T 21 could improve some of the harbor designs in
22 to a BMW. You know, it's a long road of 22 Galveston Bay and the jetty designs for
23 changes, and we -- in fact, it's right on our 23 navigational purposes.
24 website; we mark changes as we progress and as 24 Q. And that was using ADCIRC, also?
25 we move forward. 25 A. Absolutely, yeah.
Page 19 Page 21
1 Q. So as you sit here today, can you tell 1 Q. Okay. And in between I see you have a
2 me something specifically different from the 2 National Science Foundation Offshore Technology
3 very first ADCIRC to that ADCIRC, or is that 3 Center Grant. Was that also using -- it's
4 too refined, too subtle -- 4 turbulent flow modeling with space/time
5 A. Well, one obvious big one is the 5 filtered solutions to the Navier-Stokes
6 three-dimensionality. 6 equation.
7 Q. Okay. 7 Is that also using ADCIRC?
8 A. Another thing is -- and I'd have to 8 A. No. That's using another code that we
9 get into a lot of technical details, but the 9 developed.
10 parameter that improves the phase propagation 10 Q. Another code. Okay.
11 characteristics of the solution, and we are 11 Then moving onto your 11th, you
12 learning how to set that so that we got more 12 received a grant for $343,265 from the U.S.
13 accurate results. And so there's many, many 13 Army Corps of Engineers for Waterway Experiment
14 aspects. And by the way, a lot of this -- the 14 Station in 1994, enhancement of ADCIRC model
15 results from these studies are reflected in my 15 for analysis of coastal inlet hydrodynamics.
16 journal publication list. So there's somewhat 16 And that's with with the same
17 of a correlation between this list and then 17 professor you developed ADCIRC with?
18 what's in the journals. 18 A. Correct.
19 Q. Uh-huh. And so in layman's terms, you 19 Q. Luettich?
20 added the three-dimensional aspect of it with 20 A. Luettich, yes.
21 regard -- in 1994 ADCIRC had a 21 Q. And can you briefly describe the
22 three-dimensional component which it didn't 22 enhancements that that grant provided in 1994
23 have earlier. 23 to 2000?
24 A. Correct. 24 A. Well, if memory serves me correctly,
25 Q. And it got more refined. 25 again, as I said, it's a very much of an
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1 evolutionary process, there's changes going on 1 grant, briefly?
2 all through this whole time period, and there's 2 A. That was to develop a tidal database,
3 changes going on, significant changes going on 3 I believe. Tides, of course, are important
4 today. It's -- if you sit still and don't 4 factors in terms of how fast the flow goes and
5 improve the algorithms, the computer science 5 how high the water is. The idea was to develop
6 and the physics in those codes, then you 6 a tidal database so that information about the
7 basically -- you no longer improve the 7 tides would be available in all eastern
8 reliability or the predictability with which 8 seaboard and gulf continental shelf waters so
9 you can capture these events. At that 9 that either an engineer might have immediate
10 particular time we probably very much focused 10 information about the local tides and the
11 on jetties and inlets and the small scale 11 currents that would presumably move things like
12 structures of flow, for example, the eddies 12 sediment, and in addition to that they could
13 that form on the insides of jetties which are 13 drive smaller scale local models which at the
14 very important for sediment transported 14 time were still very extensively used because
15 processes. And again, that has implications on 15 the computer resources of these large models,
16 all the three areas where one might improve 16 to have boundary conditions for a local model
17 these models. 17 so, i.e., you could go to a database and then
18 And the other thing, if memory serves 18 you could find out what the tides were in that
19 me correctly, we were very much focused on 19 region and you could then drive that localized
20 vector-based computing in those days. Vector 20 model with the tides.
21 computers were the major supercomputers at the 21 Q. And you focused on generating that
22 time, and if you structured your codes 22 database on the eastern seaboard and the gulf
23 correctly you could get tremendous speed-ups in 23 area?
24 the time it took to do a calculation using the 24 A. That is correct, yes.
25 vector-based architecture of a computer. 25 Q. Your next research grant was with the
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1 Q. So essentially, the enhancements were 1 Navy Research Laboratory in 1997, also using
2 to focus on jetties and inlets and smaller 2 ADCIRC. It's the development and application
3 water bodies and to improve the mathematical 3 of a prognostic three-dimensional baroclinic
4 equations so that you could speed up the 4 capability and ADCIRC hydrodynamic model.
5 process of processing the ADCIRC? 5 Can you describe what that is?
6 A. To improve the coding of the 6 A. Sure. I think we talked about this a
7 transformation of the mathematical equations 7 little bit earlier. Part of the processes that
8 from partial differential equations to 8 can actually drive flow are salinity
9 algebraic equations so that you can speed up 9 differences and temperature differences in the
10 the process. 10 water. So a baroclinic model accounts for
11 Q. Okay. And just the Texas Water 11 those. The diagnostic models makes assumptions
12 Development Board, was that using ADCIRC, the 12 on the salinity and temperature distributions
13 computer simulation of water movement and 13 and then drives the flow. A prognostic model
14 salinity transport in Galveston Bay, Texas? 14 makes the assumption that there's going to be
15 A. It was, yes. 15 interactivity between the transport of salinity
16 Q. That's using ADCIRC, okay. 16 and temperature and the hydrodynamics, i.e, the
17 And then 13. You get another grant 17 hydrodynamics drives the transport or movement
18 for $114,721 from the U.S. Army Corps of 18 of salinity and temperature, and the
19 Engineers for a development of a 19 temperature and salinity in turn drive the --
20 second-generation long wave hydrodynamic 20 drive currents.
21 database for the U.S. coastal and continental 21 By the way, am I loud enough for you
22 margin waters. 22 guys?
23 Did that use ADCIRC? 23 Q. You're loud enough for me.
24 A. That is correct. 24 The next research -- and that was
25 Q. And what was the objective of that 25 ADCIRC. So did you change ADCIRC as a result
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1 of that, or did you develop some sort of 1 Q. Then you received another $21,000
2 component module for using with -- 2 grant from the Texas Water Development Board.
3 A. Well, basically, we added capabilities 3 Was that just to apply your -- I'm
4 to the code that took into account these 4 sorry. What was that grant for?
5 processes in addition to adding transport 5 A. That was essentially to -- again,
6 modules which actually take care of tracking 6 that's a fairly small grant, and that was to
7 the salinity and the temperature and/or 7 implement to some of the Texas estuaries the
8 pollutants that were needed in order to do 8 models that we had been building.
9 that. 9 Q. And the next one also is $21,000 to
10 Q. And then you received a grant for 10 apply ADCIRC for shelves, coasts and estuaries
11 $400,000 for Army Research Office to create a 11 in the Texas Gulf Coast. Is that essential the
12 scalable metacomputing -- for scalable 12 same --
13 metacomputing and computational sciences and 13 A. That is.
14 engineering. Was that with the U.S. Army Corps 14 Q. -- type of project?
15 of Engineers or some other division? 15 Then there's a $200,000 grant in
16 A. No, that's from the Army Research 16 January of 2000 from the University of Notre
17 Office which is the overriding organization 17 Dame Graduate School Equipment Restoration Fund
18 that takes care of research in the U.S. Army. 18 to develop a scalable metacomputing for high
19 Q. And can you describe briefly what 19 performance computational science and
20 this -- did this involve ADCIRC? 20 engineering. And was this also dealing with
21 A. My use and contribution certainly was 21 ADCIRC?
22 ADCIRC; however, you can see that there's 22 A. It does, but basically was an
23 multiple PIs that were doing -- running 23 extension of Grant Number 15. We had -- that
24 different codes for this particular project. 24 was an equipment grant, by the way. Number 15.
25 Q. So the $400,000 was for the entire 25 And Number 18 is, as well. And we took an
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1 project, or was that just for the portion that 1 opportunity to get some internal funds to get
2 you dealt with? 2 an upgrade for our equipment.
3 A. That was for the entire project, but 3 Q. And the next one is U.S. Army
4 the -- it was a computer science based project 4 Engineering Research and Development Center.
5 that was looking into parallel computing. By 5 There was a $674,450 grant for, from the U.S.
6 this time, the computer science had moved very 6 Army Engineering Research and Development
7 rapidly to parallel processing as opposed to 7 Center. Is that affiliated with the U.S. Army
8 vector-based processing, and so the idea was to 8 Corps of Engineers?
9 develop the base knowledge and software to 9 A. That is the -- a major Army research
10 allow us to start putting a whole variety of 10 center that does do research in support of the
11 codes onto parallel machines so that a lot of 11 Army Corps of Engineers.
12 processors could be doing the computations 12 Q. And for this nearly -- this $675,000
13 simultaneously. 13 grant, the project was ADCIRC Hydrodynamic
14 Q. And was that to expedite the actual 14 Circulation and Transport Code Development and
15 output or was that to generate different types 15 Applications. Can you describe briefly what
16 of output? 16 that grant allowed you to do with ADCIRC?
17 A. No, it was to expedite the output. 17 A. Again, the push was higher and higher
18 And the ultimate goal in all of computational 18 resolution. If I may, just for example, the
19 science is to add computational resolution, how 19 starting resolution of the computational grids
20 fine the underlying meshes are in which the 20 that we started out with might have been five
21 calculations are done so that you can improve 21 thousand computational points. By this point
22 the quality of the results. And parallel 22 we were probably at 200,000 computational
23 processing or scalable processing is a huge 23 points. And of course today we're at millions.
24 avenue that opened up around that time or a 24 So that certainly, again, the computational
25 little bit before that towards that goal. 25 aspect of this was very important. If I recall
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1 correctly, there was a major push at that 1 code development and application include work
2 particular time to start including the detailed 2 in the specific geographic area of the
3 interactions with rivers and coastal flood 3 Louisiana coast?
4 plains. So it started encompassing more of the 4 A. I don't recall that specifically. I
5 domain as we moved forward. And again, that 5 think at the time we may have been working in
6 has tremendous implications in how you 6 New York. I'm not sure. Probably at Long
7 implement all the algorithms that are the 7 Island Sound, a bunch of different New York
8 engines to the code. Again, together with that 8 inlets, if I recall. I don't know if we
9 are implications how you write the code in 9 specifically did any Louisiana applications for
10 terms of getting it to work quickly on the 10 that.
11 computer platforms. 11 Q. Okay.
12 Q. And this was done again with Luettich? 12 A. But a lot of the ERDC was nationwide.
13 A. Luettich, yep. 13 And I think, if I recall, actually we also had
14 Q. Were you -- just on an aside, did you 14 interest and projects up in Grey's Harbor,
15 study with Luettich or did you -- 15 Washington and several other inlets there, I
16 A. He was a classmate of mine at MIT. 16 think Willapa Bay. It might be in Oregon. And
17 Q. Okay. The Item No. 20 is a grant for 17 so several inlets and estuarine systems along
18 $247,928 from the Army Corps of Engineers New 18 the Washington and Oregon coasts.
19 Orleans District for modifications of the 19 Q. And when you say ERDC, you mean
20 ADCIRC New Orleans Hurricane Model to enhance 20 Engineering Research Development Center?
21 robustness, accuracy and ease of 21 A. That is correct.
22 implementation. Can you describe what was done 22 Q. Okay. Moving on to the next grant,
23 with that grant to improve the robustness, 23 you received $77,000 from the National Science
24 accuracy and ease of implementation of ADCIRC? 24 Foundation from 2001 to 2004 to develop
25 A. Sure. So again, one of the driving 25 adaptive multinumeric finite element methods
Page 31 Page 33
1 factors is to add more and more details and 1 for shallow water flow. What exactly -- did
2 more and more resolution to describe the 2 that have anything to do with ADCIRC?
3 physical system, and so we were evolving the 3 A. Absolutely.
4 models to do that. Some of that stuff is 4 Q. And how did that affect the
5 published, again in my publication list. And 5 development of ADCIRC?
6 in addition, of course, when you start looking 6 A. So our grids are becoming very large.
7 at hurricanes in southern Louisiana obviously 7 Resolution is very important. You have to
8 it's vital to incorporate the full coastal 8 resolve the physical features that are in the
9 flood plain, all the levees, all the channels, 9 system, i.e., the geometry, bathymetry,
10 and so it was partly implementing those 10 topography, et cetera, but you also have to
11 features, and then making sure that the 11 resolve the flow. So if there's flow features
12 numerical algorithms could sustain the very, 12 that are small scale that evolve and come up
13 very fast flows and currents and rapidly 13 and you don't have the grid sufficiently
14 propagating long waves that were part of these 14 adapted or resolved the capture those features
15 calculations. And so we had some accuracy and, 15 or to resolve them, then you get, A,
16 again, phase propagation enhancements, wetting 16 inaccuracies, and B, potentially instabilities.
17 and drying algorithm improvements, and above 17 So the move at that time was to start
18 and beyond everything resolution improvements. 18 rethinking the basic algorithms which, by the
19 Again, this was -- this whole process has been 19 way, we obviously are continually, through this
20 a huge march forward in terms of resolving the 20 process, looking at the foundation of the
21 physical system and the fluid mechanics of 21 algorithms, what's out there, how we could
22 those processes. 22 implement it better, et cetera, to understand
23 Q. Just to go back for a second to 23 if we should have engine changes. But the
24 Item 19, did the research that you did on the 24 foundation of that was to start rethinking
25 ADCIRC hydrodynamic circulation and transport 25 algorithms so that the grids can start adapting
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1 themselves. So a grid might be course through 1 that the first -- well, what resolution could
2 much of the calculation, but then all of a 2 you get to at that point? Do you recall how
3 sudden a high-concentration gradient comes 3 fine the resolution was?
4 through, a high-velocity gradient, an eddie 4 A. Um -- you know, we were probably --
5 that has shed off of a part of the system comes 5 and this is guessing, but gosh, I'd say we were
6 through, and then automatically the grid will 6 probably at four or five hundred meters or
7 adapt itself to resolve that particular 7 something like that on large scale grids and
8 feature. So, A, you maintain the integrity of 8 maybe about fifty or a hundred meters on small
9 the calculation, and B, you maintain the 9 scale grids. But I'd have to look up at the
10 robustness and stability of the calculation. 10 publications at the time and look at the
11 Q. So the grid stays big on the outside 11 studies to be sure.
12 and then when there's a motion or a small water 12 Q. Okay. So just generally, it went
13 flow it becomes a smaller resolution that you 13 from, it was like a fifth. You got down to a
14 can see it in greater detail? 14 fifth of what the large scale grid was roughly?
15 A. The grid essentially is defined to 15 The small scale was a fifth of the large scale,
16 resolve the topography and bathymetry, and 16 roughly?
17 parts of that can be course if there's not much 17 A. Well, there were small scale study
18 happening. But then when it does find a flow 18 grids which would focus on an inlet and then
19 construct or a flow component that is very fine 19 larger grids that would focus on a region.
20 scale, it does refine itself, so it goes from a 20 Q. Okay. But in terms of the proportion
21 large finite element to smaller finite element, 21 of small scale, I'm trying to figure out
22 either using H adaptivity or P adaptivity, and 22 whether you were getting to like a grain of
23 that means that you can either make the finite 23 sand or whether you were getting to something
24 elements smaller or you can increase the bases 24 that was just -- like you were down to about a
25 functions or the polynomials with which the 25 fifth of the large scale at this point?
Page 35 Page 37
1 functions are described in that finite element 1 A. That's probably correct. So our --
2 from low order to high order. 2 and within each grid, within a large scale grid
3 Q. Okay. And is that -- all right. I'm 3 and within the small scale grid there was a lot
4 getting a little ahead of myself here. 4 of variability also. Really, the grids were
5 Did this study, when you were 5 always designed to try to provide resolution
6 enhancing ADCIRC to be able to do this 6 where you needed it.
7 variation in fine resolution involve studying a 7 Q. Uh-huh.
8 specific geographic area? 8 A. Right? There were not, you know,
9 A. We -- actually, a study like that 9 let's say 10 kilometer or 20 kilometer grids
10 starts on the algorithmic level, and we would 10 everywhere, there were large grids where there
11 start with idealized cases that would be 11 was very little happening and then there were
12 generic representations of the kinds of things 12 small grid finite elements where a lot more was
13 we find in our operational grids, so that we 13 happening, except for our localized studies
14 can understand how the algorithms would work in 14 happened to put a lot more resolution into a
15 those kinds of scenarios. 15 small region, and then within that, for
16 Q. Okay. 16 example, the tips of jetties would be very
17 A. And then as the technology evolves 17 highly resolved.
18 both in terms of algorithmically and on the 18 Q. What was the highest resolution at
19 computer science side of the house, then we 19 this stage, which is like, you know, 2000 when
20 start implementing real situations. 20 you're doing your first -- or wait, no, I'm
21 Q. So at this point you're just doing the 21 sorry, that's not the when you did it -- it was
22 generic study to get the algorithms right -- 22 between 2001 and 2004. How fine could you get
23 A. That is correct. 23 the resolution?
24 Q. -- so you can make the changes. Okay. 24 A. You know, I would say probably the
25 And for the -- for Item Number 20, is 25 finest scale studies, maybe about 50 to 25
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1 meters, something like that. 1 to I believe it's Aquaveo.
2 Q. All right. Moving on to the next 2 Q. Okay. Sorry. That was just a little
3 study is the $21,000 again from Texas Water 3 diversion there. We did discuss the Texas
4 Development Board. Or was this just to apply 4 Water Development Board.
5 ADCIRC to the coast again in Texas? 5 Number 23 is the Millennium Trust
6 A. That was to apply some of the 6 Health excellence Fund, and you received
7 improvements that we had been making to their 7 $209,846 grant in January of 2002 to 2005 to do
8 study areas. 8 hydrodynamic modeling of flooding events in
9 Q. Okay. 9 southern Louisiana. Did that have to do with
10 A. And again, that went hand in hand with 10 ADCIRC?
11 improvements in resolution on their grids. 11 A. It did.
12 Q. On their grids. Did they-- 12 Q. Was that for the State of Louisiana
13 A. No, we got grids from them on their 13 Hurricane Center?
14 study areas. 14 A. It was.
15 Q. Now, when you developed this product, 15 Q. And can you describe what the grant
16 this ADCIRC product and then you apply it to -- 16 was for and what was the enhancements that were
17 who actually owns the ADCIRC model, the 17 provided by that grant?
18 intellectual property of the ADCIRC model, is 18 A. Essentially, it was to set up a --
19 it the funding agent that gave you a grant to 19 what we ended up doing was setting up a very
20 enhance it, or is it the university or is it 20 interactive -- a much more rapid turnaround
21 your personal product? Or how did that work? 21 system so that we could start doing predictions
22 A. Actually, there are several different 22 of hurricane storm surge for incoming
23 versions of ADCIRC, but the -- one code is 23 hurricanes. So everything that we had done had
24 actually copyrighted by myself and Luettich. 24 been hindcast studies, try to get the physics
25 Q. So the one that we're talking about is 25 better, try to be able to do design studies
Page 39 Page 41
1 copyrighted by you and Luettich. 1 with it, and the interest there was to morph
2 So if you wanted to get -- a third 2 this into had a model that would -- could be
3 party or a private person was interested in 3 used for predictions. And that again involves
4 finding out about their waterway, they could 4 speeding up the code on the parallel platforms,
5 pay you personally to get their waterways 5 which we worked on very extensively, it
6 analyzed. 6 involved implementing scripting so that the
7 A. Well, they could buy the code and do 7 codes could be run automatically, and it
8 whatever they wanted with it. 8 involved adding pre and post processing
9 Q. Got you. Okay. But they would be 9 capabilities so that everything could be done
10 buying it from you, not from the U.S. Army 10 much more quickly.
11 Corps of Engineers or the university. 11 Q. Just to back up, other than government
12 A. Actually, they'd be buying it through 12 entities and -- who was a market for ADCIRC
13 several private companies that sell it. And 13 outside of academics and government entities?
14 that's who would be selling it to them. 14 A. There's consulting companies that buy
15 Q. But you own the private companies or 15 it worldwide.
16 you own the software? 16 Q. Okay. What kind of consulting
17 A. No. We just get a royalty from them. 17 entities would have an interest in purchasing
18 Q. Oh, okay. 18 the ADCIRC -- private entities that would have
19 A. And I should say that all governmental 19 an interest in purchasing the ADCIRC?
20 agencies, all universities, all academic 20 A. Any consulting company that would be
21 institutions, all research institutions get 21 doing design or analysis studies along the
22 free copies of the code just for the asking. 22 coast.
23 Q. What are the name of the companies 23 Q. Would that be for any like offshore
24 that have this, that sell the code? 24 oil companies that would have an interest off
25 A. Veri-Tech. And one just changed names 25 the coast, or what private entities would have
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1 an interest in what's going on off the coast? 1 A. Oh. From hindcast to prediction.
2 A. Well, people designing harbors, people 2 Yes.
3 designing discharges of sewerage treatment 3 Q. Right. That's what I meant.
4 plants, people that might be involved in dredge 4 A. From actually putting it into the
5 operations, potentially people doing fisheries 5 forecasting realm where you take the predictive
6 studies, people doing studies of discharges of 6 atmospheric data, i.e., the incoming track of a
7 heated water from a power plant, people 7 hurricane, incoming hurricane, and forecasting
8 controlling water withdrawal for agricultural 8 what the storm surge would be to the
9 purposes from a river, changing the salinity, 9 development of the model that do hurricanes,
10 so there would be a tremendous number of 10 that had started -- in New Orleans and
11 applications. 11 Louisiana, that had started I lot earlier.
12 Q. And the objective would be for 12 Q. Oh, okay. So let me see if I
13 hurricane prediction purposes, or what would be 13 understand the distinction you made. One is to
14 the objective of doing this? 14 look at -- to use this model to deal with
15 A. No, anything that moves water, 15 hurricanes as a general topic, but at the
16 anything that moves sediment, anything that 16 Millennium -- at the time of this, when you
17 moves pollutants, so a wide variety of 17 moved from hindcasting to prediction, that was
18 applications. 18 for forecasting hurricanes as opposed to --
19 Q. Did you have much of a market for 19 A. That was for forecasting incoming
20 ADCIRC in the private entities prior to Katrina 20 hurricanes in a very, very fasttrack --
21 or did it just -- did it become a commercially 21 obviously, if you come up with a solution three
22 interested product after Katrina? 22 days after the weather forecast that doesn't do
23 A. Actually, there's been -- I should 23 much good.
24 make clear that neither a large part of our 24 Q. That's not very helpful. Okay.
25 income or interests are in marketing ADCIRC. 25 All right. So -- and then moving from
Page 43 Page 45
1 Our interests are developing codes to -- high 1 that grant you did another study of the Texas
2 performance computing codes to solve 2 Water Development Board for another $20,000.
3 engineering problems. But I would say the 3 Was that just applying ADCIRC again to the --
4 market -- I don't recall how long it's been 4 improvements in ADCIRC to the Texas coast?
5 marketed through those two companies in the 5 A. Yeah. They were just very interested
6 packages that they have but, you know, that's 6 in keeping abreast of all our developments.
7 been a fairly steady, as I said, worldwide 7 Obviously, their grants are fairly small.
8 market for the last ten years or so. So 8 These are -- they're very, very labor intensive
9 significantly before Katrina. 9 to do all the programming and all the checking,
10 Q. But you had mentioned that the 10 et cetera. But so we did applications for them
11 hurricane prediction components of it started 11 with the models as they were evolving, and that
12 with the Millennium Trust Health Excellence 12 was their -- basically the contribution to be
13 funds? 13 able to get the models to work for their areas.
14 A. Well, actually if you look at the 14 And it certainly was our benefit to have
15 grants that we were discussing, the hurricane 15 another test bed to check our models and see
16 prediction component started quite a bit 16 how they were doing.
17 earlier. 17 Q. Just to back up for a moment, when you
18 Q. Oh. 18 are doing the prediction, the forecasting
19 A. Ready for the various Corps studies, 19 aspect of enhancing ADCIRC, did you pick -- I
20 as well as for the ERDC studies as well as for 20 mean it was from the University of -- the
21 the New Orleans District of the Army Corps of 21 university hurricane center, was it focusing on
22 Engineers. 22 the Louisiana coast, the work you were doing at
23 Q. Okay. Because I thought you had 23 that time?
24 mentioned that it was moving from hindcast to 24 A. It was.
25 prediction. 25 Q. Okay. So you had that database that
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1 you were working with, the Louisiana coast, 1 have the code to run the model, as well. So
2 when you were developing it, and then you 2 the models are specific parts of coastline or
3 applied it also to the Texas coast pursuant to 3 oceans that get run through the code.
4 this grant? 4 Q. So I guess then what I was asking was
5 A. Correct. 5 did this grant from Texas provide the funding
6 Q. Okay. 6 for you to create a model with this code of the
7 A. So -- actually, sorry, I may have 7 Texas coastline?
8 miscaught that one. 8 A. So what the grants from Texas were
9 THE WITNESS: 9 doing all along is providing some money to
10 Can you read that? 10 improve the models in the Texas area, in the
11 EXAMINATION BY MS. GILBERT: 11 bays that they were interested in, for example
12 Q. I was -- maybe I misunderstood, but 12 Galveston Bay, and to then, um -- to apply the
13 when you were working on modifying or enhancing 13 newest codes with all the improvements and
14 the ADCIRC to incorporate aspects of it that 14 capabilities that had been added to those
15 would take it into the forecasting of hurricane 15 models.
16 realm -- 16 Q. Okay. And so when you were doing the
17 A. Yes. 17 original studies, you were using models for the
18 Q. -- for the Louisiana coastline -- 18 Louisiana coast.
19 A. Right. 19 A. Which original studies?
20 Q. -- is the modification of the research 20 Q. The Millennium Trust -- the original
21 or the grant that you received from Texas just 21 prediction, forecasting -- hurricane
22 to include the Texas coast in that study, as 22 forecasting was done on a model for the
23 well or -- 23 Louisiana coast?
24 A. Oh. No, it was to apply the software 24 A. Oh, yeah. Those so those were models
25 developments -- and we probably didn't really 25 that had already been developed. But then we
Page 47 Page 49
1 use -- you know, everything of course builds 1 really -- you know, if memory serves me
2 up, right? We don't have a set of improvements 2 correctly, one of the really main things we
3 that we make for one sponsor and not carry them 3 focused on was getting that from hindcasting
4 forward, i.e., everything that we are sponsored 4 mode to fast forecasting mode.
5 to do moves forward as the code and the models. 5 Q. Uh-huh.
6 And maybe I should make that distinction. So 6 A. And obviously, again, that has
7 there's a code and there is actual models. 7 implication across the board how you to that.
8 Q. Uh-huh. 8 Q. But you have to pick an area to start
9 A. Should I clarify this? 9 with in running models?
10 Q. Please. 10 A. Yeah. Absolutely. The obvious
11 A. Okay. The code is the actual 11 interest of that study was Louisiana.
12 software. 12 Q. Louisiana. The next grant you
13 Q. Uh-huh. 13 received was $445,506, again from the Army
14 A. And it converts the differential 14 research --
15 equations to algebraic equations. 15 A. I think you skipped the Sun
16 Q. Uh-huh. 16 Microsystems.
17 A. So then there's the model -- the 17 Q. I'm sorry. Yeah, I did. The next one
18 codes, they have the computer science in them, 18 was a $40,896 grant from Sun Microsystems
19 the mathematics, i.e., the algorithms, all the 19 matching equipment grant. Did that have
20 coding. And then there's the models that are 20 anything to do with ADCIRC?
21 the input devices with the grids, with all the 21 A. Yeah. That was basically our own
22 information on them, the topography, the 22 parallel processing computer that we ran ADCIRC
23 bathymetry, the levees, the land use, the 23 on.
24 friction factors. And obviously you have to 24 Q. The next one -- and that was in July
25 have a model to run the code, but you have to 25 of 2003.
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1 A. Uh-huh. 1 within the codes on the physics and the
2 Q. The next one was in -- between 2 resolution on the computer science and the
3 February of 2005 and January of 2007, the Army 3 algorithms. Everything is coupled together.
4 Engineering Research and Development Center 4 So rarely do we say, well, we're just going to
5 funded a grant in the amount of $445,506 to 5 focus on this one little component and not
6 apply coastal zone modeling system for 6 worry about the rest, because everything is
7 circulation, transport and morphology for the 7 related.
8 development and applications of ADCIRC CZMS. 8 Q. Understood. But with regard to
9 Can you define -- can describe that for me? 9 modeling, if you're going to apply all these
10 A. Sure. 10 other things to an area in the universe -- or
11 Q. Okay. 11 the earth, all of the work that was done
12 A. That -- essentially, we had gotten to 12 applying to the model of the Louisiana
13 the point that it started being important to 13 coastline came from either the Army Corps of
14 try to actually have a feedback loop of 14 Engineers or that Millenium --
15 morphology, i.e., what the bottom surface of 15 A. Some had already come from Waterways
16 the ocean looks like backed into the 16 Experiment Station, so from ERDC.
17 hydrodynamics. So what happens as you develop 17 Q. ERDC.
18 a scour hole? Obviously, flows slow down. How 18 A. They had had an interest in -- they
19 do scour holes form and how do they interact 19 had had a generic interest in applying --
20 with hydrodynamics? So it was building a 20 looking at hurricanes along the whole U.S.
21 sediment transport model and having that feed 21 coastal. But certainly one of the areas of
22 right back into the hydrodynamics and vice 22 interest that we had looked at for them or with
23 versa. 23 them had been the Louisiana area.
24 Q. Okay. So prior to this time, prior to 24 Q. Okay. And when you are applying --
25 2005, 2007, the prediction model and the 25 when you're improving a model or developing a
Page 51 Page 53
1 hindcast -- the forecasting and the hindcasting 1 model, are you improving the grid, or is that
2 models for ADCIRC didn't incorporate the bottom 2 what you mean when you're saying everything has
3 surface of the ocean, what the bottom surface 3 to be worked on together and then you apply a
4 of the ocean looked like? 4 model of a geographic area?
5 A. Oh, absolutely they did. They didn't 5 A. Okay. So we -- our kind of the reason
6 incorporate the evolution or the scour or 6 for being is to improve the whole package.
7 accretion of sediment during some type of 7 That's our interest. We're not simply model
8 event. So i.e., the change. You cannot not 8 users. Our goal is to improve the whole code,
9 have what the bathymetry looks like, but the 9 plus the model, which ultimately ended in the
10 change in bathymetry that might occur during a 10 predictability of the features that we're
11 storm event or during tides or during any kind 11 looking for, so storm surge, tides, riverine
12 of driver event how the bottom changes during 12 currents, what have you. So we're looking at
13 that event, that was then included. 13 the whole gamut. And now, certainly, what we
14 Q. Just to back up a second, with regard 14 then deliver and people can use is our guidance
15 to the Louisiana coastline work that you used 15 on how to build the models at a certain point
16 for a model for applying ADCIRC, did any entity 16 and guidance how to use the code. And they
17 other than the U.S. Army Corps of Engineers 17 then become model users. That at a certain
18 provide funding for the Louisiana coastline 18 point in time has a certain amount of physics,
19 specifically, as a model? 19 numerics, i.e., algorithms, and computer
20 A. I suppose the Hurricane Center did, to 20 science built into it. But our -- certainly in
21 some extent. The main work was -- again, 21 the academic arena, it's our goal to improve
22 everything is very wrapped in. It's not you do 22 the predictability of those models so we're
23 one little part and you get a better solution; 23 always working objective our components.
24 you have to be work on the models, you have to 24 Q. And that's the grid part or the
25 be working on the codes, you have to be working 25 application of the code to creating a grid.
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1 A. Well, it's building the grid to run 1 you can actually -- you get the right
2 through the code -- 2 convergence rate to make sure that as you're
3 Q. Okay. 3 refining that grid that the answers are getting
4 A. -- i.e., you know, if you're, for 4 better at the right rate; and the second aspect
5 example, working on the vective acceleration 5 of those studies is to be able to quantify what
6 terms of the study, eddying at a jetty, you 6 the error levels are that are associated with a
7 have to improve the algorithms, but the 7 certain set of grid resolution or a certain
8 algorithms are pretty dependent on the grid 8 range of grid resolution for a particular
9 spacing, so then when you have the model, a 9 process to then give you guidance on how to
10 major component of model is the grid, you have 10 build grids that will do a good enough job at
11 to improve the grid, too, to understand that 11 simulating the physics in a particular area.
12 all. 12 Q. Okay. Now, so that's what you were
13 And obviously we also do convergence 13 doing with the $445,506, was to create the --
14 studies to understand -- to make sure that the 14 both to improve the modeling and to improve the
15 algorithms are working correctly. So that 15 convergence studies?
16 involves building a whole sequence of grids to 16 A. Well, actually, the convergence
17 do the study. 17 studies, again, you can see this in the papers
18 Q. Can convergence -- we have converge 18 that we published, but the idea there -- the
19 energy studies. 19 main focus of that was to start coupling the
20 A. No. Convergence. 20 sediment transport and morphology models to the
21 Q. And what exactly is that, convergence 21 hydrodynamics in a two-way mode.
22 studies? 22 Q. Two-way. What do you mean by two-way
23 A. So, you have a discreet set of -- you 23 mode?
24 have the continual mathematical equations, a 24 A. Well, that the sediment transport and
25 set of partial differential equations, okay, 25 morphology are driven by the hydrodynamics or
Page 55 Page 57
1 from calculus. 1 fluid flow, and that then, in turn, the fluid
2 Q. My favorite. 2 flow is affected by the changes in morphology.
3 A. It's the foundation of engineering. 3 Q. Okay. And did ADCIRC then develop a
4 And you then -- you can't solve those equations 4 component or a module that would process that
5 in close forms, and that's of course where all 5 information? Is that what you were doing at
6 the algorithms come in. The algorithms convert 6 that point?
7 those equations into discreet algebraic 7 A. That is correct.
8 equations. The simplest concept to explain 8 Q. And is that like an optional addition
9 that is if you, for example, go back to basic 9 to the ADCIRC or is that something that just
10 calculus, a derivative is the rise over the run 10 becomes part of the program?
11 as in the limit as the run goes to zero. 11 A. That is still an optional component,
12 Q. Uh-huh. 12 but as we move further along in that realm it
13 A. So what we're doing is we're 13 will become an integral part of the whole
14 essentially getting discrete approximations to 14 system.
15 those derivatives. And so once you go through 15 Q. When you're testing the convergence
16 that process, there is an error, there's what's 16 studies on these, how do you do the -- I mean,
17 called a truncation error. The algebraic 17 how do you confirm the consistency of the rate
18 equations are no longer identical to the 18 of accuracy?
19 continuing equations, they're only identical in 19 A. Okay. Well, you can do one of three
20 the limit as the grid size goes to zero. 20 basic things: You can either look at a problem
21 However, we want to be able to quantify what 21 that has an analytical solution and that
22 that error is and we also want to be able to 22 applies some simplifications in the actual
23 quantify the rate at which that error reduces, 23 problem that you would look at. The second
24 and that's the order of the method. So the 24 thing is that you can use what's called
25 idea behind a convergent study is to prove that 25 Richardson-based extrapolation, and that is
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1 understanding the theoretical form of the 1 federally funded for the development of ADCIRC?
2 truncation errors, and the truncation error is 2 A. Yeah. I think -- well, I'd have to
3 defined as the difference between the 3 take a quick look at it, but there are small
4 differential equation and the algebraic 4 contributions from Texas and Louisiana;
5 equation that represents it, and studying that 5 otherwise, it's the Army, the Navy and the
6 theoretical form and you can actually derive an 6 National Science Foundation that I have that
7 approximate error of the leading order of 7 have been the sponsors.
8 truncation error term, if you have two 8 Q. Okay. Now, do you know of any other
9 solutions to the same problem on different 9 entities that are working privately to
10 grids. 10 develop -- or academic institutions that are
11 Q. Okay. 11 working privately to develop ADCIRC separately
12 A. And you can then estimate that error. 12 from your research?
13 And the third way is to have a very finely 13 A. Yeah. There's -- we have evolved
14 resolved grid, and that's super finely 14 into, really, a development community.
15 resolved, that you then use to test much 15 Q. Uh-huh.
16 courser grid solutions. We typically use 16 A. There are former students and people
17 either the first or the second method. 17 that have interest in it that are also actively
18 Q. Now, just quickly, why do you prefer 18 developing components of it and contributing to
19 the first two over the third test for 19 it, so we're really evolving more into a
20 reliability on the convergence study? 20 community-based model with contributors at
21 A. Well, because in order to get a fine 21 Texas, at Oklahoma, at the U.S. Navy, at the
22 enough grid to essentially minimize the 22 Corps of Engineers, and Penn State, Ohio State,
23 truncation error relative to the grids you're 23 University of Tokyo, so a lot of people are
24 studying, you have to refine it so much that it 24 very actively working on it. And the reasons
25 becomes very, very cost prohibitive. So you 25 for that are obvious.
Page 59 Page 61
1 start pushing it out of the realm of reality. 1 Q. Is there a forum where you go to
2 So it's much nicer to work with that sequence 2 critique each other's development of ADCIRC, or
3 of grids where you're comparing, let's say, 3 is there one version of ADCIRC that's
4 Grid A and B, and then B and C, and then C and 4 considered particularly the only official
5 D, and to extract errors out of that. And in 5 version or the best version?
6 fact in you can -- in that methodology, you can 6 A. I believe that's two questions.
7 check yourself by checking the error from Grid 7 Q. Okay. You're right.
8 A to Grid B, and then from Grid B to Grid C, 8 A. The first is we have an annual
9 and computing the error for Grid B and seeing 9 workshop where developers and users get
10 if you come up with the same answer. 10 together, it rotates between the U.S. Navy, the
11 Q. Okay. I'm going to try and sort of 11 U.S. Army and the National Oceanic and
12 expedite this thing. You have, of the 12 Atmospheric Administration, and we share notes
13 remaining studies, granted studies that you 13 on what works, what doesn't work, that needs
14 received from -- let's start back at the 23, 14 improvement, et cetera. And then there are
15 Millennium Trust -- you have one, two, three, 15 official release versions that are posted on
16 four -- let's say, Item 26, 28, 29, 30, 31, 32, 16 the adcirc.org site and that you can obtain by
17 33, 34, 35, 36 -- well, let me ask you this: 17 requesting -- sending an E-mail to Rick
18 Is the National Science Foundation a federally 18 Luettich. And complete documentation on that
19 funded grant? 19 website of how the code works, which -- users
20 A. Absolutely. It's one of the premier 20 manuals for the various versus, theory manual,
21 science foundation -- science sponsors in the 21 everything is out there.
22 country. It's funded directly by Congress. 22 Q. Just to back up, and I know that
23 Q. Other than Offshore and Coastal 23 you're here pursuant to this litigation against
24 Technologies and Sun Microsystems and the 24 the Army Corps of Engineers and the federal
25 Millennium Trust, are all of your grants 25 government. We have -- the plaintiffs have
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1 presented expert reports from several sources. 1 A. Um -- you want to some history on
2 Are you familiar with the plaintiffs' 2 that?
3 experts' reports? 3 Q. If you can do it quick.
4 A. Actually, I have briefly looked at 4 A. Okay. The Belgians actually started a
5 some of them at various stages. I have, 5 workshop on unstructured ocean modeling, and
6 however, not studies them very carefully. 6 the Delft people got very involved in that and
7 Q. Okay. When did you first receive any 7 basically have been organizing that workshop
8 of the plaintiffs' experts' reports? 8 together with some of the other Europeans. In
9 A. Actually, I'd have to check my -- some 9 fact, I've organized one of the workshops in
10 of my notes on that, but I would -- I would say 10 that series here in the United States, in
11 maybe six months ago? I'm not exactly sure. 11 Miami. And so we've become really a much
12 Again, I have never spent tremendous amounts of 12 larger community interested in forward building
13 time. I've reviewed some of them briefly, but 13 these unstructured grids of many processes in
14 not really thrown myself into it. 14 the ocean, circulation, sediment transport,
15 Q. Okay. I have -- I apologize for going 15 transport, and certainly waves being an
16 back and forth on this. I have one last 16 important process, as well. So out of this
17 question for you in your sponsored research. 17 workshop, the cooperation between their group
18 There's a note in Item 31 of the Office of 18 and our group developed and we were able to
19 Naval Research Project Wave and Circulation 19 obviously obtain major funding from the Office
20 Modeling on Unstructured Grids. 20 of Naval Research to concurrently sponsor both
21 A. Correct. 21 efforts and to couple these models very, very
22 Q. And it says that the project is in 22 closely together, which we've succeeded in
23 cooperation with a separately ONR-funded 23 doing.
24 parallel project entitled A Spectral Shallow 24 Q. I know I asked you whether you're
25 Water Wave Model with Non Linear Energy and 25 acquainted with Professor Vrijling. Do you
Page 63 Page 65
1 Phase Evolution at Delft University. 1 have a professional opinion of his work on the
2 A. Yes. 2 SWAN modeling?
3 Q. Were you working with Delft University 3 A. Actually, I believe that he did not --
4 on that study? 4 he's not a developer of the SWAN model. So, in
5 A. Yes. 5 fact I'm sure of that.
6 Q. Are you acquainted with Hans Vrijling? 6 Q. All right. Withdrawn. Are you
7 A. No. 7 acquainted with Paul Kemp?
8 Q. Did you have anything to do with his 8 A. Yes.
9 team at all when you were working on that 9 Q. And what is your professional opinion
10 project? 10 of Mr. Kemp -- or of his work?
11 A. No. I actually -- so the lead 11 A. Um -- you know, he's more on the -- I
12 professor is Guus Stelling. The associate 12 would say the ecology side of things. I've
13 professor is Leo Holthuijsen. And they're the 13 been involved with him in some ADCIRC work. I
14 principal investigators. We work with one of 14 don't have strong opinions of his work one way
15 their research personnel, Marcel Zijlema. And, 15 or the other.
16 um -- but I'm not personally familiar with 16 Q. And how long have you known or been
17 Professor Vrijling. I am, however, obviously 17 acquainted with Paul Kemp?
18 familiar with some of the other people at 18 A. Well, we can go back to your list of
19 Delft. 19 things here, and I guess probably since about
20 Q. Are you acquainted with his work? 20 2002 or maybe 2003.
21 A. Not tremendously well. 21 Q. What was the nature of your
22 Q. Do you happen to know whether the 22 acquaintance with him in 2002 and 2003?
23 work -- was the work you were doing with Delft 23 A. He was also working on the Item 23 on
24 University associated with the SWAN model or 24 the LSU side.
25 another unstructured grid model? 25 Q. And are you acquainted with Bob Bea a
17 (Pages 62 to 65)
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Page 66 Page 68
1 professional level? 1 the first time that you were contacted to
2 A. I have just seen Bob Bea give some 2 prepare that report? When was that contact?
3 talks to the National Research Council during 3 A. Gosh. Well, I should say that we have
4 the IPET reviews, and of course have read about 4 a lot of projects going on obviously
5 him in the newspaper, and that's about it. 5 simultaneously, and so I would say that, um --
6 Q. Do you happen to know anything about 6 you know, perhaps -- and I'd have to look at my
7 the SWAN model? 7 records, but perhaps about nine months ago or
8 A. Yes. 8 something like that, or a year ago, that I
9 Q. What, do you know if the Office of 9 think I was first asked to participate.
10 Naval Research uses the SWAN model? 10 Q. Can you describe for me the first time
11 A. Yes, they do. 11 that you were contacted nine months ago? What
12 Q. Is that in addition to or in 12 was the nature of the request that was made of
13 conjunction with the ADCIRC model? 13 you?
14 A. Well, they're two models doing very 14 A. Um -- basically to provide assistance
15 different things. 15 to the Department of Justice in the modeling
16 Q. Okay. 16 work of the surface elevations and currents,
17 A. The ADCIRC model computes currents and 17 i.e., the ADCIRC modeling, to see what happened
18 water surface elevations. They're much longer 18 and what some of the pertubations in the system
19 wavelength processes. On the other hand, the 19 could have done to the water surface
20 SWAN model computes wind waves, so the waves 20 elevations.
21 that you see coming in at the coast and of 21 Q. Pertubations in which system?
22 course can be much larger. And so, however, 22 A. Well, the hurricane protection system.
23 what our involvement is is to couple the two 23 But essentially to give expert guidance on
24 models, because the two processes, the currents 24 hurricane storm surge modeling.
25 and water surface elevations, affect the wind 25 Q. And was it in specific response to the
Page 67 Page 69
1 waves, and the wind waves affect the currents. 1 litigation, or was it a general request to do a
2 So there's a very important interaction there 2 study based on the events that Katrina --
3 that has traditionally been neglected, and 3 A. Um -- that you'd have to ask them.
4 there's many, many levels of that interaction 4 You know, basically they asked me to give them
5 that we are very, very heavily involved in in 5 guidance, and the broad-based study, of course,
6 coupling, and that's the basis of the Office of 6 that I was involved in prior to the litigation
7 Naval Research project. 7 was the IPET investigation. That was a
8 Q. Are you acquainted with the developers 8 broad-based effort to try to understand what
9 of SWAN? 9 happened during the hurricane -- during
10 A. Yes. Actually, the -- well, the SWAN 10 Hurricane Katrina.
11 has a long history to it, as does ADCIRC. And 11 Q. And nine months ago when you were
12 the Dutch academic system has mandatory 12 contacted to do work --
13 retirement, so quite a few of the earlier 13 A. Again, I'd have to look
14 developers of SWAN have retired. And so 14 specifically --
15 there's a -- really, there's a current 15 Q. Roughly nine --
16 generation of developers at Delft right now. 16 (Brief interruption.)
17 It is a university model. 17 EXAMINATION BY MS. GILBERT:
18 Q. Going back to where we were when I 18 Q. Okay. We're going to use nine months
19 took my little diversion there, we were talking 19 ago as a rough date. Could it be more like a
20 about the plaintiffs' expert reports that 20 year ago?
21 you've had -- 21 A. It could be. I would really have to
22 A. Yes. 22 check my records.
23 Q. -- for approximately six months. 23 Q. If you would give me a range so that I
24 When you prepared the report that is 24 wouldn't be boxing you in and wouldn't be
25 in front of you marked as Exhibit 1, what was 25 excluding a time frame, that would be helpful
18 (Pages 66 to 69)
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Page 70 Page 72
1 so that we could work within that time. 1 problem?
2 A. Let's call it a year and we'll call 2 A. I would have to look that up. Um --
3 the rest round off. 3 but probably I would say maybe a year or so
4 Q. A year ago when you were contacted to 4 before Katrina. And there were several other
5 prepare this report, was there any discussion 5 studies done as well by private -- certainly by
6 of this litigation associated with the 6 a private company during the pre-Katrina
7 preparation of that report? 7 period.
8 A. Um -- there were certainly discussion 8 Q. Can you just -- can you list for me
9 of the pending litigation. 9 the studies that you're referring to that
10 Q. Uh-huh. And when you were first 10 predate your IPET involvement, the sequence of
11 contacted with regard to this report, were 11 studies?
12 expert reports furnished to you or do you 12 A. Well, there's probably -- to the best
13 recall having received any kind of 13 of my recollection, there was a study that
14 documentation about what the theories of the 14 looked at the MRGO that we did together with
15 experts were at that time? 15 the MVN.
16 A. There were -- as the reports were 16 Q. MVN?
17 produced, I did receive and look through 17 A. The New Orleans District. Mississippi
18 several expert reports, as they came on line. 18 Valley New Orleans District.
19 Q. Over the course of the year. 19 Q. Okay. When was that?
20 A. Over the course of the year, yeah. 20 A. Gosh, I'd really have to look that up
21 Q. Okay. Do you recall how the project 21 to give you an exact date.
22 was presented to you, what the problem was that 22 Then --
23 you were to solve with regard to this 23 Q. Was that in connection with the
24 litigation aspect of your study? 24 reevaluation of the MRGO in 2000 or 2001?
25 A. It was to ascertain the influence of 25 A. I'm not sure, you know. I mean, these
Page 71 Page 73
1 the MRGO on the flooding in the Metropolitan 1 studies -- we're asked to provide technical
2 New Orleans region. 2 guidance. Often we really don't know what the
3 Q. How many people were involved -- or 3 project sponsor is.
4 were you the first person involved in setting 4 Q. Okay. And so would about 2000, 2001
5 up the paradigm to study this problem of the 5 be about the time frame that -- an accurate
6 influence of the MRGO on flooding of the 6 time frame?
7 Metropolitan New Orleans region? 7 A. It could have been a little bit later
8 A. It was an issue that was also of 8 than that, you know --
9 interest in IPET. It was an issue that was of 9 Q. Okay.
10 interest to the Corps prior to IPET. And there 10 A. -- I'd say. There was then also a
11 was a sequence of studies that were done in 11 study that was done by URS Corporation, I.
12 order to look at the sensitivity of the storm 12 Believe, and to the best of my recollection,
13 surge to the MRGO looking at various 13 that particular study was done for the
14 pertubations of the system. 14 Louisiana DNR. That was also an ADCIRC study.
15 Q. So your involvement initially in 15 Q. Just to go back for the second, the
16 studying the influence of the MRGO on flooding 16 first one that you mentioned with the MVD --
17 in the metropolitan area started with IPET? 17 A. MVN.
18 A. I believe it was before that. 18 Q. MVN. I'm sorry. Was that for an
19 Q. Okay. When was the first time that 19 academic study or this was as a hired
20 you were contacted to study the influence of 20 consultant?
21 the MRGO with regard to the flooding in 21 A. I believe it was just part of our
22 metropolitan area of New Orleans? 22 contractual work with the district. It was a
23 A. Well, it was prior to Katrina. 23 small study.
24 Q. Okay. How long prior to Katrina were 24 Q. When you say your contractual work
25 you personally involved in studying this 25 with the district, is that different from
19 (Pages 70 to 73)
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Page 74 Page 76
1 research grant? 1 were involved in these full studies of the
2 A. No. That's part of the research 2 flooding?
3 grants that we receive from them. 3 A. Um -- to the best of my recollection,
4 Q. Okay. So it was part of some other 4 what we did is we eliminated MRGO Reach 1. I
5 study that you received funding for -- 5 think we decreased the depth -- sorry, we
6 A. Yeah. I believe so, yeah. 6 eliminated Reach 2 and we decreased the depth
7 Q. -- from the New Orleans District or 7 of MRGO Reach 1.
8 the MVN. 8 Q. I'm sorry. When you first did the
9 A. But I'd have to check my records on 9 study that you're referring to, when was the
10 that. 10 very first time that you did a study where you
11 Q. Okay. Could you please do that, and 11 eliminated Reach 2 to evaluate the flooding in
12 we'll request the production of those records 12 New Orleans?
13 to identify when and who funded that study. 13 A. That was the first study done let's
14 The next one was URS Corporation. I'm 14 call it maybe five years ago.
15 sorry. 15 Q. Five years ago.
16 A. Correct. 16 A. So approximately, plus or minus, to
17 Q. And was that an academic study or as a 17 the round off accuracy of the number 5.
18 paid consultant? 18 Q. So the very first time that you did a
19 A. That was a private contractor study. 19 study that was specific to the MRGO and the
20 What we did was basically gave them some grids 20 impact of the MRGO with regard to storm surge
21 and the code and they went to work themselves 21 or storm flooding in the New Orleans area you
22 and drew their own conclusions. We had no 22 eliminated the Reach 2.
23 further involvement in that study. 23 A. Correct.
24 Q. Okay. And what was the next study 24 Q. And was that the same study in which
25 that you were involved in or related to the 25 you reduced the Reach 1?
Page 75 Page 77
1 MRGO and the impact of flooding? 1 A. I think that was a later study for
2 A. To the best of my recollection, we 2 IPET that we reduced the depth of Reach 1.
3 looked at this issue during IPET, and I believe 3 Q. Okay. So five years ago you
4 it may be an appendix in the IPET report. 4 eliminated Reach 2, and in IPET you did a study
5 Obviously, during a study like that you want to 5 reducing the depth of Reach 1.
6 start looking at all the possibilities, and 6 A. Correct.
7 that's what was done. 7 Q. So when you were doing the elimination
8 Q. What are the possibilities that you're 8 of the Reach 2 -- five years ago when you
9 looking at? 9 started this study, the first study, did you do
10 A. Well, what the sources of flooding 10 anything other than study what would happen if
11 were. So we looked at many, many pertubations 11 you eliminated Reach 2, five years ago?
12 of the system, what the influence of barrier 12 A. To the best of my recollection, the
13 islands were, et cetera. 13 main focus of that was to eliminate Reach 2.
14 Q. I'm sorry. Go on. 14 Q. Did you do anything associated with
15 A. So we looked at a lot of variabilities 15 narrowing it or -- at that time, in the five
16 and configuration components of the flood 16 years ago, narrowing it, changing the
17 protection system in southern Louisiana to try 17 parameters of it?
18 to establish what factors would influence storm 18 A. Well, we certainly put the marsh back.
19 surge. 19 Q. This is five years ago now.
20 Q. And when you were doing that, the 20 A. Yes.
21 study of the MRGO specifically came up in these 21 Q. Okay.
22 particular studies. 22 A. But certainly the grid resolution that
23 A. That is correct. 23 we could afford at that particular point in
24 Q. All right. And what aspects of the 24 time is not nearly what it is that we can
25 MRGO did you study with regard to -- when you 25 afford today, so going down to the really,
20 (Pages 74 to 77)
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Page 78 Page 80
1 really high level of geometric detail, for 1 of it, we just didn't do it.
2 example, that we've gone to recently, that was 2 Q. Okay. Why didn't you do it back five
3 not possible. 3 years ago?
4 Q. So when you say that you eliminated 4 A. Well, because most of the hurricane
5 Reach 2 in the study you did five years ago, 5 storm surge signals that we were looking at
6 how exactly did you -- did you fill it in to 6 were fairly close to water -- open water. And
7 ground level? How did you go about -- what 7 so the sensitivity to frictional resistance
8 were the parameters of your study at that time? 8 then becomes much less.
9 A. We filled it in to adjacent topo and 9 Q. When you replaced Reach 2 of the MRGO
10 set -- essentially set the elevation -- totally 10 five years ago, how far up did you go? Did you
11 filled it in. 11 go up to past Bayou La Loutre?
12 Q. And at the time you were doing the 12 A. We went basically to where the
13 study then, you filled it in, and did you also 13 confluence of the GIWW and MRGO is.
14 restore the marsh to whatever kinds of 14 Q. That was five years ago.
15 vegetation was there, um -- 15 A. Five years ago, and all the way down
16 A. Actually, if I recall correctly, in 16 to where it was dredged to in the ocean.
17 the very early study we did not have the 17 Q. Past Bayou La Loutre?
18 detailed Manning's N based representation of 18 A. Yes.
19 friction. We had what was called a Chezy 19 Q. So up at the confluence of the GIWW
20 representation of friction. So I believe that 20 and the MRGO, the topographical area wasn't
21 we did not play with that parameter extensively 21 open water. So if you had the capacity to
22 in those days. 22 input Manning's N coefficients back five years
23 Q. So that was a study five years ago. 23 ago when you were replacing the Reach 2 up at
24 And five years ago, could you have 24 the top, why didn't you do it up at the top, if
25 changed the Manning's N coefficient in your 25 you recall?
Page 79 Page 81
1 ADCIRC? 1 A. As I said, really, the high water
2 A. Um -- so five years ago, we were 2 marks that we were dealing with --
3 looking at flooding that was typically quite 3 Q. Uh-huh.
4 close to the coast. Obviously, since that time 4 A. -- that were reliable at the time,
5 the historical hurricane record has changed 5 they were typically close to open water, so
6 very dramatically, and the extent of inland 6 that the whole dynamics of extensive inland
7 flooding has dramatically changed. 7 inundation really hadn't been worked out very
8 Q. Uh-huh. 8 well yet.
9 A. This necessitated us improving the 9 Q. Okay.
10 frictional representation in our model. And so 10 A. And that's -- again, obviously after
11 we spent, during IPET and the subsequent LACPR 11 Katrina and Rita, but particularly Rita, that
12 studies, quite a bit of time really going to 12 became extremely important to try to work that
13 very, very broad-based, very wide flood plain 13 out correctly. And so that's when we moved to
14 studies that would inundate a large part of the 14 the much better in terms of inland coastal
15 coast. And so the improvement in the 15 flood plain inundation representation of the
16 frictional representation really evolved during 16 friction formulation to Manning's N.
17 IPET. And that was very important, especially 17 Q. So you weren't using Manning's N back
18 for a storm like Rita with very, very extensive 18 in -- five years ago at all a, you were using
19 inundation. 19 the other.
20 Q. Okay. So then my question is, during 20 A. Chezy formulation.
21 the time five years ago when you were doing 21 Q. Chezy formulation.
22 this study, was ADCIRC capable of taking 22 A. Right.
23 multiple Manning's N coefficients or not? Five 23 Q. Okay. After this study where you
24 years ago, prior to the IPET, I mean. 24 filled in the MRGO, five years ago, and you did
25 A. It would have been certainly capable 25 your studies with the Chezy formulation, you
21 (Pages 78 to 81)
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Page 82 Page 84
1 described another study in which you -- for the 1 down very quickly compared to the other longer
2 study that you performed five years ago in 2 waves that we were talking about.
3 which you filled in the MRGO from Reach 2, just 3 Q. Now, why did you not study the wind
4 the Reach 2 portion of it, what individual 4 waves five years ago when you were doing this
5 aspects of flooding did you study? 5 study of the MRGO with Reach 2 filled in?
6 A. So what we looked at, to the best of 6 A. Well, as I think I, in our
7 my recollection -- I haven't seen the report 7 conversation about the evolution of our
8 for a long time -- was we looked at some low 8 research, computational science is a very, very
9 energy hurricanes and some high energy 9 rapidly evolving discipline. As we are able to
10 hurricanes, on a variety of tracks. 10 garner more computer horsepower, we're adding
11 Q. Did you study the surges? 11 more physics, we're adding more resolution,
12 A. Yes. 12 we're adding -- the physics is tied up with
13 Q. Can you define the surge at the time 13 processes and trying to improve the models in
14 for the low energy hurricane -- can you define 14 that way all the time. So basically as we were
15 surge for the record, please? 15 able to garner enough computational horsepower,
16 A. Surge is the water level that's 16 the next logical thing to add was the wind wave
17 attained within a hurricane event. 17 action, and that's what we've been
18 Q. How do you distinguish that from 18 concentrating on since IPET. We did it in IPET
19 waves? Or did you distinguish it from waves 19 and obviously the Office of Naval Research
20 five years ago when you did the study in which 20 study is a major move in that direction or
21 you filled in the MRGO Reach 2? 21 major push in that particular direction, as
22 A. I guess maybe perhaps it would be good 22 well.
23 to distinguish are you meaning wind waves? 23 Q. Was your focus in the study five years
24 Q. What your definition of waves are. 24 ago purely in how to model through a computer
25 And if there's a different wind wave versus 25 program the surge and wave run-up, or was it
Page 83 Page 85
1 another kind of wave -- 1 the study of wave run-up and surge?
2 A. It's all waves. The surge is a wave. 2 A. Perhaps if I may clarify that, we're
3 The tides are waves. Um -- wind waves are 3 talking about waves -- tides, that is, a very
4 waves. So they're all waves. 4 long wave.
5 Q. So did you study any one of those in 5 Q. Uh-huh.
6 your -- did you study any of the variations in 6 A. Surge is a very long wave. Wind waves
7 kinds of waves in your study five years ago in 7 are typically referred to as short waves.
8 which you filled in the MRGO Reach 2? 8 Q. Uh-huh.
9 A. Five years ago, our focus was tides 9 A. So.
10 which are waves, and storm surge which is a 10 Q. But you told me you didn't study short
11 wave, or can propagate as a wave. It's the 11 waves.
12 generation and then propagation of that wave. 12 A. Right. At that time, we did not study
13 However, they're very long waves. And at that 13 short waves. And wave run-up is associated
14 time we did not focus on wind waves, which are 14 with short waves.
15 also a very important component, obviously. 15 Q. I understand that. But the capacity
16 Q. Can you define wave run-up for the 16 and the ability to do these studies existed, so
17 record? 17 my question for you is whether or not your
18 A. Okay. That refers to the effect of 18 involvement in this study five years ago was
19 wind waves when they break against a shoreline 19 purely for the purpose of enhancing the
20 or against a structure. And in the breaking 20 computer ability to calculate these waves, or
21 process the water reaches a certain level on 21 was it for the purpose of studying the waves
22 that structure, and that's wave run-up. 22 and their impact on storms in the Greater
23 But then you also have the high period 23 Metropolitan New Orleans?
24 oscillations of the wave, or higher frequency 24 A. Which waves are you talking about, the
25 that basically moves the water level up and 25 wind waves?
22 (Pages 82 to 85)
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1 Q. Wind waves or any waves. You said you 1 Research --
2 were involved in a study of the effect of the 2 Q. Okay.
3 MRGO and the impact of the MRGO on flooding 3 A. -- project. So that was to try to, as
4 five years ago. 4 I've I think maybe -- is our reason for being,
5 A. Yes. 5 to improve the physics and our understanding of
6 Q. And part of what you did was to close 6 these processes and ultimately, at the end of
7 Reach 2 and evaluate what the impact of closing 7 the day, produce predictable -- not tuned but
8 Reach 2 would have on flooding of the -- 8 predictable water levels for these hurricanes.
9 A. Yes. 9 (Brief recess.)
10 Q. And you didn't study short-range 10 EXAMINATION BY MS. GILBERT:
11 waves -- 11 Q. I just want to back up a bit on this
12 A. Correct. 12 study that was done in -- let's say five years
13 Q. -- and your answer to me, if I'm not 13 ago. Was it 2004, roughly? Or was it five
14 mistaken, was that you were working on the 14 years before Katrina?
15 computational ability to process that in a 15 A. No, it was about -- I'd say about five
16 computer program. 16 years ago or so. You know, and again I'd have
17 A. Perhaps I should clarify. 17 to check.
18 Q. Uh-huh. 18 Q. Okay. Well, we'll just say the study
19 A. What I said was that five years ago 19 that was done five years ago, roughly in about
20 the computational capability -- 20 2004.
21 Q. Uh-huh. 21 The objective of the study was to
22 A. -- in terms of enough computer 22 study the effects of the MRGO on the impact of
23 horsepower, and the computer infrastructure to 23 flooding in the metropolitan area; is that
24 simultaneously compute on a large scale the 24 correct?
25 wind waves and the surge and the tides and the 25 A. That is correct.
Page 87 Page 89
1 riverine flow, did not yet exist. 1 Q. And what would the effects of the --
2 Q. Okay. 2 what were the effects that were being studied?
3 A. So that's why those waves were not -- 3 What potential effects were being studied?
4 those processes were not being coupled. Now, 4 A. Um -- the effect of MRGO Reach 2 on
5 certainly individually there are lots of wave 5 storm surge levels in and around Metropolitan
6 models out there that were being applied for 6 New Orleans.
7 studies for a long time. 7 Q. Five years ago, you only studied Reach
8 Q. Uh-huh. 8 2; is that correct?
9 A. But to comprehensively, within a 9 A. That was the focus, yes.
10 hurricane storm surge environment, to couple 10 Q. And did you study the -- what aspects
11 those processes on a much larger scale that's 11 of the MRGO could affect surge levels in
12 necessary within a hurricane, that capability 12 Metropolitan New Orleans?
13 did not exist anywhere in the world. 13 A. Well, it was certainly a digital
14 Q. In one computer program. 14 study. Right? It was either there or it
15 A. Well, in linking multiple computer 15 wasn't there in terms of the topography.
16 programs or whatever. But within one computer 16 And what specifically would you like
17 shell. 17 me to address?
18 Q. Okay. So the real study was in 18 Q. I just want to -- I'm trying to
19 developing a computer shell, it wasn't in 19 understand how you're studying the storm surge
20 developing a study of the MRGO and -- 20 potential and the storm effect of flooding and
21 A. No. No. No. This was a study that 21 how MRGO impacted that. So I'd like you to
22 was focused on looking at the MRGO. The other 22 maybe just -- I'm not a hydrologist and I'm not
23 studies that focused on developing that 23 a current specialist, and I'm trying to
24 capability to couple those processes came down 24 understand what variables are relevant to an
25 the road during IPET and the Office of Naval 25 analysis of studying the MRGO 's impact on
23 (Pages 86 to 89)
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Page 90 Page 92
1 flooding -- Reach 2 of the MRGO 's impact on 1 A. And we are not obviously geotechnical
2 flooding. 2 engineers, so we have never actively given
3 A. Sure. So the -- what you have to look 3 advice or information as to how to construct
4 at, of course, is -- well, first of all, in 4 levees, et cetera.
5 terms of the physical system is is it there or 5 Q. All right. And the next question that
6 not there, and we've established that -- we 6 I had there --
7 studied, compared the situation with it there 7 A. Was whether we looked at, if I
8 to not being there. And then the other thing 8 understand correctly, and correct me if I'm
9 to look at is the variety of storms. 9 wrong, if the elevations at the time of the
10 Q. Sorry? 10 design were considered?
11 A. Is to look at a variety of storms, of 11 Q. No.
12 hurricanes. So we looked at both big storms 12 (Whereupon the previous question was
13 and small storms, and on a variety of tracks, 13 read back.)
14 because all those factors come into play, 14 EXAMINATION BY MS. GILBERT:
15 obviously, what the storm surge in and around 15 Q. And when I say the manner in which the
16 New Orleans is going to be. 16 levees were constructed, I mean the height of
17 Q. Is storm surge only the level of water 17 the levees and the considerations that went
18 in New Orleans or are there other things 18 into deciding how to construct and what
19 associated with storm surge in what you're 19 level -- what height to build the levees?
20 studying? 20 A. We simply put in the elevations that
21 A. Could you run that by me again, 21 the levees were at the time into our model.
22 specifically? 22 Q. Did somebody go out and measure each
23 Q. When you're studying the impact of the 23 particular levee as it existed five years ago?
24 MRGO on storm surge and hurricane flooding, is 24 A. We basically went off the current
25 it just the height of water? 25 design charts, or current Corps of Engineers
Page 91 Page 93
1 A. At that time, we were looking 1 elevations of their levee system.
2 specifically at the hydrographs, so at the 2 Q. Do you know when those were prepared?
3 storm surge attained and what the time history 3 A. I do not.
4 of water levels were during each of the storms 4 Q. Do you know if there was any -- was
5 with and without the MRGO being there. 5 there any factor for whether it had subsided or
6 Q. Did you study the systems in place in 6 whether there was any reduction in it?
7 the vicinity around the MRGO -- Reach 2 of the 7 A. Well, in hindsight, certainly there
8 MRGO? Like the levee systems and the other 8 are some problems with that, but at the time
9 areas? 9 that was not well established.
10 A. Well, we certainly looked at storm 10 Q. So you looked at the levee heights but
11 surge levels in and around the whole hurricane 11 you didn't look at -- did you look at what was
12 protection system and how that evolved, yes. 12 considered in determining the levee heights?
13 Q. Did you look at the manner in which 13 A. No.
14 the levees were constructed and what kinds of 14 Q. Did you evaluate in any way what
15 water impact was considered at the time they 15 considerations about the introduction of water
16 constructed the levees in the vicinity of the 16 from a channel -- from the MRGO Reach 2 would
17 MRGO? 17 have on determining the height of the levee?
18 A. Did we -- 18 A. The long-term goal of our studies for
19 (Whereupon the previous question was 19 the New Orleans District were obviously to be
20 read back.) 20 able to come up with better design heights for
21 A. Okay. So I think that's two 21 their levee systems. But that process
22 questions, right? The manner in which the 22 obviously evolved and flourished during IPET
23 levels were constructed. 23 and the subsequent LACPR studies.
24 EXAMINATION BY MS. GILBERT: 24 Q. So when you're determining, you know,
25 Q. Uh-huh. 25 whether you went -- five years ago when you
24 (Pages 90 to 93)
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Page 94 Page 96
1 were doing this study on how to determine 1 MRGO did you explore other aspects of wave
2 better design heights for levee systems, what 2 impact that would affect the system, the levee
3 did you examine in determining whether or not 3 system, like run-up and short-term waves and --
4 the levee design heights were appropriate? 4 A. Yeah. I think there's three things
5 A. At the time, Congress had authorized a 5 there, right? The first thing is that our main
6 number of, quote, unquote, design storms called 6 activity definitely was to develop better
7 standard project hurricane storms, and those 7 models. But certainly there were -- the MRGO
8 storms are certainly examined -- or were being 8 study was specifically designed to understand
9 examined in order to understand the response of 9 the impact of hurricane storm surge -- of the
10 the system. 10 MRGO Reach 2 on hurricane storm surge in and
11 Q. What specific aspects of those storms 11 around the metropolitan protection system.
12 did you examine? 12 And the third thing is we at that time
13 A. What the maximum storm surge might 13 were not involved in any kind of wind wave --
14 have been during these events; however, the 14 analysis of wind wave action on the hurricane
15 main focus of our studies was to improve the 15 protection system during storm events. And I
16 computing capabilities and the modeling 16 certainly -- I presume that there were other
17 capabilities to ensure that we were moving 17 groups making an assessment of the effect of
18 forward in having improved tools in order to 18 waves in and around the protection system. In
19 then go and study what the design heights 19 fact, I'm sure of it. But.
20 should be. 20 Q. Who was the other groups you're sure
21 Q. So at the time you were not evaluating 21 of were involved?
22 whether the existence of the MRGO would have 22 A. I'm not -- I couldn't give you names,
23 impact -- was having an impact on, or could 23 but that certainly is part of the design
24 have an impact on storm-related flooding, you 24 process.
25 were examining your computational models? 25 Q. As you sit here today, are you
Page 95 Page 97
1 A. The main focus of our work for New 1 actually sure that that took place or is that
2 Orleans District was to develop better 2 something that you would have done if you were
3 capabilities. As a side bar to that particular 3 in charge of the project?
4 study, certainly there was some interest in 4 A. Um -- that the, um -- the levees would
5 determining whether MRGO Reach 2 was having an 5 have been designed with some information about
6 impact on the system which, you know, certainly 6 the waves.
7 is something that would have been of broad 7 Q. My question is not whether the levees
8 interest. 8 were designed with some information about the
9 Q. And at that time, the only manner in 9 waves, my question was in evaluating the effect
10 which you were examining -- the only aspect of 10 of MRGO Reach 2 on storm impacts and flooding,
11 the MRGO 's impact on the system that you 11 do you know whether there was somebody else --
12 examined was the height of the storm surge? 12 because you did not study the wind, the short
13 A. The time history of storm surge, i.e., 13 wind waves and flow --
14 the hydrographs, and the maximum surface 14 A. Okay.
15 elevations. 15 Q. -- do you know if there was somebody
16 Q. So the motivation for the study was -- 16 else, and if so, who were they?
17 I just want to clarify because it seemed like 17 A. On the MRGO specifically.
18 before the motivation for the study was to 18 Q. MRGO specifically.
19 evaluate the MRGO 's impact on flooding and 19 A. On the water levels on the MRGO, that
20 storm-related hazards associated with the 20 specific study did not look at waves.
21 existence of the MRGO. But it seems now that 21 Q. Do you know if there was somebody who
22 what you're saying is that your focus on this 22 did a study for the MRGO Reach 2 and the impact
23 was to improve your computational model. 23 of the MRGO Reach 2 on the storm and -- storm
24 And what I'm going to ask next is 24 hazards and flooding, did anyone other than you
25 whether or not in evaluating the impact of the 25 perform an analysis of wind generated waves in
25 (Pages 94 to 97)
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Page 98 Page 100
1 the vicinity of the MRGO? 1 were discussing earlier the work you were doing
2 A. I could not say with certainty what -- 2 with the Delft University in Holland.
3 at what level that was looked at or whether it 3 Are you using the SWAN model at all in
4 was looked at or not for that specific study. 4 your work with the Dutch?
5 Certainly, our component of the study was to 5 A. Um -- okay. There's different
6 obtain water levels. 6 versions of the SWAN model, and part of the
7 Q. If the objective of the study as a 7 push has been process-wide, right, for both the
8 whole was to determine the impact of the MRGO 8 wind wave modeling community and the storm
9 Reach 2 on hurricane-related flooding, should 9 surge/current/circulation community to build
10 it have included an analysis of -- 10 unstructured grids, and the rationale is that
11 (Brief recess.) 11 you can provide grid resolution where you need
12 (Whereupon the previous question was 12 it, where processes are changing rapidly,
13 read back.) 13 whether it's wind wave energy or whether it's
14 EXAMINATION BY MS. GILBERT: 14 currents or whether it's surface elevations.
15 Q. -- of the wind generated waves and 15 The traditional SWAN models have been
16 wave run-up in the vicinity of MRGO? 16 structured grid models, i.e., provide the same
17 A. Right. So I think there's a little 17 level of resolution everywhere, grid
18 bit of clarification needed here in terms of 18 resolution, i.e., your computational points are
19 how wind waves can impact the hurricane 19 equi-spaced pretty much everwhere. And so the
20 protection system. And on a broad scale, wind 20 project that we have with ONR is for them to
21 waves interact with the water by pushing the 21 take the SWAN model and to make it from a
22 water up further. At that time, there was no 22 structured grid model to an unstructured grid
23 modeling group that was including that 23 model. In the meantime, it's been our task to,
24 particular aspect of wind waves in the storm 24 A, provide them with the software that we've
25 surge assessment. And that only came later on 25 developed to make ADCIRC into a massively
Page 99 Page 101
1 during IPET, LACPR and also through our own 1 parallel, scalable code. And so that means
2 funding and has been, as we move forward in the 2 that you can run these codes on not ten, not
3 modeling community, an increasingly integral 3 twenty, not a hundred computational processors,
4 part to doing these studies. So there's that 4 but on let's say ten thousand, or in the near
5 aspects of it. 5 future a hundred thousand. That's going to be
6 Then the other aspect is certainly 6 very, very important in terms of computational
7 when you go into the design phase, when you 7 science perspective. So we provided them with
8 start designing levees, you have to have water 8 all our technology to do that.
9 levels in order to understand what kind of 9 The other thing that's very
10 waves can reach the levee system. So the 10 important --
11 fundamental building block to designing levees 11 Q. I'm sorry. When you say you provided
12 is to start out with still water levels, as 12 them, you provided --
13 FEMA calls them, and that is what the water 13 A. Our software, to enable them to do
14 levels would be without any waves moving back 14 that.
15 and forth on them. And that still water level 15 Q. The Dutch at Delft University.
16 can incorporate wave breaking action or not -- 16 A. That is correct.
17 and we can discuss that later if you want more 17 Q. Okay.
18 details on that -- but certainly the process of 18 A. Then the other important -- so that's
19 designing levees, actually evaluating what kind 19 for their unstructured grid version of the SWAN
20 of levees you would build in an area, would 20 model that they had developed.
21 absolutely include the design considerations 21 The other aspect of our cooperation is
22 for wave action. 22 that these models have to talk to each other as
23 (Lunch break.) 23 we progress in refining the physics of the
24 EXAMINATION BY MS. GILBERT: 24 models. So the waves really have to know about
25 Q. Just to go back for the second, you 25 what's happening on the water levels and
26 (Pages 98 to 101)
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Page 102 Page 104
1 current because waves are effected by water 1 Q. And the wind wave program that it
2 levees and currents. Obviously, if you don't 2 works tightly with is --
3 have water sitting somewhere you can't run 3 A. So the SWAN is the one, and then it
4 waves on top of it. So inundation, depth of 4 also interfaces with the STWAVE wave program.
5 water, all those things really, really matter 5 Q. And is that the program that was
6 to what the wave environment looks like. And 6 developed by the Corps?
7 so obviously they have to know what we're 7 A. That is correct.
8 doing, what the currents and surface elevation 8 Q. And we'll get back to that, I just
9 is doing. 9 wanted to clarify that for the moment.
10 On the other hand, we, as we progress 10 When we broke for lunch we were
11 in refining the ability of these models, need 11 talking about the project you had worked on in
12 to know what's happening with the waves. When 12 roughly 2004 studying the effect of the MRGO on
13 waves break they add additional stresses to the 13 flooding or enhanced flooding in the vicinity
14 water surface. If you will, it's just like you 14 of the MRGO. And I believe -- hang on.
15 running through this room and then tripping and 15 (Off the record.)
16 falling on your stomach. You're going to have 16 EXAMINATION BY MS. GILBERT:
17 a tremendous stress on you, right? You're 17 Q. You explained to me that in building
18 going to feel the carpet burn. That's the 18 the height of the levee you analyze surge and
19 stress. That's what happens when waves break; 19 wave run-up separately.
20 they transfer the momentum that they have into 20 A. No.
21 the water column and push water. And what 21 Q. Okay. Could you define for me what
22 happens when you push water? Just like wind 22 would be involved in analyzing -- building a
23 pushing water, you raise water levels. 23 levee.
24 So that's the interactivity of these 24 A. Okay, I can described in a tremendous
25 models, and in order for it to be scalable, in 25 amount of detail what we do, and that is what
Page 103 Page 105
1 order to achieve the goal of tens of thousands 1 we did do and where we are evolving to. But
2 of computational processors, they need to be 2 our goal in life is to compute water
3 very tightly coupled, and you need to design 3 elevations.
4 the interface between these models very, very 4 Q. Uh-huh.
5 cleverly, otherwise you will not have that 5 A. And whatever drives them, whether it's
6 scalability. And, um -- that's what we're 6 riverine currents, tides, winds, atmospheric
7 doing with them. 7 pressure, and now an added component, waves to
8 And then the last thing that we're 8 this -- right? Wind waves, just to be clear,
9 doing with them is testing this out on large 9 because again that can push water levels up.
10 scale hurricanes in the Gulf of Mexico. 10 So -- however, there's a whole history and an
11 Q. And when did you start doing this work 11 evolution to how you design levees, and there
12 with them? 12 are many parts to that.
13 A. About -- I'd say we started around 13 The reason we look at wave
14 three years ago in the planning phases. I'd 14 environments is to compute water levels. The
15 have to check the dates. But probably a little 15 foundation or the starting process is to define
16 bit over three years ago. Coming up on three 16 still water levels because the waves run on top
17 and a half or so. 17 of that. In the design process, the first
18 Q. And so the SWAN -- so your current 18 stepping stone to coming up with a levee design
19 programs are working with the SWAN wave 19 is the still water level. There then is an
20 programs. 20 evolution of procedures to estimate wave
21 A. Our current programs work very tightly 21 heights that go into the design. In terms of
22 with the SWAN program; however, they also work 22 what those exactly are and how those have
23 with other wave programs -- wind wave programs, 23 evolved, you'd have to ask a person that deals
24 to be very specific. Because like I said, 24 with that specifically. But the stepping
25 surge and tides are waves, as well. 25 stone, the foundation of coming up with a levee
27 (Pages 102 to 105)
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1 design, is to figure out where the still water 1 engineering tools that have been developed.
2 level is. If you don't have a still water 2 You have to understand that it's a rapidly
3 level you can't put waves on top of it. And so 3 evolving business, the sophistication and
4 that's a very, very important component to 4 detail with which you can make these
5 starting these types of analyses. 5 assessments.
6 Q. And when you're analyzing the height 6 Q. Understood. I'm with you. I'm just
7 of a levee, you want to know what the wave on 7 trying to -- I'm being much more simple than
8 top of the still water level would be. 8 you are, I'm afraid. I'm trying to understand,
9 A. Absolutely. But the foundation is the 9 in evaluating the effect of this waterway
10 still water levels. And that's the part that 10 you've got the waterway which has waves and it
11 we've been tremendously focused on over the 11 has a still water level, and you're worrying
12 last twenty years. 12 about a levee. And in evaluating a levee you
13 Q. So when the study that was done in 13 want to know what the conditions around the
14 2004 was designed -- what was the study that 14 levee are, correct?
15 was done in 2004 designed to evaluate? 15 A. Yes.
16 A. At that time, the focus on the effect 16 Q. And so if you're going to evaluate the
17 of the MRGO was the still water levels. 17 conditions around the levee with a new waterway
18 Q. What would be the effect the MRGO had 18 nearby, you would have to evaluate the effects
19 on still water levels. 19 of that MRGO on those two conditions, still
20 A. Right. And then on top of that you 20 water level and the wave on top of it.
21 would then, as a designer -- and again this is 21 A. And again, I need to emphasize that
22 not my area of expertise -- you would do a 22 the starting point of that particular analysis
23 separate assessment of what kind of wave 23 is knowing what the water levels are.
24 conditions. But if you don't know the still 24 Q. That's fine.
25 water levels you can't say anything about the 25 A. And, the techniques that would be used
Page 107 Page 109
1 wave environment. 1 to evaluate the wave environment would be a
2 Q. But in order to evaluate the effect of 2 follow-up step, but those techniques would
3 the MRGO you'd need to know both of those 3 change quite a bit over time.
4 components. 4 Q. Well, the techniques are what they
5 A. No. 5 are, and they'll change obviously by whatever
6 Q. How would you know what the effect of 6 developmental abilities that technology allows,
7 the MRGO is on waves without evaluating both of 7 but in terms of just the rudiments of analyzing
8 these -- 8 what the effect a waterway would have on
9 A. You would make an assessment of what 9 bringing water to a levee, the two things you
10 kind of waves could exist in that environment 10 need to analyze are the surge and the wave on
11 given the water levels. 11 top of the surge.
12 Q. And how would you make that 12 A. Well, and again, that's not
13 assessment? 13 necessarily entirely true if your water levels
14 A. Well, I'm not an expert in that area. 14 don't change, right? Even though -- and you've
15 Q. Would you need -- I'm just trying to 15 determined that the processes bringing water to
16 back up because -- you'd need to know what that 16 that environment don't change, then your wave
17 is -- whether you did it or somebody else did 17 conditions would likely be very similar.
18 it, if you were evaluating the MRGO 's effect, 18 Q. How could that happen; with regard to
19 you would need to know both of those things. 19 the MRGO Reach 2, for example, how could you
20 A. When designing the levees you would 20 conclude that the water levels would not
21 make an assessment of the wave environment that 21 change? Or could you?
22 would exist under the water level conditions 22 A. Well, we certainly did. Okay. So let
23 under the prevailing conditions. What the 23 me be very specific there. Our conclusion was,
24 sophistication of the tools is that you would 24 based on the storms that we looked at, which
25 do has evolved like anything else in the 25 was a variety of storms that were thought to
28 (Pages 106 to 109)
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1 impact the area, was that the MRGO was not a 1 wave on top of the still water height to
2 conduit of water -- or a major conduit of water 2 evaluate the MRGO?
3 into in and around the metropolitan New Orleans 3 A. So which study are we talking about?
4 area -- 4 Q. I'm just trying to figure out -- I
5 Q. Okay. 5 thought prior to lunch that you said that the
6 A. -- for major storms. 6 study of waves on the still water height had
7 Q. Okay. But just let me back -- it was 7 not been done until IPET.
8 a conduit; correct? 8 A. That's correct. Yes.
9 A. Well, it was a conduit for very low 9 Q. For the study of the effect of the
10 energy events, i.e., not high events. And if 10 MRGO on flooding that was done in 2004, did
11 you think about it, it was a conveyance -- when 11 somebody study the effect -- the waves on the
12 you had a very low energy, very low level of 12 surge?
13 storm surge entering the area, obviously then 13 A. Okay. Again, what we provided during
14 it is a conduit that allows additional water to 14 that study was water levels.
15 flow. But this was for very low energy storms, 15 Q. I know you did --
16 as it is in the whole drainage process. So for 16 A. If they were to have gone further into
17 example, when Lake Pontchartrain gets filled 17 the design phase of how do I build a levee,
18 up, having the additional waterway over a 18 then they certainly would have taken into
19 number of days to drain the lake would be an 19 account estimates of the wave environment that
20 additional mechanism to more quickly drain 20 would have existed in and around a levee that
21 water out of Lake Pontchartrain. 21 was being designed.
22 However, when we're talking about big 22 Q. Did they never get to that point in
23 storms which are true threats to the hurricane 23 that study?
24 protection system, they typically inundate a 24 A. That I don't know.
25 massive portion of the continental shelf, 25 Q. If they were going to evaluate the
Page 111 Page 113
1 including the Biloxi marsh, possibly the 1 effect of the MRGO on those levels they would
2 Caernarvon marsh, Lake Borgne and very shallow 2 have to determine whether or not -- it's
3 areas that are in and around the hurricane 3 just -- you know, would you have done it? If
4 protection system. Typically, the water -- the 4 you had perfect information --
5 most dangerous storms are from water that's 5 A. Okay.
6 driven from the east. So you have a massive 6 Q. -- perfect information, perfect
7 amount of inundation, and the water is 7 control over the study, you would want to know
8 predominantly being pushed from the east. So 8 both of these factors?
9 in that case you're not driving a significant 9 A. The baseline is the still water.
10 amount of additional water through MRGO Reach 10 Q. Still water height, I understand.
11 2. 11 A. So if that still water level does not
12 Q. Did you tell me earlier that the study 12 change for your most dangerous storms and your
13 of waves on the still water height had not been 13 design storms, then you, at that time, would
14 done for the analysis in 2002? It hadn't been 14 have little to -- you would have little impetus
15 done until IPET, isn't that correct? 15 to say that the wave environment is going to be
16 A. No. No. Actually, what I said is 16 dramatically different, because the wave
17 that the effect of waves on still water levels, 17 environment is heavily affected by the water
18 that that had not -- and that interactivity, 18 levels. You can't ride waves on top of -- if
19 was something that was pioneered during IPET. 19 there isn't any water. The size of those waves
20 That was one of the next logical major steps to 20 are going to be tremendously affected by the
21 improving the performance of those 21 water levels and the current environment, but
22 computational codes and the physical processes 22 predominantly the water level environment. So
23 that drive storm surge. So -- 23 if the water level environment doesn't change
24 Q. So is it your testimony, then, that 24 dramatically in and around your system, you
25 during the 2004 study there was an analysis of 25 would have little reason to believe that the
29 (Pages 110 to 113)
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1 wave action -- 1 were, the standard project hurricanes. And
2 Q. Needs to be studied. 2 that was -- certainly had evolved from the
3 A. -- is going do change dramatically. 3 previous generation of technology and what was
4 Because again, one of the most -- once you get 4 available at the time and the tools that were
5 close to the protection system, or close to an 5 available to engineers and scientists at the
6 inland environment, one of the major factors 6 time.
7 controlling the wave action, and again this is 7 Q. So after the study that you -- you
8 very peripheral knowledge for me, but is going 8 don't recall, as you sit here today, what the
9 to be the, um -- the depth of the water. And 9 track of the storm was that was analyzed to
10 you have to, again, imagine that you have waves 10 determine that there was no substantial --
11 of fifteen, perhaps twenty meters in deep 11 A. There were a variety of tracks but I
12 water -- 12 would have to look that information up.
13 Q. Uh-huh. 13 Q. Would you be able to tell me whether
14 A. -- during a hurricane. 14 any of the tracks that you studied paralleled
15 Q. Waves or surge? 15 the track of Katrina?
16 A. No, waves. Waves. Wave heights. 16 A. I would definitely have to look that
17 Q. On top of the still water level. 17 up; however, I can tell you that it was a
18 A. On top of the still water, that 18 variety of tracks and a variety of intensities.
19 obviously are attenuating as you get closer and 19 And the big factor was the intensity of the
20 closer to the coast and your water depth 20 storm, i.e., very low intensity storms which
21 decreases. That process is controlled by water 21 did not inundate a massive amount of the shelf
22 level. 22 and surrounding marshes, that the MRGO did have
23 So the point is, if your water levels 23 somewhat of an effect.
24 don't change dramatically it would not be a 24 Q. In low intensity storms --
25 high priority to go and change to do a detailed 25 A. The MRGO did have an effect in terms
Page 115 Page 117
1 study of wave action because your expectation 1 of pumping some more water into the system.
2 would certainly be that your wave heights would 2 However, high energy storms which inundate a
3 be very similar. 3 large part of the surrounding area in and
4 Q. So was the conclusion in the 2004 4 around the Metropolitan New Orleans hurricane
5 study when you did it that based on your 5 protection system, there's extremely small
6 personal analysis the still water height didn't 6 effect, if any.
7 change during hurricanes as a result of MRGO, 7 Q. So assuming for the moment that -- do
8 so they did not do a wave analysis? 8 you have -- do you recall if during the
9 A. I'm not sure whether they didn't do 9 analysis of the kind of storms that were
10 that or not. You'd have to ask them. But 10 evaluated, did they track any particular storms
11 certainly the conclusion of the study was that 11 that you can recall?
12 there was no dramatic shift in still water 12 A. I would have to look it up.
13 elevations during any of these events -- during 13 Q. And where would you -- how would you
14 the big events that you would design for. 14 get that information?
15 Q. And when you were analyzing the big 15 A. There's a report on it.
16 events, what was the track of the hurricanes 16 Q. Okay. Would the study have
17 that were the big events that were studied for? 17 appropriately considered like the track for
18 A. I'd have to look that up. At that 18 Hurricane Betsy and the track for Hurricane
19 time we were working with much less detailed 19 Ivan and Isabel to make an informed decision
20 information about the meteorology. That 20 about what the effect the MRGO had?
21 really, again, took a huge step forward during 21 A. Again, I need to emphasize that the
22 IPET. And again, what we were working with is 22 methodologies in every aspect of trying to
23 design forms, at the time, as mandated by 23 predict hurricane storm surge levels, wave
24 Congress and worked out by the National Weather 24 environment, meteorology, all this stuff
25 Service, what the quote, unquote, design storms 25 evolved --
30 (Pages 114 to 117)
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1 Q. Uh-huh? 1 answer.
2 A. -- from extremely simplistic methods 2 A. However, resolution at that time was
3 to -- from trying to solve a differential 3 probably not detailed enough to, for example,
4 equation as a one-dimensional problem using an 4 look at the details of the currents in certain
5 analytical solution, making adjustments based 5 parts of the system. We would have needed
6 on historical records, similarly so, to very 6 additional resolution.
7 sophisticated high performance computer tools. 7 EXAMINATION BY MS. GILBERT:
8 And so the evolution of what kind of storms 8 Q. Can you define flow for the record?
9 should you design for has progressed along a 9 A. Flow would typically be a broad
10 similar path. 10 description of currents. And currents can be
11 At the time, the Congress mandated 11 one of two things: They can be the depth
12 that the surge protection be up to something 12 integrated volume of flow, meters squared per
13 called the standard project hurricane, and that 13 second, for example, or feet squared per
14 has evolved and changed dramatically to a much 14 second, that you would get across the line,
15 more statistical approach to give an 15 going from the top of the water surface to the
16 understanding of what you would design for. 16 bottom, or it could also describe the
17 And that has been true across many disciplines 17 velocities in a depth averaged type situation
18 in civil engineering. For example, in riverine 18 that would be the velocity that would be
19 environments there's been a similar evolution. 19 constant from the bottom to the top, and it
20 Q. All right. Well, I guess we can -- so 20 would be the speed at which the water is going
21 is what you're trying to tell me that you would 21 at any point through the water column, or in a
22 not have been able to mirror the track, the 22 three-dimensional situation it could be any --
23 technology would not have permitted you to 23 the speed of the current and the
24 mirror the track of Ivan or Betsy in 24 directionality, of course, at any point in an
25 evaluating -- in 2004 to evaluate the still 25 X, Y, Z Cartesian grid. Or Cartesian
Page 119 Page 121
1 water heights? 1 coordinate system.
2 A. Again, I would have to look up exactly 2 Q. So when you answered my previous
3 what tracks we looked at, whether we looked at 3 question about studying flow with regard to
4 some of the historical ones or just some of the 4 the -- in the 2004 analysis of the impact of
5 standard project hurricanes or some 5 the MRGO and you answered with regard to
6 hypothetical tracks that would have been 6 current, what aspect of current were you
7 thought to do that. But a very sound based 7 responding to? Did you study flow in -- what
8 analysis, statistical analysis, as that evolved 8 aspect of flow did you study or not study?
9 during IPET, using some of the best 9 A. Well, obviously flow is a very
10 meteorologists in the country and with the 10 important part in terms of flow, whether it's
11 consensus to a set of techniques, that did not 11 velocity or a flow rate, so whether it's meters
12 exist in those days. It simply wasn't done. 12 per second or meters squared per second, is the
13 Q. Okay. Did you study the flow of the 13 mechanism that brings water from one part of
14 water during the analysis that was done in 14 the system to the other. It's important in
15 2004? 15 terms of frictional dissipation, it's important
16 A. We did not, as I recall, spend a lot 16 in terms of the advective processes, it's
17 of time looking at the currents. 17 important in terms of local acceleration, it's
18 Q. Would it have been -- would currents 18 important in terms of lateral viscous action.
19 have an impact on either still water height or 19 So every matter of the governing equations,
20 the potential for wave run-up? 20 it's a part of it. It's important in terms of
21 A. Currents, obviously, drive water to 21 the conservation of mass or conservation of
22 where it's going. 22 volume equation. So flow is a very integral
23 (Brief interruption.) 23 part of what we calculate, and certainly we're
24 MR. SMITH: 24 considering it.
25 You can go ahead and finish your 25 Did we look specifically at the
31 (Pages 118 to 121)
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1 results of the flow? And the answer is no. 1 (Brief recess.)
2 Q. And why not? 2 EXAMINATION BY MS. GILBERT:
3 A. In those days, and still today, the 3 Q. Dr. Westerink, can you explain for me,
4 dominant amount of information that we have 4 just going back, because this is -- can you
5 from measurements that we would compare models 5 explain to me what is the difference between
6 to are surface elevations, whether they're 6 wave and wave run-up?
7 hydrographs that have been measured through 7 A. Okay. So you have waves -- and again
8 whatever type of technology and tools are 8 this is not my area of specialization, it's a
9 available, so that's time history of surface 9 peripheral area that we integrate into now
10 elevations versus time, or whether it's high 10 because of my interest --
11 water marks that have been left behind after a 11 Q. Your area of expertise is better than
12 hurricane. So that was the data to compare to. 12 my area of understanding.
13 And again, this is an evolutionary 13 A. So waves is basically -- or wind
14 process. As we progress, we look deeper, 14 waves, to be specific, are the fluctuations in
15 broader, more processes, and at more data. 15 surface water that are anywhere between seconds
16 Q. Going back to my question now 16 to seven or eight, nine, ten, fifteen seconds,
17 regarding the tracks of the hurricanes that 17 and that you see these pertubations in the
18 were studied for the 2004 analysis of the 18 surface elevation of the water. These are very
19 impact of the MRGO, would it affect the still 19 much faster waves.
20 water height -- was it your conclusion, or 20 Q. Those are wind waves.
21 would the track of the hurricane affect the 21 A. Those are wind waves. And of course
22 still water height in the MRGO? 22 so if you were to stick a rod in the water and
23 A. The answer is yes. So if you move the 23 measure the surface, that rod or pressure gauge
24 track over and it's the same sized storm, in 24 or however you measured the water 's surface,
25 the eastern part of the hurricane -- east bank 25 you would see the water going up and down in
Page 123 Page 125
1 of the Mississippi River, which was the area of 1 the fifth to ten to fifteen second range.
2 interest for that particular study, obviously 2 Q. On any given day.
3 because the MRGO is located there, you'd get a 3 A. Well, obviously there has to be
4 smaller storm. And so if you have a small, low 4 something producing those wind waves.
5 energy storm surge in that part of the system 5 Q. Uh-huh.
6 for that particular storm as you move that 6 A. So there has to be wind driving those.
7 track to the west, then the MRGO, relatively, 7 Q. But it's not a hurricane.
8 would have a bigger impact. 8 A. Out -- well, it can be a hurricane, it
9 Now, does it have an impact on the 9 can be a much slower -- a much less intense
10 types of storms that you would have designed 10 storm. It can have -- they can have been
11 for? And the answer to that is no. Because 11 generated thousands of miles away. You can
12 once you get a high energy, high intensity 12 have waves in Hawaii being generated across the
13 event bringing water into that part of the 13 Pacific.
14 system, then the MRGO, because of its 14 Q. Okay.
15 proportionately less effect on the conveyance 15 A. And so -- but it's basically a
16 in the system, and because the water in that 16 transformation of energy that manifests itself
17 part of the system for the storms that matter 17 in pertubations in the water 's surface. So
18 come out of the east, it would not have had an 18 those are wind waves and what we see. And as
19 effect. 19 I've explained to you, they can have an effect
20 So the focus was to look at storms 20 on the still water level.
21 that mattered and understand the sensitivity in 21 Now, the still water level could be
22 terms of the strength of the storms that would 22 obtained by taking that signal and averaging it
23 exist in that part of the system and come to an 23 out. It could be obtained by putting a
24 understanding what the effects of the MRGO 24 stilling well, that is, essentially a big tube
25 would have on still water levels. 25 that goes down deep into the water, then
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1 looking at the water level that exists at that 1 Q. Who?
2 particular point within the stilling well, not 2 A. Harley Winer.
3 outside of the stilling well. So you would 3 Q. And what was his role?
4 then see the water surface moving up and down 4 A. He was the engineer that was doing the
5 outside the stilling well. The water surface 5 work on the Corps of Engineers side. He, I
6 would -- if go deep enough, would be fairly 6 believe, at the time, was probably also our
7 still within the stilling well. 7 project technical point of contact, or the
8 Now, other things happen and when 8 technical director of the project. And if I
9 those waves break against the structure, 9 recall correctly, he did quite a few of the
10 they'll wash up just like they do on the beach, 10 analyses, as well.
11 and the water will rush up further up the beach 11 Q. Are you familiar with Edmond Russo?
12 and up the profile, and that's wave wash. 12 A. I know him casually and, of course, in
13 Q. Wave run-up. 13 his role over LACPR.
14 A. Or wave run-up. 14 Q. Was there a team of professionals
15 Q. Now, what is the process by which a 15 involved in this study in 2004?
16 wave is regenerated? 16 A. Um -- there were a variety of
17 A. That you would have to ask a, um -- a 17 engineers from the Corps. There was a project
18 wave expert. 18 manager that was extremely interested in
19 Q. Is there like a basic formula, though, 19 advancing the technologies and the tools that
20 that would establish how much time it would 20 were being used in order to do the analysis.
21 take for a wave to regenerate under certain 21 He was very, very bent on trying to develop
22 wind conditions with the depth of the water? 22 better mechanisms for understanding the
23 A. Again, those are -- there's a 23 processes and ultimately doing the -- improving
24 tremendous body of physics and theory, and much 24 the designs. There was a external review panel
25 of this is implemented in wave models that 25 that was gathered to oversee the project that
Page 127 Page 129
1 defines that or at least the best knowledge 1 we were involved in and to provide advice and
2 that's available to define those processes, and 2 their opinion on the technology that was being
3 again that's outside of my area of expertise. 3 developed.
4 Q. Does the depth of the water have any 4 Q. Who is we, the internal guys at the
5 effect on the wave run-up? 5 Corps and you? Or was there anybody other than
6 A. It, um -- again, I'm not familiar with 6 you?
7 the run-up formula. There's a body of 7 A. The we was, at the time, I believe,
8 knowledge that covers that. You'd have to talk 8 Rick Luettich and myself and the engineers at
9 to a wave expert. Certainly, the wave 9 the Corps that were involved in developing
10 conditions that are prevalent are tremendously 10 these better tools.
11 affected by water depth, which is again one of 11 Q. Do you know what specific disciplines
12 the major factors that we're tremendously 12 these engineers, whether there was a wave
13 interested in in coupling the current/water 13 specialist in from the Corps who was
14 level models to the wind wave models. 14 participating in this?
15 Q. And in the analysis of the MRGO, the 15 A. Well, for example, on the external
16 effect of the MRGO on storm waves in 2004, 16 review panel there was Professor Robert Dean,
17 there was no analysis done of the wave on top 17 who is probably -- professor at the University
18 of the still water height? 18 of Florida, he's a member of the National
19 A. Again, I'm not sure. You'd have to go 19 Academy of Engineering, he is considered
20 back and talk to the people on the Corps side 20 probably the preeminent wave expert in the
21 that were involved in that project. 21 nation. There is Professor Robert O. Reid,
22 Q. Who did you deal with at the Corps 22 professor of Oceanography at Texas A & M
23 when you were working on your portion of that 23 University, also a member of the National
24 analysis? 24 Academy of Engineering that was part of the
25 A. Harley Winer. 25 review team. He was the Editor of Journal of
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1 Physical Oceanography for I believe fifteen 1 advancement in improving the tools to do those
2 years, although I'd have to look that up, which 2 kinds of studies.
3 is one of the preeminent journals in physical 3 Q. So the focus of the study was to
4 oceanography. Or the preeminent journal. And 4 improve the computer models.
5 there's Mark Powell who is a meteorologist at 5 A. That is correct.
6 the National Hurricane -- the Hurricane 6 Q. The focus of the study wasn't
7 Research Division of NOAA which basically is 7 specifically the MRGO, it was the method of
8 trying to develop better tools to define the 8 improving these models.
9 meteorology during a hurricane. So those were 9 A. The MRGO was a very, very small side
10 the three people that were part of our ERP. 10 study to try to understand what the role, if
11 Q. This was a 2004 study, these were the 11 any, that the MRGO Reach 2, at the time, would
12 external review panel. 12 play in the inundation levels and the still
13 A. That's correct. And by the way, 13 water levels in and around the hurricane
14 again, we should clarify that it was circa 14 protection system of Metropolitan New Orleans.
15 2004. 15 Q. And in doing that, you and
16 Q. Understood. 16 Mr. Luettich did not study wave on top of still
17 A. I'm not exactly sure what the years 17 water height.
18 were. 18 A. We did not study waves.
19 Q. With regard to the people who were 19 Q. Okay. What was the parameters of the
20 actually doing the study internally, though, 20 project that were presented to you for IPET?
21 was it just you and internal Corps engineers or 21 A. Bottom line is, find out what went
22 was there any other professional consultant 22 wrong, why it went wrong so we can fix it and
23 retained to participate in analyzing, 23 start designing, improving -- avoid this kind
24 independent from you, the effect of waves? 24 of catastrophe in the future. Those were the
25 A. By the way, sorry. I was coughing in 25 broad based parameters of IPET.
Page 131 Page 133
1 the early part of your question. Could you 1 Q. Can I just ask you, you said professor
2 repeat it? 2 Dean was involved in the IPET study or the 2004
3 Q. My question was, with regard to the 3 study?
4 study that was done -- this was external review 4 A. The circa 2004 study, he was, um --
5 panel after your work. 5 was the -- on the external review. And again,
6 A. Right. 6 the National Academy of Engineering is the
7 Q. They reviewed your work. 7 preeminent body of engineers in this country,
8 A. No. They reviewed our work during the 8 both Professors Dean and Reid were the best and
9 whole process. 9 tremendously experienced people that could be
10 Q. Who set up the -- but the people who 10 found in this area to extend advice, guidance
11 were doing the work were you and internal Corps 11 and analysis of our techniques.
12 engineers, right? 12 Q. Okay. Now, going back to the project
13 A. Luettich, myself, our students, a 13 for IPET, it was find out what went wrong, why
14 whole slough of students and several engineers 14 it went wrong?
15 from the Corps of Engineers. 15 A. That is correct.
16 Q. And all of the students that worked 16 Q. Okay. When were you first approached
17 with you would only study the current -- the 17 to do work on the IPET study?
18 actual still water heights, they were not 18 A. Um -- that's a little bit of a
19 studying waves. 19 multifaceted answer. Within a week after the
20 A. This project was designed by the 20 storm there was tremendous interest on the part
21 project manager at the Corps of Engineers to 21 of the Corps of Engineers to move while the
22 try to take a huge stepping stone to advance 22 iron was hot in improving the designs and
23 the capabilities to compute better water levels 23 raising the level of the hurricane protection
24 in and around the hurricane protection system. 24 system in and around Metropolitan New Orleans.
25 And there had been a tremendous lack of 25 There had been, traditionally and for a long
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Page 134 Page 136
1 time, huge funding concerns in terms of 1 Q. Okay.
2 obtaining funding from Congress as well as the 2 A. And that was not IPET.
3 local sponsor. The management of the Corps of 3 Q. That was just a fund-raising --
4 Engineers New Orleans District decided that the 4 A. Not a fund raising, it was a
5 best way to improve the system as fast as 5 conceptualization of how do we build a system
6 possible was to start designing for intense 6 that's truly safe, and how do we build a system
7 hurricanes and present to Congress a plan to 7 that doesn't take over thirty-five years to
8 truly improve the system instead of the 8 build under piecemeal and constantly cut
9 piecemeal and slow progress that had been made 9 budgets.
10 due to severe funding restrictions and 10 Q. What was it that was presented to you
11 limitations since Hurricane Betsy. And so we 11 as the issues that needed to be addressed in
12 began, within a week after Hurricane Katrina, 12 designing these levees or building this system?
13 to improve our grids and to start making design 13 A. By the New Orleans District?
14 runs for large hurricanes, at the time Category 14 Q. By the New Orleans District at this
15 5 and 4, in order to come up with design 15 time.
16 elevations for a protection system. 16 A. Again, under relatively limited
17 And again, we -- my understanding was 17 funding we had been working for a number of
18 that the political will would never be better 18 years to improve the modeling in and around New
19 to obtain the necessary funding to accomplish 19 Orleans, again under the funding of Al Naomi at
20 that goal. So that was my first involvement. 20 the New Orleans District, and the concept was
21 And one of their project managers came to Notre 21 let's -- this is the time to put these models
22 Dame and started defining parameters and 22 into action and to come up with the full -- the
23 scenarios that these improved designs could be 23 designs, as best we can, for how we would
24 performed by. 24 redesign the system and how high it needs to be
25 Q. Who was the project manager? 25 built so that this will never happen again.
Page 135 Page 137
1 A. Angel Mislan. 1 Q. And at this time was both still water
2 Q. And he came to Notre Dame to have you 2 heights and wave considered among the necessary
3 participate in the design of levees? 3 variables to study; when Al Naomi approached
4 A. He came to give guidance and fully 4 you, did the subject of studying still water
5 participate in this what was considered by the 5 heights plus waves come up?
6 New Orleans District as the vital component to 6 A. So, again, clarification, Al Naomi --
7 getting the necessary funding which had been 7 our studies with the New Orleans District
8 sorely missing both from the federal government 8 started some years before --
9 and of course had been missing from the local 9 Q. With Al Naomi.
10 sponsors, but likely would not be necessary 10 A. -- with Al Naomi. And then again, he
11 under the local sponsor. So that was my first 11 and others at the New Orleans District decided
12 involvement post-Katrina in the modeling work 12 it was time to push for a true Category 5
13 in order to improve the system. 13 system. After the storm.
14 Q. And do you know what -- and what were 14 Q. Okay. Just to -- for the purpose of
15 the other disciplines that were approached to 15 clarification, during the time -- prior to the
16 participate in IPET? 16 time that Angel Mislan contacted you, when you
17 A. Okay. So that was not IPET. 17 were working with Al Naomi, did there come a
18 Q. That was not IPET. 18 time when you were analyzing both the still
19 A. That was the New Orleans District 19 water heights and separately waves?
20 Corps of Engineers that was basically dedicated 20 A. So, just for clarification, again,
21 to their jobs to trying to improve the system 21 this process of developing these improved
22 and understanding that having foresight and 22 models was, A, funding the work and the
23 obtaining funds to build such a system would be 23 research, which rode on top of a lot of ERDC
24 a vital -- it was a vital time to move ahead on 24 funding as we went through this morning, to try
25 this. 25 to improve the tools. And the focus of the New
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1 Orleans District funding was to develop the, 1 a very different set of technologies that were
2 quote, unquote, models in and around here, and 2 being focused on.
3 then to validate those models. The external, 3 Q. Okay. So --
4 very preeminent external review panel was hired 4 A. That sets of technologies is still
5 to, A, ensure that these models were the state 5 different today depending on who is doing the
6 of the art, and that their reliability was the 6 analyses, what company, what federal agency is
7 best that was available -- 7 doing the analyses for the wave environment.
8 Q. Okay. 8 Q. Okay. So when you're studying,
9 A. -- so that they could then proceed 9 though, the construction of levees, the design
10 with using these tools for a new generation of 10 of levees for the New Orleans District, you
11 design. This was done, on their end, on a very 11 need to do both, study the surge and study the
12 low budget because they didn't have a lot of 12 wave, and your function has been to study the
13 money from Congress to do these kinds of 13 surge and to provide the computer technology to
14 things. 14 model the study of the surge, and somebody else
15 Q. Okay. 15 would be doing the function, or maybe with you
16 A. And the -- as you saw this morning, a 16 at this point, of studying the wave. Is that
17 lot of the funding for the basic tools came 17 correct?
18 from ERDC. ERDC is the largest center of 18 A. The wave environment is always
19 hydraulic civil-based research in this 19 considered in the design of the levees.
20 country -- 20 Q. Always considered in the design of the
21 Q. Okay. 21 levees.
22 A. -- and the center of expertise in 22 A. However, our part and the push for
23 hydrodynamic processes in the coastal ocean as 23 advancing the technologies at that point of the
24 well as in riverine systems in the United 24 available tool kit --
25 States. 25 Q. At which point are you talking?
Page 139 Page 141
1 Q. Okay. 1 A. -- at let's say circa -- you know,
2 A. So they had funded over the years 2 when we started off, and we could look this
3 many, many of the tools. The specific 3 date up in here to start to maybe put a, um --
4 application for the Metropolitan New Orleans 4 so, okay, so that would have started roughly
5 region was then funded by Al Naomi. 5 2000 or so, the projects with the New Orleans
6 Q. Okay. When Al Naomi was approaching 6 District, Number 20.
7 you and working with you prior to the time that 7 Q. Uh-huh.
8 Angel Mislan came, did he -- at what time did 8 A. Our push was to work -- the number one
9 he introduce the need to study both surge and 9 question is how high can storm surge get? And
10 wave as functions and variables of analyzing 10 I can tell you the variability in the storm
11 the proper design for levees in the New Orleans 11 surge environment is the biggest question in
12 area? 12 terms of the big question that you have to
13 A. Again, the answer to that question is 13 answer.
14 that surge and waves have always been partners 14 Would anybody, prior to Hurricane
15 in these processes, i.e., they've always been 15 Katrina, 2005, have said that you could get
16 vital components to the levee design process. 16 thirty foot of surge along the Mississippi
17 Q. Okay. 17 coast? They would tell you you were crazy.
18 A. Were we working specifically on wave 18 And there is a lot of things that were not
19 models? And the answer is no. You can ask why 19 known about these huge questions how high could
20 weren't we working on wave models? Because the 20 surge go? And so the number one focus was on
21 wave models like STWAVE and SWAN were not to 21 the carrier process, and that is the still
22 the point that you could apply them in an 22 water level. Again, the available techniques
23 unstructured environment like the ADCIRC 23 to make wave estimates certainly would have
24 model -- as was the basis of the ADCIRC model. 24 been used in any kind of design procedure.
25 So there's still a very different paradigm and 25 Q. Because no matter how high the surge
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1 get, a wave will make it higher, correct? 1 whoever else was going to be doing wave
2 A. But also depending on how high the 2 analysis.
3 surge gets will control what kind of waves can 3 A. There's a tremendous number of facets
4 ride on top of that surge. So until you have 4 downstream from the still water levels.
5 the water level right, the still water level, 5 There's the wave action, there's the -- there's
6 your estimates, or a -- if you're off on that 6 the design of the structure itself, there's the
7 significantly your estimates of what kind of 7 subsidence and soils engineering aspects.
8 wave environment can exist will be very poor. 8 There's a huge downstream set of design
9 Q. I think -- I mean, clearly the surge 9 parameters that come into play.
10 is obviously very important. But also 10 Q. But the fundamental building block of
11 determining how much on top of the wave is a 11 all of this is the characteristics of the storm
12 possibility, how much higher the wave will get, 12 surge?
13 affects how high the levee should be, correct? 13 A. That is correct.
14 A. Yes. 14 Q. Of the surge of the water.
15 Q. Okay. And when Angel Mislan came to 15 A. That is correct.
16 you about pushing to start setting up a design 16 Q. And that was your job.
17 for the levees for the New Orleans District, 17 A. That is our job.
18 was he talking about analyzing both of these 18 Q. Did there ever come a time when you
19 factors, not just the potential for analyzing 19 all sat down together and said this is Part A,
20 the surge characteristics but also the 20 tell me how you're coming. Did you ever have a
21 potential for -- maybe not through your 21 pow-wow?
22 discipline exclusively but to have somebody on 22 A. At that point we were just in go mode.
23 this team to analyze also the component of 23 And as I said, these are non trivial
24 waves? 24 calculations. We invested ourselves fully and
25 A. They would have been passing these 25 solely to this particular purpose. Everything
Page 143 Page 145
1 numbers back to design teams that would have 1 else got dropped. In fact, one of my kids even
2 considered how to -- what kind of wave 2 was excused from school for some time to be
3 environment would exist in these circumstances 3 involved in the process. He's a grid builder,
4 and taking that into consideration in their 4 a phenomenal grid builder. So.
5 designs. 5 Q. And he was involved in the process of
6 Q. Do you know who was doing that for 6 helping you build a computer generating, or
7 IPET? 7 computer system that would.
8 A. This is not IPET. 8 A. No, no, no. He's involved in the
9 Q. I'm sorry. Okay. 9 process of building the finite element grids,
10 A. This is pre IPET. 10 which is very, very, um -- very intensive
11 Q. Pre IPET. Do you know who was doing 11 manual work to place nodes to represent the
12 it at that stage? 12 physical system. So we.
13 A. I do not. 13 Q. Where was he in school at the time?
14 Q. Okay. 14 A. In high school in South Bend.
15 A. We were absolutely immersed, 18 hours 15 Q. Okay.
16 a day, for probably five, six weeks, my whole 16 (Brief recess.)
17 team, everybody in my lab was totally, totally 17 EXAMINATION BY MS. GILBERT:
18 immersed in this process to get that going, to 18 Q. Going back to IPET, when you started
19 get those numbers done. 19 the IPET project -- now we've moved out of the
20 Q. The process of determining the surge 20 New Orleans District project that you were just
21 characteristics. 21 describing -- can you describe the project or
22 A. That is correct. 22 problem parameters that were presented to you
23 Q. And it was your understanding that 23 for IPET specifically?
24 that would be passed along to somebody else, 24 A. Okay. Now, IPET was just a general
25 those numbers would ultimately be built upon by 25 description. First of all, the mission of IPET
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1 was to get to the bottom of it, what and why it 1 Louisiana? Tremendous amounts of water were
2 went wrong and also what could be done to 2 driven into Lake Pontchartrain by high water
3 prevent it. Um -- IPET was very different 3 that piled up against Mississippi. And so to
4 because, A, it was a tremendously high energy 4 get the attenuation and the processes correct
5 effort funded at an appropriate level that 5 we had to look at a large scale region.
6 could make tremendous progress, in just a wide 6 The other factor that was very
7 range of disciplines, all the way from soils 7 important was obviously proving the
8 engineering to the surface water type of 8 capabilities of the modeling tools that were
9 calculations, to waves engineering, to interior 9 then rapidly being pushed and advanced, it
10 drainage components, um -- to the geotechnical. 10 would be important to have as much data that we
11 I guess I already included that. Everybody was 11 could validate the models with as possible.
12 assembled into a set of teams that would then 12 And again, that was the logical extension into
13 comprehensively look at this whole process and 13 the state of Mississippi.
14 at this whole project. 14 Q. Okay. So the region that you studied
15 Q. And when you were approached, how many 15 was Mississippi to the southwest --
16 different sets of teams were there? 16 A. Southeastern Louisiana.
17 A. I believe there were ultimately ten 17 Q. Southeastern Louisiana. Okay.
18 teams. There was a team co-lead on the 18 How many people were on your team for
19 hydrodynamics. 19 IPET with Bruce Ebersole?
20 (Off the record.) 20 A. So this was the long wave
21 EXAMINATION BY MS. GILBERT: 21 hydrodynamics team.
22 Q. So you were co-lead with who? 22 Q. Uh-huh.
23 A. Bruce Ebersole. 23 A. And they're listed in the IPET report,
24 Q. And that was on the hydro -- I'm 24 but it probably fluctuated somewhere between
25 sorry. The long -- 25 forty and a hundred and twenty or so.
Page 147 Page 149
1 A. Long wave hydrodynamics. 1 Q. People on that team.
2 Q. Can you explain the problem that was 2 A. Yeah. I'd have to look exactly who
3 presented to you and your team to solve? 3 all was listed, but there are obviously people
4 A. So the specific problem that we were 4 that we didn't even list that were involved.
5 faced with was to define the hydrodynamic 5 Q. Okay.
6 conditions that existed during Hurricane 6 A. But it was a tremendous effort.
7 Katrina. 7 Q. And what were the disciplines that
8 Q. And was there a region that you 8 were incorporated in your team?
9 studied or how did you determine what the 9 A. Essentially we had meteorologists, we
10 boundaries of your study analysis was? 10 had wave experts -- there was a co-team looking
11 A. Again, that evolved very rapidly. 11 at -- really a simultaneous team looking at the
12 Obviously, it's a large scale regional thing, a 12 waves up against the structures that was load
13 hurricane. Ike is just the latest example of 13 by Don Resio and Bob Dean. We interfaced
14 that, a storm that makes landfall about five 14 tremendously with them.
15 hundred miles away putting eleven feet of water 15 But we, in and of ourselves, decided
16 into the IHNC. 16 that the time was right to create a close
17 Q. Okay. 17 coupling to the wave models at that point, that
18 A. So we extended our study to include 18 we could afford to do it. We had to
19 Mississippi and southeastern Louisiana, our 19 computational horsepower, the Department of
20 study region, and again this was for a number 20 Defense dedicated roughly 15 to 20 percent of
21 of reasons. First of all, we wanted to try to 21 one of their biggest supercomputers to this
22 assess the impact of the storm surge hitting 22 project, we had the monetary resources and we
23 the Mississippi coast where the largest surge 23 had the personnel to rapidly advance these
24 hit. 24 methodologies, to refine our capabilities and
25 On Louisiana. How does this affect 25 to better than ever had been defined before
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1 define the hydrodynamic circumstances during 1 limitations from Delft University. And so we
2 this major hurricane event. 2 had, in addition, a National Research Council
3 Q. Okay. You've explained that you had 3 or National Academy of Engineering review
4 wave experts on your team, meteorologists on 4 board, tremendous numbers of additional experts
5 your team specifically? 5 integrated into the whole process and giving us
6 A. And wave people, meteorologists, long 6 constant feedback and review.
7 wave circulation modelers, and then in addition 7 Q. And in IPET, what -- how did you
8 we interfaced with the many, many other teams 8 define the -- what did you do first in
9 that were involved in this process. 9 analyzing what your team was going to do?
10 Q. Not just the co -- not just the wave 10 A. Well, we already had the good fortune
11 up against levees or structures team that was 11 of having been funded to develop the, quote,
12 Resio and Dean. 12 unquote, models for southern Louisiana.
13 A. No, no, no. The interior drainage 13 Q. And that's the ADCIRC?
14 people, the soils people, um -- IPET was a 14 A. Well, that's the model -- remember the
15 truly integrated scientific and engineering 15 difference between the code and the model.
16 analysis process. 16 Q. Yeah. Uh-huh.
17 Q. Okay. And I'm trying to break it into 17 A. The code had been under development
18 something that is where your obligations were 18 for years with continual refinements and
19 and where that ended and somebody else's began. 19 capabilities being added.
20 When you were dealing with the wave 20 Q. Uh-huh.
21 experts, who was the wave expert on your team? 21 A. The models are location specific. The
22 A. Jane Smith and Don Resio. 22 metropolitan southeast New Orleans/southeastern
23 Q. Now, was that on your team or the 23 Louisiana model had been developed for a number
24 co-team that dealt with waves against 24 of years. And so we had exercised that model
25 structures? 25 extensively right after Katrina, and we had
Page 151 Page 153
1 A. No. She was on both. 1 validated it for a number of storms that we
2 Q. And whether about Don Resio? 2 felt very confident in it. We then took that
3 A. He was, of course, co-lead of the wave 3 as our starting position to start the IPET
4 team against structures but he was an integral 4 process, knowing that we were going to add
5 part of our team, as well. And again, we were 5 capabilities that would push this process along
6 all interfacing, we were all meeting once a 6 faster and quicker and that we were going to
7 week on the phone, and I think probably once to 7 add tremendous refinements. One of the big
8 twice a month we were either meeting in our 8 capabilities we decided to add right away was
9 individual teams or with all the teams. I 9 to add the effect on still water levels, i.e.,
10 forgot how many, maybe every two months there 10 wave tripping. Wave breaking.
11 was a big IPET meeting. I'd have to look up 11 Q. Can you define what that is for the
12 the schedule, but it was very, very frequent 12 record?
13 interfacing of every possible component. 13 A. Okay. As I explained, there's a dual
14 In addition, we had American Society 14 feedback mechanism between the two processes,
15 of Civil Engineers external review panel, some 15 and our interest is of course in the still
16 of the, again, best people in the world, that 16 water levels. The waves breaking adds an
17 were not already on the IPET working were 17 additional stress to the water surface that
18 involved in that. Our team had, for example, 18 pushes up water higher --
19 Professor Billy Edge from Texas A&M, we had 19 Q. So you were developing a process where
20 Professor Urann Butjes from Delft University. 20 your computations would be able to incorporate
21 Professor Batjes is one of the if not the 21 the regeneration of a wave over time, or just
22 preeminent wave expert in the world. Um -- and 22 the wave run-up?
23 one of the early developers of the SWAN model. 23 A. -- that's probably a more appropriate
24 He's truly the preeminent faculty member, and 24 question to ask the wave experts Jane Smith and
25 now retired faculty member because of age 25 Don Resio; however, certainly these wave models
39 (Pages 150 to 153)
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1 that we were then incorporating would 1 one point did take a second look at the MRGO in
2 incorporate those processes. Not the run-up. 2 order to try to get a better answer on what
3 And the reason the run-up would not be 3 might happen if you add additional
4 incorporated into these models is that they're 4 constrictions to the Reach 1 of the MRGO. So
5 still not resolved sufficiently in order to 5 we had -- under our very early look, and under
6 compute that process. However, there was -- 6 a URS Corporation 's look at the same problem
7 under the wave against structures process, and 7 for the Department of Natural Resources in the
8 you can talk to Don Resio about the details, 8 State of Louisiana, that had focused
9 there was a very concerted effort to understand 9 predominantly on Reach 1 -- on Reach 2;
10 that in more detail, and very sophisticated, 10 correction. So we then decided to look at
11 very high resolution, but very local so-called 11 Reach 1. And again, it was not the singular
12 Boussinesque models were run a Texas A & M to 12 focus of the study, but what we decided to do
13 get a more in-depth understanding of that 13 was limit the depth and increase the frictional
14 process. 14 resistance by limiting the depth in Reach 1 of
15 Q. And once you -- so the project that 15 the MRGO.
16 you worked on was to develop the models so that 16 Q. How did you go about limiting the
17 you would be able to integrate these two 17 depth in your study?
18 features. And did you reach a conclusion in 18 A. Well, you just set the bottom on a
19 IPET about the -- what went wrong with regard 19 different elevation.
20 to the vicinity of the MRGO? 20 Q. And at this time, could you modify the
21 A. Yeah, I think we did. It was an 21 Manning's N coefficient?
22 overwhelming storm. 22 A. Well, at the time of -- I mean shortly
23 Q. And how did the MRGO -- how did the 23 after Katrina, of course, Rita came along.
24 storm affect the still water height in the 24 Q. Uh-huh.
25 MRGO? 25 A. And Rita presented another huge wealth
Page 155 Page 157
1 A. How did the storm affect the still 1 of data.
2 water height in the MRGO? 2 Q. Uh-huh.
3 Q. Yes. 3 A. So simultaneous to analyzing
4 A. Is that the question? Okay. Well, 4 Katrina -- which again, the distance between
5 the still water height was controlled in the 5 areas that were inundated and open water was
6 MRGO -- during the storm was controlled by the 6 not that great, generally. Okay? Versus of
7 adjacent marshes. There's essentially no 7 course in Rita massive expanses of inland areas
8 difference between the water level in the MRGO 8 were inundated. So we were doing simultaneous
9 and the adjacent marsh. The whole area gets 9 analyses for Rita at the time for another
10 inundated by more than fifteen feet of water. 10 project, and it became apparent that certainly
11 Q. And did you analyze at all the rate at 11 the importance of the bottom friction
12 which -- or the flow of the water in the MRGO? 12 formulation in terms of achieving both maximum
13 A. Um -- what we did is we did look -- 13 inundation levels, the rate of inundation and
14 have a second look at the MRGO, and at that 14 most importantly, in terms of understanding the
15 point, with the available models -- and by the 15 correctness of the frictional formulation, the
16 way, I should back up a little bit and again 16 recession rates of various parts of the system,
17 point out that this was an evolutionary 17 the water recession rates, the withdrawal
18 process. We refined the details of the 18 rates, that we needed to switch to the Manning
19 geographic and geometric details and added 19 formulation. Now, the Manning formulation is
20 refinement to the grids because we got a huge 20 the standard in frictional formulations that
21 improvement not only in the technology as it 21 are used for, for example, riverine flood plain
22 was evolving but a huge allocation of one of 22 sites. And so we felt confident that that was
23 the biggest computers in the country. We -- so 23 a robust and physically correct formulation to
24 it was a process of continual refinement, a 24 use with quite a bit of -- quite an experience
25 spiral development that was going on. We at 25 base.
40 (Pages 154 to 157)
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1 Q. At this time could you change the 1 Q. And it's inappropriate to change that
2 Manning's coefficient within a study area? 2 number.
3 A. As the study evolved, we certainly -- 3 A. It -- certainly, based on the
4 I forgot the exact point at which we switched 4 experience base --
5 fully over, but we did build, through that 5 Q. Uh-huh.
6 process, the ability to change the Manning 6 A. -- we did not -- we would not want to
7 formulation. Could be that the final 7 change it.
8 implementation was actually just a little bit 8 Q. Okay.
9 after IPET into the LACPR study. 9 A. Now, is there --
10 Q. And when I -- I mean, just so that 10 Q. I just have another question.
11 we're on the same -- earlier you talked about a 11 Within the study at this time, you
12 different coefficient of friction that you were 12 could change -- within the capacity of your
13 using. 13 program and at the time that this study was
14 A. Correct. 14 done for IPET, could you change the coefficient
15 Q. And when you say switched over, you 15 of friction from one area to another area based
16 had switched over to Manning's, and within the 16 on the vegetation that was in different areas
17 study could you manipulate the actual number of 17 in your study region?
18 Manning's coefficients in your program? 18 A. That ability definitely evolved during
19 A. Okay. Now I should be very clear on 19 IPET. Now, whether we used that for the, those
20 this: Our purpose was to objectively define 20 runs for the final IPET report or shortly
21 frictional resistance once we started going 21 thereafter, I don't recall. But those
22 over to spatially variable formulations. And 22 capabilities were being developed.
23 that is -- specifically what that means is that 23 Q. So at the time that you started the
24 you don't change frictional coefficients to get 24 project, you could not do those variations in
25 a better answer. When you see a certain type 25 coefficient of friction.
Page 159 Page 161
1 of marsh, you assign a friction coefficient 1 A. We had, um -- never invested a lot of
2 that has an experience base for that type of 2 time or effort into looking at that. The Chezy
3 land cover. And so what we ended up doing was 3 formulation that we had been using worked very
4 taking what's called GAP data, which is data 4 well in lakes, worked well in rivers, worked
5 about the types of land cover that exist in the 5 well in the coastal ocean, worked well in the
6 states of Louisiana and Mississippi, looking at 6 oceans; however, the emphasis on IPET was of
7 the Manning N literature, assigning Manning N 7 course to look at the flooding in the coastal
8 parameters, and then looking at -- making 8 flood plain and its interaction with all those
9 correlation between the GAP data, which is 9 other water bodies.
10 30-meter by 30-meter pixels, and averaging 10 Q. Uh-huh.
11 those onto the finite element nodes in our 11 A. That process pushed us to switch
12 grids. So it was a very objective procedure, 12 frictional formulation.
13 but there was no tuning or monkeying, that had 13 Q. So when you were using the Chezy
14 an experience base, and a rich and trusted 14 formulation you could just pick a number, use
15 experience base to make these assignments. 15 that coefficient of friction because that was a
16 Q. So the actual assignment of a 16 generic type of vegetation in that vicinity?
17 coefficient of friction to a type of marsh or a 17 A. Well, most of the ocean and rivers are
18 type of vegetation was solidly established in 18 sandy. Right? So typically, the range of
19 the Manning's N. coefficient. 19 types of sandy sea are not that dramatically
20 A. That is correct. Yes. 20 different, there's a fairly narrow range of
21 Q. So you couldn't change marsh from 21 Chezys that would be appropriate for that,
22 being -- if it was marsh, it's going to have a 22 unless you have huge sand waves or very special
23 specific coefficient of friction and you're not 23 scenarios or three-dimensionality that you're
24 going to change that number. 24 not capturing, for example, flow going over a
25 A. That is correct. 25 sill and having tremendous recirculation
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1 underneath that sill or behind that sill. 1 the processes, i.e., the processes were pushing
2 That's a frictional dissipation process. Now, 2 water further inland, this became a much more
3 if you're using a two-dimensional model you 3 relevant and important issue.
4 wouldn't capture that, and you would have to 4 Q. When did the Manning's coefficients of
5 somehow represent that in the depth average 5 friction for different vegetation get
6 friction and increase the Chezy coefficient. 6 developed, do you know?
7 But generically, the Chezy formulation proved 7 A. During the IPET process. And then it
8 to be fairly reliable to the level of that our 8 was fully implement and completed during -- at
9 computations were capable to at that time 9 the beginning of the LACPR process.
10 representation of the bottom friction process. 10 Q. The development of Manning's
11 Q. And when you converted it, when you 11 coefficients?
12 started to have to study the coastal area of 12 A. Oh. The Manning N?
13 Louisiana and hurricane scenario, you 13 Q. Right.
14 determined that you needed to change that. 14 A. It's been around for probably, I don't
15 A. Maybe I should be a little bit -- 15 know, maybe 100 years.
16 provide a little bit of refinement to that. 16 Q. And what was it used for, if not this,
17 When we started studying inland flood 17 during that 100-year period?
18 plain inundation, that's when we decided that 18 A. Well, it was extensively used in
19 the Chezy formulation was not sufficient in 19 riverine and in flood plain studies. However,
20 order to characterize the frictional 20 there are many caveats in this modeling
21 dissipation throughout the whole hurricane, 21 business. What you cannot resolve we put into
22 both the inundation and recession process, in 22 coefficients. An example I gave you is the
23 order to faithfully model the physics of that 23 recirculation zone -- very dynamic
24 scenario. 24 recirculation zone over a sill. Another
25 Q. Had you never before studied the 25 example is a meandering river. If you don't do
Page 163 Page 165
1 inland flood plain? 1 a two-dimensional calculation and do a
2 A. Well, we certainly looked at in and 2 one-dimensional calculation of a flowing river,
3 around New Orleans area. 3 you'll never compute the dynamic and very
4 Q. Okay. 4 dissipative eddies. You then throw that into a
5 A. Also, I should specifically point out 5 coefficient. So there's a hierarchy of
6 that there was not a lot of reliable data 6 Manning's N coefficients which basically take
7 available for inland inundation until Katrina 7 into account anything from the actual physical
8 and Rita. These were the -- if you look at the 8 roughness of the surface, if you will, let's
9 historical high water marks from published 9 say a sand surface or a grassy surface --
10 historical gulf hurricanes, there is not a lot 10 Q. Uh-huh.
11 of data available far inland. It's mostly 11 A. -- to then putting roughness elements
12 coastal. 12 such as shrubs or perhaps some type of other
13 If you look at the reliability of the 13 vegetation onto that surface.
14 available data, it's very poor. It's typically 14 Q. Uh-huh.
15 to either ground level or to, quote, unquote, 15 A. 2-dimensionality issues such as
16 mean sea level. And God knows what that means. 16 meandering, and dissipative processes that are
17 So both the quality and quantity of data for 17 not caught by, let's say, a one-dimensional
18 inland hurricanes was not very extensive. 18 model.
19 In addition, most early hurricanes 19 Q. Okay.
20 were not nearly as large as the recent 20 A. So there's a hierarchy of
21 hurricanes we've seen; Gustav, Ike, Rita, 21 coefficients. What we used were the base
22 Katrina, very large hurricanes -- 22 coefficients for the various vegetation types.
23 Q. I understand. 23 Q. Professor, do you have an opinion on
24 A. -- pushing a lot more water much 24 the conclusions of IPET with regard to the
25 further inland. Again, so the science followed 25 effect of waves on the surge level on or around
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1 the MRGO? 1 experts ranging from people from the USGS, Army
2 A. Well, there's certainly some 2 Corps of Engineers, to -- I would have to again
3 conclusions that were drawn during and after 3 look at my records who was exactly involved in
4 IPET studies. 4 that. That was often based on conversations
5 Q. Talking about in IPET. Just in the 5 that were not face-to-face, and -- but
6 IPET report. 6 essentially the scenarios I think that
7 A. There were some -- if I recall 7 presented themselves were fairly clear in order
8 correctly, and again this is an evolving 8 to garner an understanding of how the MRGO and
9 process that never really had an ending or a 9 its development may have affected the storm
10 beginning, but I do believe we made some 10 surge elevations.
11 estimates on the still water level increases in 11 Q. You were not personally responsible
12 the IPET report due to wave action. Roughly 12 for developing the scenario parameters, were
13 the range was somewhere between 1.5 and 3 feet, 13 you?
14 i.e., if you do not include the effect of waves 14 A. No.
15 breaking and fed that into the current model 15 Q. Do you know who was specifically
16 there might be a difference of somewhere 16 responsible?
17 between one and a half and three feet. 17 A. It was, to the best of my
18 Q. Is there a distinction that you're 18 recollection, it was more of a group effort to
19 making between wave run-up and waves in that 19 start to understand the main variables involved
20 conclusion? 20 and to establish scenarios that could then,
21 A. No, I'm not talking at all about wave 21 again, develop an understanding of how the
22 run-up. 22 changes that took place in the system over the
23 Q. Was there a conclusion about wave 23 years of interest might have affected storm
24 run-up that was -- 24 surge elevations.
25 A. That would be Don Resio would be the 25 Q. Was there a point person who was
Page 167 Page 169
1 person to ask. 1 communicating information about what they
2 Q. You wrote this report, that report 2 wanted done, or was it always a form of
3 that we've had. Let's talk a little about 3 committee?
4 that. When was it that you were -- I know we 4 A. It was more of a conversation to try
5 started with this some time ago. When were you 5 to define the relevant scenarios with a variety
6 first approached to write that report in front 6 of people.
7 of you that's been marked as Exhibit -- 7 Q. Who were the people that you dealt
8 A. I'd have to -- I'm a little bit fuzzy 8 with?
9 on dates when we are really focused on 9 A. Well, on the DOJ side, certainly Robin
10 projects, but I would say, you know, circa a 10 and Jack, um -- I dealt with Bruce Ebersole,
11 year ago. But I'd have to look at my records 11 John Baras, then of course people that worked
12 in order to establish an actual date. 12 for me, both inside the university and outside
13 Q. Okay. And the project that was 13 the university.
14 presented associated with this report, what was 14 Q. Who would those people be?
15 that? 15 A. Specifically, the two people that I've
16 A. The project was to, A, assist DOJ in 16 been working very closely on my side of this
17 technical information relating to water surface 17 are John Atkinson and Hugh Roberts, both
18 elevations and/or current and hydrographs, and 18 employees of a Dutch corporation called
19 to, if needed, explore any scenarios that would 19 Arcadis, and certainly we talked to Steve
20 shed light on the influence of the MRGO on 20 Fitzgerald quite a bit in terms of making sure
21 storm surge in the Metropolitan New Orleans 21 we are on the same page for the products that
22 area, to the best of my recollection. 22 we needed, as well as to Don Resio and Jane
23 Q. Who developed the scenarios that were 23 Smith. Those, to the best of my recollection,
24 presented? 24 are the predominant interfaces.
25 A. That was really a broad-based team of 25 Q. And when you were first approached for
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1 this particular project, was it in the context 1 Q. Refinements and improvements in the
2 of this litigation or was it in the context of 2 model. Which model, specifically?
3 a study project? 3 A. Remember, there's the code and the
4 A. Again, I'm not privy to all the 4 model.
5 specific details, but my recollection or 5 Q. Uh-huh.
6 assumption would have been that it would have 6 A. The model, there is an interest in
7 been specific to this litigation. But I'm not 7 simulating the 1958 shape and form of the IHNC
8 sure. 8 between Paris Road and -- I'm sorry -- of the
9 Q. When you developed any information 9 GIWW between the IHNC and Paris Road. The
10 associated with your studies or you were 10 prevalent width of that channel was much less.
11 interested in embarking on some variation on a 11 So we had to substantially refine the IHNC,
12 study that you had started, would you contact 12 GIWW, and then later on, the entire MRGO, in
13 the DOJ or would you contact one of the 13 order to accommodate the scenarios that were of
14 colleagues Ebersole, Baras, Atkinson, Roberts, 14 interest to DOJ.
15 Arcadis or the other academic professionals? 15 Q. Have students you mentioned -- who did
16 A. Well, certainly in terms of scientific 16 you mention in addition to Arcadis? You had
17 and engineering questions we had open 17 Atkinson and Roberts. Was there anybody else
18 conversations with each other to establish 18 who worked specifically for you in developing
19 this. Our role was to provide guidance to DOJ. 19 your aspect of this project, or your particular
20 In terms of directions and specific scenarios 20 report?
21 and specific details, we certainly communicated 21 A. Um -- once in a while different
22 and obtained consensus or approval from our 22 students in my lab pitched in in order to
23 project sponsors which is DOJ. I mean, that's 23 accommodate tight deadlines, and they would do
24 any project you have to work within those 24 some gridding. Certainly one of my sons was
25 constraints. 25 involved in some of the gridding work that had
Page 171 Page 173
1 Q. And when you initially began the 1 to be done. Um -- and several of the students
2 project, what was the first aspect -- what was 2 in my lab pitched in once in a while. And
3 the first parameter that you -- where did you 3 essentially -- well, they all have assigned
4 start your analysis? How was it defined? 4 projects, but when one project needs a little
5 A. Well, certainly the starting point was 5 bit of extra help people will pitch in. So in
6 the base case and to understand that. And of 6 a very minor way they were involved, also.
7 course we'd already been working on that for a 7 Q. So for your specific report who is
8 very extensive period of time. 8 assisted in writing that document?
9 Q. That would be your H1 scenario? 9 A. Most of it was written by myself.
10 A. Right. And that's through IPET, 10 Some portions were written by Hugh Roberts and
11 through the follow-up study, LACPR, through a 11 some portions of some of the background was --
12 variety of follow-up studies for the design of 12 were extracted from other reports. But I'm
13 the major closure at Paris Road, and other MVN, 13 responsible for the whole document, and I
14 that's Mississippi Valley New Orleans District 14 edited the whole document and I wrote all the
15 Corps of Engineers, as well as HPO, Hurricane 15 specific conclusions that were relevant to
16 Protection Office of the Corps of Engineers, 16 this.
17 studies on various aspects of building a better 17 Q. The specific conclusions that were
18 and stronger system that we were involved in. 18 relevant, is that what you said?
19 So again, the model of the current day 19 A. Well, the specific scenarios and
20 situation had evolved, had improved and had 20 conclusions of what had happened for this
21 gotten better. So that was essentially the 21 particular project.
22 starting point of the analysis. However, to 22 Q. Okay. And what portion of your report
23 accommodate the interests of the DOJ, we had to 23 was -- would have been written by, or was
24 make further refinements and improvements in 24 written by Hugh Roberts?
25 the model. 25 A. Um -- essentially, that's very
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1 difficult to define because some portions of 1 MRGO affect water surface elevations, it's very
2 the report were edited, and in order to provide 2 important to understand where water was coming
3 a complete enough picture of what went into the 3 from, which direction the wind was blowing, and
4 model -- and again, the model itself was a 4 that varies tremendously in different parts of
5 results of many, many, many previous studies, 5 the system, particularly because the storm
6 as we've been talking about today, so there's a 6 passed right over the hurricane protection
7 whole history of reports that evolved, as well. 7 system.
8 Some portions of this report were in fact 8 Q. Right. And did you run these
9 extracted from those earlier reports, which 9 particular -- for all of the storm surge models
10 were again very multiple authored efforts. But 10 that are in here and the philosophy models with
11 I would say that -- you know, it's very 11 regard to H1, was that from a previous report
12 difficult to say how much of that -- I'd say 12 or did you do that specifically for this
13 50 percent of this report was extracted from 13 litigation on this particular, um --
14 previous reports in portions to essentially 14 A. Well, remember that we had to add a
15 give a good enough background to understand 15 lot of grid refinement to the grid in order to
16 what went into the model which, again, was an 16 accommodate, one, the 1958 version of the GIWW,
17 evolutionary process itself. 17 which was, remember, a lot finer --
18 Q. So when you say that -- are you 18 Q. Can I just ask -- I was asking you
19 referring to the portion of your report at the 19 about the H1 scenario, the first part.
20 beginning that describes the specific model 20 A. I think I'm trying to answer that.
21 types and aspects, that portion of your 21 Q. Okay.
22 report -- 22 A. So we actually put that in the grid.
23 A. That's correct. 23 Right? In order to ensure that the base -- as
24 Q. -- would be contributed to by other 24 well as the much finer MRGO Reach 2, in order
25 reports and other individuals. 25 to ensure that that worked well within the
Page 175 Page 177
1 A. Correct. 1 system we had to rerun Katrina on that
2 Q. And the portion of the report that 2 particular grid.
3 starts with H1, for example, and starts to 3 Q. What were the previous studies that
4 analyze the impact of -- the effects of the 4 you used, that you drew upon initially for H1?
5 variables of the hurricane, that was all 5 A. Okay. So start the evolution? MVN.
6 written by you? 6 Then, um -- later on IPET. Later on, um --
7 A. That was written by me. 7 LACPR. Later on a whole host of HPO and MVN
8 Q. Now, in the portion of your report 8 funded studies where we kept on making
9 that dealt with analyzing the H1 scenario, 9 continual refinement and improvements in the
10 which is -- which was a large chunk of your 10 geometric and physical representation of the
11 analysis from the scenario section -- 11 system. Then on top of that, we built a much
12 A. Uh-huh. 12 finer version of the IHNC, of the GIWW/MRGO
13 Q. -- does that portion of your report 13 Reach 1, and of MRGO Reach 2. For obvious
14 come from previous analytical -- 14 reasons they were the focus of this study, and
15 A. That portion is an edited version of 15 a high level of mesh refinement was deemed
16 previous reports, however, somewhat modified to 16 very, very beneficial to trying to understand
17 give more clarity where it might be relevant 17 the hydrodynamics through those channels.
18 for this particular report. And again that was 18 Q. Is there a way that you can isolate
19 originally written by me and then evolved 19 for me the portions of this report that
20 through various reports, and then came here 20 predated the initiation of this particular
21 again since I think it is an important part of 21 report and the portions of this report that
22 developing an understanding of how the storm 22 were generated specifically for this purpose?
23 surge evolved in this particular system. 23 A. Well, certainly the generic
24 Because if we're trying to draw conclusions as 24 description of the models, the generic
25 to how does a particular structure like the 25 description of the grid, obviously slightly
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Page 178 Page 180
1 modified since we had a higher resolution 1 models, the GAP data. GAP is an extremely
2 version of the MRGO/GIWW, IHNC, the generic 2 comprehensive set of land use types, actually
3 description of H1 in Katrina itself. Bottom 3 more ecosystems, I should -- it's an
4 line is, the code worked the way it was 4 ecological-based land classification, and has
5 supposed to and things didn't change that much. 5 many, many different types of marsh and of land
6 Or hardly at all. And so those sections were 6 covers in it, or habitats, I should say. We
7 essentially -- didn't change, so it was 7 had -- during the IPET, LACPR, and of course I
8 certainly not a worthwhile endeavor to rewrite 8 should mention the FEMA IDS study, as well, we
9 those from scratch because the information had 9 had -- or FEMA DFRIM, really, we had
10 not changed. However, I think to have it in a 10 established, based on literature, correlations
11 package to help develop a full understanding of 11 between the GAP land use types as well as the,
12 the processes, of the parameters, I thought it 12 um -- as the Manning's Ns. We then received
13 was very beneficial to put that in. Obviously, 13 from John Baras, I believe, the 1956 recreation
14 there's a lot of sections that I reference in a 14 of the system, and that had a little bit
15 much more comprehensive FEMA IDS study, which 15 different classifications. So we then, using
16 was really concurrent to LACPR, for more 16 the GAP classifications, transferred those over
17 details, but I tried to put in enough 17 to the classifications that were given to us
18 information that one could develop an 18 based on the 1956 and earlier.
19 understanding of how the model worked, where 19 Q. Okay. And that was done -- the 1956
20 the data came from and what the history of the 20 stuff was done for this report. And was there
21 model was. 21 any Manning's N coefficient given to the land
22 Q. When you developed the scenarios that 22 area from a previous study at any time?
23 dealt with the configurations of the land in 23 A. No. We used the -- even though the
24 1956, was that newly developed for this study? 24 1956 classifications weren't as comprehensive
25 A. Um -- the information about the land 25 and slightly different, we could use the
Page 179 Page 181
1 utilization was provided to us by -- as 1 knowledge we had developed for the GAP
2 guidance from the both USGS people as well as I 2 classifications and transfer it over.
3 believe their ecosystem specialist from ERDC. 3 Q. Okay. I guess my question, though, is
4 Q. And was that provided to you 4 for the picture that you had, and for
5 specifically for this particular report? 5 processing the coefficient of friction, was
6 A. Well, certainly, the interest was in 6 that done with the -- from a previous study and
7 establishing what the ecosystem looked like 7 incorporated into this study with regard to the
8 from 1956. We're absolutely not experts in 8 2005 wetlands in the vicinity?
9 that. Obviously, we rely on tremendous number 9 A. Well, we had to cross-correlate
10 of other disciplines for our current day models 10 between the land cover types from the 1956 map
11 as well as establishing a model that would have 11 and the land cover types that we had
12 represented a system at an earlier time, which 12 established from the GAP maps.
13 of course is of general interest to us in 13 And by the way, the GAP maps are also
14 hindcasting earlier storms despite the fact 14 slightly different between Mississippi and
15 that the data is very sparse as well as the 15 Louisiana.
16 information about the wind fields is relatively 16 Q. Sure.
17 poor. But we still have an interest in that. 17 A. They're local studies that really
18 Q. And with regard to the inputting of 18 concentrates on the habitats for animals.
19 the Manning's coefficient in this report, was 19 They're a habitat study for the specific
20 that from a previously generated report -- 20 states. And I believe that the local U.S.
21 whether it's for the 2005 wetlands or for the 21 Geological Survey and the biologists and
22 wetlands as it was presumed to be in 1956, was 22 ecologists are very heavily involved in that
23 that for this report or was that from some 23 process.
24 other previous -- 24 Obviously New York has different
25 A. Okay, so we used, for the currents day 25 habitats and land covers and marshes and
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1 ecosystems than we have in Louisiana or 1 wasn't quite as dense, but certainly within --
2 Mississippi. So we basically took the 2 you could identify what the correlation would
3 information that we had for the GAP Louisiana 3 be.
4 study that we had established the relationship 4 Q. Uh-huh.
5 between the Manning N and the land cover types 5 A. I forgot the exact classifications,
6 for the GAP, and then applied those to the less 6 but for example there might be saline, brackish
7 dense, i.e., not as many line classifications 7 and freshwater marsh in the GAP data, and there
8 that we had for the 1956 data. 8 might be just saline and fresh in the 1956
9 Q. And that you did for this 9 data.
10 particular -- for this report? 10 Q. Understood.
11 A. We did. 11 A. So we had to make some -- brackish
12 Q. And my question is whether or not you 12 being somewhere between fresh and salt. So we
13 had a previous analysis that you had done at 13 had to make some adjustments and say, well, we
14 any time where you applied a Manning's 14 don't know exactly what this is, we'll take
15 coefficient to your application of this MRGO 15 something in between.
16 area from another report that you incorporated 16 Q. Okay.
17 into this report. 17 A. And so the basis of it, of the
18 A. Well, certainly we used the GAP 18 selections that we made, were the GAP Manning
19 Manning N data that we had established based on 19 N -- the GAP classification to Manning N tables
20 the hydraulic literature, and then we used that 20 that we had established and used for many, many
21 as a basis for establishing the 1956 land cover 21 previous studies.
22 to Manning N table. 22 Q. Okay. And then you applied them for
23 Q. Uh-huh. 23 the first time for this report.
24 A. Which by the way I should say is 24 A. Then we adjusted them to fit the land
25 incorrect in this report. It is a clerical 25 classifications that were associated with the
Page 183 Page 185
1 error on my part that that table is incorrect 1 USGS 1956 data, and that is what we applied.
2 and does not reflect the actual Manning Ns that 2 So certainly the basis of what we selected had
3 were used for the various line cover types. 3 a very firm footing in our previous studies.
4 But I could certainly provide a correction to 4 Were they exactly the same? Obviously not
5 that. 5 because the land classifications were not the
6 Q. Okay. Well, we'll ask for that when 6 same.
7 we get to that section. But just out of -- so 7 Q. Uh-huh. Okay.
8 there was no analysis that was -- I'm really 8 (Off the record.)
9 just trying to figure out whether the entire 9 EXAMINATION BY MS. GILBERT:
10 body of this report was generated -- with 10 Q. On an aside, post-Katrina do you know
11 regard to the Manning's N analysis was 11 why they designed the closure at Paris Road --
12 generated for this report or whether or not you 12 the major closure at Paris Road?
13 had a previous report that did an analysis of 13 A. Sure.
14 applying -- an analysis applying Manning's N 14 Q. Okay. Share.
15 coefficient that you borrowed to incorporate 15 A. Excuse me?
16 into this. 16 Q. Please share.
17 A. Okay. So the answer is that we had 17 A. Okay. Of course. Again, there's a
18 the GAP data to Manning N tables -- 18 major evolution in improvement in defining the
19 Q. Uh-huh. 19 statistical characteristics of the storms that
20 A. -- very well, we had exercised those 20 would be used in design water levels. And
21 extensively, they were based on the hydraulic 21 they're for levee systems. And very vulnerable
22 literature -- 22 areas, ultimately, are the areas that face
23 Q. Uh-huh. 23 eastward along the whole -- so looking to the
24 A. -- and we had the 1956 land use data. 24 east --
25 The land use data was not exactly the same, it 25 Q. Uh-huh.
47 (Pages 182 to 185)
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1 A. -- along the whole east side of the 1 So you're generating a lot of surge.
2 river. That includes English Turn, 2 The most vulnerable areas in around New Orleans
3 Braithwaite, it includes the Golden Triangle, 3 being English Turn and the Golden Triangle. So
4 it includes the -- the sparsely populated area 4 your 100-year storm levels are significantly
5 between, um -- Rigolets and Chef Menteur. And 5 higher there. So now, you look at the most
6 it also includes, of course, the Mississippi 6 vulnerable part of the system, or the area part
7 coast. Essentially, what you have is a delta 7 of the system that due to physical reasons and
8 that extends out onto a very broad shelf. The 8 the tracks and character of the hurricanes
9 broader the shelf and the shallower the shelf 9 generates the most hurricane storm surge, and
10 the more storm surge you can generate with wind 10 you certainly have to protect that part of the
11 forces. 11 system.
12 Q. The broader the shelf and the 12 Q. Well --
13 shallower the shelf, the more storm surge. 13 A. So building the closure is a logical
14 Okay. 14 answer to that answer. Instead of doing the
15 A. Particularly when you stop the flow. 15 absolutely very, very costly thing of raising
16 So if you have a broad shelf that runs 16 the levees along entire Chalmette and the
17 east/west and you're blowing hurricane winds on 17 Citrus back and New Orleans back levees, then
18 it, you blow a lot of water around when the 18 the entire IHNC, it's a much more cost
19 winds are coming from the east. 19 effective and safe solution to put closures in
20 Q. Shallow water? 20 at Paris Road.
21 A. Shallow water. And the shallower the 21 Q. But why at Paris Road? What about
22 water the more effective wind stress is in 22 Paris Road provides that protection?
23 pushing up water. On an east/west coast, 23 A. Well, I, um -- this is where I go over
24 however, it's predominantly the southerly winds 24 to conjecture. Obviously, you could do many,
25 that tend to produce storm surge because the 25 many things to provide that protection, but
Page 187 Page 189
1 southerly winds push the water instead of 1 somewhere you need to build a barrier that
2 east/west they push the water up against the 2 faces to the east that stops the surge from
3 land. And if look at a storm like Rita, that's 3 entering the system. Do you redesign the whole
4 essentially what happened. 4 system? For example, do you change the New
5 On the other hand, you now put a 5 Orleans East and St. Bernard polder? You would
6 protrusion, a giant protrusion onto that 6 have to ask the designers and the politicians
7 continental shelf, and you really start 7 why that's on or off the table. But certainly
8 collecting water from those easterly winds. So 8 given the existing system, given the cost of
9 on an east/west coast with no protrusions 9 lengths of levees that one might build, given
10 you're generating storm surge from the east. 10 the foundation engineering that's required to
11 Going to -- I mean you're generating currents 11 build levee systems in this area and the soil
12 from the east to the west, you're only 12 conditions in the region, I would assume, and
13 generating storm surge with the southerly 13 again this is me as a sideline observer making
14 winds. The problem on the east bank of the 14 the assumption that the cost effectiveness and
15 Mississippi River, and many -- and New Orleans 15 the level of protection that you could provide
16 East and St. Bernard, Chalmette, and of course 16 at that location would be optimal compared to
17 even extending into interior New Orleans, is 17 all the other design choices.
18 that you are exposing the massive potential of 18 Again, I'm not a designer of levees,
19 those very long-lasting -- relative to the 19 I'm only a guy that levee designers look to to
20 southerly winds, very long-lasting easterly 20 provide them water levels, and we look towards
21 winds to drive water up on that continental 21 the designs and what they consider the feasible
22 shelf and to produce, as we have seen in many 22 alignments that they can work with to providing
23 storms now, massive storm surge to the east of 23 them water level data.
24 the river. And so the whole area east of the 24 (Brief recess.)
25 river is tremendously vulnerable. 25 EXAMINATION BY MS. GILBERT:
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1 Q. You mentioned earlier that there were 1 years when there's a lot of missing physics.
2 some typographical errors in your report in the 2 We'd rather see the physics evolve and make
3 Manning's N coefficient chart. 3 sure that we have the best science in the model
4 A. Correct. 4 and to then establish reliability limits by
5 Q. Is there anything else in any other 5 comparing the data. And if you tune a model
6 areas of your report or any other places in 6 you can match the data perfectly but you will
7 your report that there are typos or other 7 no longer have a good judgment of how well the
8 errors that we can look at or focus on that 8 underlying physics works.
9 you've identified? 9 Q. Okay.
10 A. I'm 100 percent certain that there's 10 A. So in order to, for example, pass our
11 other typos in my report. 11 water levels to the interior drainage models,
12 Q. Of substance. Typographical errors of 12 adjustments were made upward in order to get a
13 substance. 13 more exact -- improve the precision based on
14 A. I would say the only one I've found of 14 our knowledge of the water levels that were
15 substance is the -- 15 measured of the water going into the interior
16 Q. The Manning's N? 16 systems.
17 A. The Manning Ns. There's minor caption 17 Q. Okay. An so in essence, if your
18 errors that I found after submitting the report 18 numbers are correct everyone else 's numbers
19 that probably should be corrected, as well, 19 flow, and if your numbers are incorrect
20 but -- 20 everyone else 's numbers are affected and all
21 Q. But nothing that would adversely 21 the rest of the experts are adversely affected
22 affect the ability to understand your report? 22 by inaccuracies in your surge numbers.
23 A. Absolutely not. I mean, I think 23 A. That would be a correct
24 the -- 24 characterization; however, some steps were
25 Q. Not for you, I meant for me. Somebody 25 taken to refine the accuracy of our
Page 191 Page 193
1 who is not you. 1 calculations before passing them down to the --
2 A. No. The conclusions are very solid, 2 for example, Steve Fitzgerald and the interior
3 the methodologies are very solid and have a 3 drainage models.
4 tremendous basis and track record on them of 4 Q. So before your numbers were passed --
5 peer review, and so, there's -- again, this 5 whatever numbers you passed on, though, if
6 whole process of the code and the models has 6 those numbers are incorrect everybody else is
7 evolved over the years under a tremendous 7 off, but you've made efforts to correct -- to
8 amount of scrutiny, for obvious reasons, due to 8 calibrate or remedy any error, right?
9 the importance of what ends up getting built 9 A. Not calibrate, because we don't
10 with these models. 10 calibrate. Calibrate is adjusting parameters
11 Q. Okay. Now, in the process of reaching 11 to try to get a better match between the data.
12 the conclusions that the experts in this case 12 Our process involves making the simulations
13 for government have presented, is your report 13 based on the best physics that we can, by
14 the backbone of all the other reports? 14 making assignments, for example, of Manning N
15 A. Our water levels are used as a basis 15 that are objective, not subjective --
16 for the other work. So for example, the wave 16 Q. Uh-huh.
17 work is certainly riding on top of our water 17 A. -- and then to run the calculations.
18 levels. And our water levels are certainly 18 However, when passing that information to an
19 used for the interior drainage. However, there 19 interior drainage model, if you can improve the
20 have been corrective adjustments made to try to 20 precision by making slight adjustments, if you
21 match the measured water levels a little bit 21 have measured hydrographs or measured high
22 better. As I perhaps have alluded to in a 22 water marks, than you would improve the
23 couple of points, in our modeling work we 23 precision of the interior drainage model once
24 really don't like to, quote, unquote, tune 24 you make that transfer.
25 models. This was a prevalent practice for many 25 Q. So whatever number, though, that is
49 (Pages 190 to 193)
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Page 194 Page 196
1 transferred is -- if that number is accurate, 1 plain.
2 then everybody else will flow, but they will 2 Q. So was SO8 limited to Chezy
3 not change those numbers and they will build on 3 coefficients or would use Manning's N?
4 whatever numbers you gave them, hopefully. 4 A. Well, certainly conceptually it
5 A. They build on the numbers with the 5 wouldn't have been limited to it. And you can
6 exception of that Bruce Ebersole made some 6 run the SO8 model through the new codes and
7 adjustments to the hydrographs that were along 7 prepare some extra information and run the,
8 the St. Bernard polder levees to ensure -- to 8 um -- the Manning Ns if you so desire.
9 further refine their accuracy. 9 Q. Okay.
10 Q. Okay. Now, can you -- I tried to look 10 A. I.e., all these models can be run
11 online and fine the ADCIRC SL15 versus the 11 through any versions of the codes that are
12 ADCIRC SO8. Can you describe for me what the 12 available. But in the SO8, the way we used it,
13 differences are between SO8 and SL15? 13 we didn't; we only used the Chezy coefficient.
14 A. Yes. Sure. So again, SO8 is 14 Q. The way you used it. But anyone who
15 probably, I'm going to say, five years old, 15 wanted to use it today could change it in that
16 roughly. 16 way.
17 Q. Okay. 17 A. Sure. If they wanted to.
18 A. And it's described in the Monthly 18 Q. Okay.
19 Weather Review paper, and it is roughly 320,000 19 A. But they'd still have poor resolution
20 nodes or something like that. So it did not 20 and they would -- also, they could not run it
21 have a variable Manning N, it did not include 21 with waves. That model simply does not have
22 wave action, and the storms that we simulated 22 the resolution to interface correctly with
23 with it did not probably have as good a winds 23 waves.
24 as we had the luxury of having for Katrina and 24 Q. Okay.
25 Rita. 25 A. The grid resolution.
Page 195 Page 197
1 Q. In SL15. 1 Q. Now, just to go back, you had
2 A. In SO8. 2 mentioned that you had types in the Manning's N
3 Q. The ones that you had in Katrina were 3 coefficients. And can you just tell me what
4 from SL15. 4 the tip graphical errors are in the Manning's N
5 A. Were used with the SL15 model. 5 coefficients?
6 Q. And SL15 had what? What was different 6 A. I assume I may reference my report
7 about the SL15? 7 here.
8 A. Well, SL15 in various renditions has 8 Q. Pleas do. Which is has been marked as
9 probably somewhere between 2.2 and 2.6 million 9 Exhibit 1.
10 computational points. 10 A. Okay. So the first category, fresh
11 Q. Those are nodes. 11 marsh, looks like it's correct, it's .055.
12 A. Nodes. Right. 12 Then we have non fresh marsh, the second one,
13 Q. Okay. 13 and you look at what we have, and you say it's
14 A. So we went up an order of magnitude in 14 intermediate marsh, brackish marsh, saline
15 the magnitude of resolution. We have more 15 marsh -- well, it's kind of hard to tell, but
16 processes. We have a much tighter interface 16 we selected intermediate, something that was
17 between the wave breaking process and the wave 17 more akin to brackish, and saline marsh, and I
18 processes than we did -- which we simply did 18 would have to double-check what number we used
19 not have in SO8. But resolution, resolution, 19 for that.
20 resolution is the key thing that we have in 20 Forest is obviously wrong. Right?
21 SL15, much more of it. 21 Type 7. And that should be more in the range
22 And then the other thing is that we 22 of, you know, something like .14. And again, I
23 have made a lot of progress and a lot of 23 can pull up the code that was used to set these
24 refinements in using Manning N as opposed to 24 land use types.
25 using the Chezy coefficients on the flood 25 Swamp is obviously wrong; that's .035.
50 (Pages 194 to 197)
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1 And if you look at the maps we use more 1 Q. One second. What page is it on?
2 something like .06. 2 A. 101.
3 And agriculture and pasture looks like 3 Q. 101?
4 it got the forest type somehow. And so that 4 A. Yes.
5 should be much larger, more in the 0.035 range. 5 Q. Okay. One moment. Got you. I'm with
6 Developed looks like it's correct. 6 you.
7 Although again, I'd have to check exactly what 7 A. Okay. So now you look right adjacent
8 value we used. But certainly in the right 8 to the 40 arpent levee, and to the interior of
9 range. 9 the Chalmette levee and the Chalmette Extension
10 And then water looks like it's in the 10 levee.
11 right range. 11 Q. When you say interior, is that going
12 Q. How can you check what the correct 12 to the west or toward the east?
13 code that you used was? 13 A. That's going to the west. So go to
14 A. Well, we have a pre-processing code 14 the west of the Chalmette levee. And go to the
15 that looks at the pixels in the land use maps, 15 east of the 40 arpent levee, and you can see
16 either the GAP maps or the maps provided, and 16 that aquamarine color.
17 they're in pixelated data. And so we used a 17 Q. Yeah.
18 piece of code to then correspond to various 18 A. And that's about .06.
19 pixelated colors in the way they're coded to 19 Q. Okay.
20 come up with the Manning N. So it's a very 20 A. And you go to Baras 's figure, which
21 definitive procedure to establish what we 21 is on Figure 55 on Page 120, and then you can
22 actually used. And then of course you can go 22 see that essentially the swamp land type, and I
23 back and look at the grids and see what values 23 assume the adjacent intermediate marsh, are
24 we actually have in the grids, and that are 24 roughly at .06, .055, somewhere in that range.
25 reflected in the plots that are in this report. 25 Q. Okay.
Page 199 Page 201
1 Q. So would it be tied to the color maps 1 A. In order to get the exact evaluation
2 that were in one of the other experts' reports 2 of what -- how the nodes have been assigned,
3 Britsch or Baras? 3 you'd have to go into the files that are
4 A. Yes. 4 associated with the computational grid and you
5 Q. So the coding -- my question is, the 5 could exactly see what happens. But it's
6 coding, the pixelated coding would be tied to 6 somewhere in that range.
7 the maps of the Britsch or Baras. Is that how 7 Q. Okay. So that's how you do it. All
8 it would be done? 8 right. So you'll provide for us the codes that
9 A. Baras, yeah. So it's this Figure 55 9 were actually used.
10 on Page 120 is -- the colors are picked off of 10 A. Yeah.
11 those pictures in pixelated maps and then they 11 Q. Now, with regard to the wind studies
12 are then assigned a Manning N. And those are 12 that were done for the purposes of this report,
13 reflected in the many figures that are in the 13 your report describes H*Wind. Can you define
14 beginning of the report. 14 what H*Wind is?
15 Q. And do you have a key that would tell 15 A. Okay. Again, I'm not a meteorologist.
16 you what color was given what Manning's N? 16 I work with meteorologists and we are downwind
17 A. Well, that's in the code. 17 from them in terms of what we use, but
18 Q. Oh, okay. Can you provide that? 18 obviously it goes without saying that it's a
19 A. Absolutely. 19 very vital product to our hurricane storm surge
20 Q. Okay. Now, you said that you clearly 20 modeling. H*Wind is the state-of-the-art data
21 could tell that swamp was given .06 or 21 simulative model for taking meteorological data
22 something closer to .06. 22 that occurs, that's measured during a
23 A. Well, if you look at -- let's see an 23 hurricane, and assimilates it into a time and
24 example here. We'd have to look at H3. And 24 space interpolated wind field. And so what
25 let's say you look at Figure 20, or Figure 21. 25 they do is use land-based radar, airborne
51 (Pages 198 to 201)
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Page 202 Page 204
1 radar, they use dropsondes, anemometers, 1 that, so the worse your representation of an
2 there's a host of tools again that I'm only a 2 historical hurricane becomes.
3 periphery user of, or a very interested user 3 Also, as is obvious, hurricanes are a
4 in. You would have to speak to the experts in 4 very infrequent event, relatively speaking, for
5 terms of what all they use and what techniques 5 a specific section of coast. So you have to
6 they use. Mark Powell is the developer of the 6 have a mechanism for generating synthetic
7 H*Wind product. As far as I'm concerned, it is 7 hurricanes. The PBL model is such a mechanism
8 the world's premier product in establishing 8 or such a tool. It is based on the
9 what the wind fields look like in and around 9 establishment of a parametric atmospheric
10 the core of a hurricane. And that's it. 10 pressure field based on the -- what's called
11 Q. Now, at one point in your report you 11 the Holland Pressure Field Model, that is a
12 referred to PBL. What is PBL? 12 model that generates what the atmospheric
13 A. Okay. So I should add one more piece 13 pressure field, given the size of a hurricane
14 of information. There is also winds away from 14 and the pressure deficit at the eye of a
15 the core. These are provided by OWI, Ocean 15 hurricane, what it might have looked like. It
16 Weather, Inc. And they actually blend, for the 16 then moves on to solve a system of conservation
17 most part, the winds in from the H*Wind 17 momentum equations, also interestingly enough
18 product, which is familiar the Hurricane 18 called the shallow water equations. They're
19 Research Division and Mark Powell, into 19 very similar equations, in fact, to what we use
20 simulated wind fields and further data 20 in the ocean, except air is the fluid instead
21 simulative procedures that they use, then 21 of water. And they also make -- those
22 taking measurements and making adjustments so 22 equations make the depth average assumption.
23 that again you have a space and time 23 It solves those equations for velocities given
24 interpolated wind field. 24 the atmospheric pressure field. Once the
25 H*Wind product is not specifically 25 atmospheric pressure field has been
Page 203 Page 205
1 geared towards the exterior portion of the 1 established, the model then looks at what the
2 hurricane. Their meteorologists are very 2 bottom roughness looks like in the wave field,
3 interested in the center portion of a 3 in the, at the water 's surface, given the
4 hurricane. However, for a hurricane storm 4 speed of the winds, and actually computes the
5 surge model, it's vital to know what the 5 atmospheric boundary layer to establish a
6 external winds are because the expanse of the 6 10-meter wind speed, 10 meters above the water
7 winds are as important to us as the intensity, 7 surface or the land surface. So that's where
8 as Hurricanes like Ike make very, very clear. 8 PBL, it stands for Planetary Boundary Layer,
9 So it's a two-step process. 9 comes from.
10 Q. Okay. 10 Q. So in the process you use both H*Wind
11 A. These two groups -- and I think it 11 and PBL?
12 would be -- in the scientific community there's 12 A. We use H*Wind/OWI winds for historical
13 wide agreement that these two groups produce 13 events, and then we use the planetary boundary
14 the best hurricane winds that have ever been 14 layer model which is a model that's established
15 assembled to simulate what the winds were like 15 by Ocean Weather, Inc., that has been written
16 during a hurricane event. 16 by them and maintained by them --
17 Q. Okay. Go on. 17 Q. Uh-huh.
18 A. I guess the PBL -- you want me to 18 A. -- to come up with synthetic hurricane
19 answer the PBL. So obviously, in design you 19 winds in order to establish a wind field for
20 don't have a sufficient data set to come up 20 synthetic hurricanes. Obviously, that model
21 with wind fields. There's a very, very limited 21 has also been extensively vetted and looked at
22 data set of hurricanes. The further you go 22 how well it can do. It does a pretty good job.
23 back the sparser the network of data collection 23 It does not do a perfect job. The data
24 points, the worse the instrumentation that was 24 assimilated winds are better. However, when
25 available to try to understand that and measure 25 you're running a host of hurricanes for design
52 (Pages 202 to 205)
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1 study, the models -- the consensus is the model 1 Cardone and Mark Powell --
2 does a good enough job to -- even though it 2 Q. Mark Powell.
3 cannot perfectly simulate the very complicated 3 A. -- on that specific topic. They are
4 structures that occur during a hurricane in the 4 the -- they're the world experts in this area.
5 wind fields, it does a very good job at 5 I -- we certainly have looked at correlating
6 simulating a whole sequence of hurricanes so 6 peak winds and wind time histories at buoys, et
7 that the basic statistics of a hurricane storm 7 cetera, and I would be extremely surprised if
8 surge are correct. 8 there's a 20 percent overestimate on the wind.
9 Q. Is there any documentation or data 9 In fact, I would be shocked.
10 that suggests that H*Wind overestimates wind by 10 Q. Okay.
11 about 20 percent? 11 A. So I can pretty much guarantee you
12 A. Okay. There's a lot of knowhow that 12 there is no 20-minute --
13 goes into wind fields. Um -- wind fields -- 13 Q. 20 percent.
14 what the wind is depends on many things. For 14 A. -- 20 percent overestimate.
15 example, the wind is measured typically 15 Q. On the maximum.
16 measured and used in order to drive wave and 16 A. On the winds.
17 surge models at 10 meters above the surface 17 Q. Okay.
18 level of the water. So if you take a level 18 A. So I suspect there's -- if anybody
19 that's much higher than that, then that would 19 thinks that, there's probably a confusion as to
20 be quite a different wind speed. 20 what averaging period they're using to
21 Then in addition, there's the 21 establish that fact.
22 averaging period. If you take a wind record 22 Q. Okay. Now, just to go back to the
23 and you average over one minute that wind 23 ADCIRC SO8 and SL15 for a moment, when you were
24 record, you will get what are called peak wind 24 running -- were you running SL15 when you were
25 speeds. If you then average over ten minutes, 25 doing the computations for this report?
Page 207 Page 209
1 you will get a lower number. If you average it 1 A. We were using one of the SL15 models.
2 over 30 minutes, you'll get a lower number as 2 And as I said, SL15 covers a range of models
3 well. So the various models are driven by 3 with the continuously evolving set of
4 different averaging periods that are 4 refinements.
5 appropriate for the model. For example, we 5 Q. Okay. The one --
6 drive our hurricane storm surge model with 6 A. No massive changes, but continual
7 10-minute average winds. Why? The dominant 7 refinements. The concept again being, unless
8 data sets that were used to establish the 8 we're doing an apples to apples study where
9 air-sea drag coefficient that models how much 9 we're trying to compare very specific small
10 momentum is transferred from the wind into the 10 changes, we progress, and as we get more data,
11 water column are based on data that was 11 as we get more knowledge of the system, we put
12 averaged at 10-minute -- at a 10-minute 12 the physical refinements that the grid better
13 averaging period. Other models might use a 13 represent the physical system in and move
14 30-minute. 14 forward with that.
15 Q. Uh-huh. 15 And as I mentioned, one of them is
16 A. So. 16 refinement of the MRGO and the IHNC and GIWW in
17 Q. So just relating back to the 17 terms of the level of grid resolution. We
18 stipulation in the data paperwork on H*Wind 18 certainly will move forward in our modeling
19 that the winds -- H*Wind overestimates the wind 19 efforts with all those refinements.
20 by 20 percent, how does that affect the 20 Q. Did you include the levee heights in
21 calculations that are derived from it? 21 that grid resolution refinement?
22 A. Well, you know, um -- I seriously 22 A. Now, there are a variety of levee
23 doubt that H*Wind overestimates the winds at 23 heights that we might use. Certainly, there's
24 the core by 20 percent, but if you -- the 24 the historical levee heights, for hindcasts, so
25 appropriate people to talk to would be Vince 25 that overtopping can occur in our modeling.
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1 There are the design heights for the 2010 1 WITNESS' CERTIFICATE
2 system. There are LACPR design heights. So 2
3 there is a variety of levee heights that we 3 I, JOANNES J. WESTERINK, Ph.D., do
4 might use on simulations. 4 hereby certify that the foregoing testimony was
5 Q. Which did you use for this? 5 given by me, and that the transcription of said
6 A. The historical heights. 6 testimony, with corrections and/or changes, if
7 Q. The historical heights from the 7 any, is true and correct as given by me on the
8 original designs? 8 aforementioned date.
9 A. The historical heights as they were 9
10 established based on measurements and dense 1 10 ______________ _________________________
11 foot by 1 foot lidar data that were provided to 11 DATE SIGNED JOANNES J. WESTERINK, Ph.D.
12 us by Bruce Ebersole. 12
13 Q. When were -- just to go back, the 13 _______ Signed with corrections as noted.
14 historical heights that were established based 14
15 on -- who did the measurements? Or when were 15 _______ Signed with no corrections noted.
16 those measurements done? 16
17 A. You'd have to -- to ensure accuracy on 17
18 this you'd have to talk to Bruce Ebersole, but 18
19 I believe that the Corps ran -- and again, this 19
20 is to the best of my recollection, I'm not the 20
21 geodetic person or the person that establishes 21
22 these heights, we depend on he data upstream of 22
23 us. But I believe the 1 foot by 1 foot 23
24 high-density measurements of the HPS were taken 24
25 prior to Katrina. That data was used. And 25 DATE TAKEN: January 27th, 2009
Page 211 Page 213
1 then there were also surveys that were used to 1 REPORTER'S CERTIFICATE
2 establish those levels. And both sets of 2 I, JOSEPH A. FAIRBANKS, JR., CCR, RPR,
3 course were adjusted to the new vertical datum 3 Certified Court Reporter in and for the State
4 that we use, and that is the NAVD88(2004.65). 4 of Louisiana, do hereby certify that the
5 Q. Who did the actual surveys, do you 5 aforementioned witness, after having been first
6 know? 6 duly sworn by me to testify to the truth, did
7 A. Well, I assume that MVN did, but again 7 testify as hereinabove set forth;
8 you'd have the check with MVN and Bruce 8 That said deposition was taken by me
9 Ebersole to get the exact sources. 9 in computer shorthand and thereafter
10 Q. And those figures were given to you 10 transcribed under my supervision, and is a true
11 and you incorporated them into the -- 11 and correct transcription to the best of my
12 A. Those numbers were given to us and we 12 ability and understanding.
13 incorporated them. Correct. 13 I further certify that I am not of
14 Q. Okay. For now, I think we can 14 counsel, nor related to counsel or the parties
15 probably cut it for today and then start 15 hereto, and am in no way interested in the
16 getting into some more detail tomorrow. 16 result of said cause.
17 17
18 18
19 19
20 20
21 21
22 22
23 23 ____________________________________
24 24 JOSEPH A. FAIRBANKS, JR., CCR, RPR
25 25 CERTIFIED COURT REPORTER #75005
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category 134:14 cetera 11:7 33:10 198:7,12 211:8 199:20 27:11 41:7 43:1,2
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caught 165:17 75:13 92:4 208:7 Chef 186:5 cleverly 103:5 52:1 101:2 111:22
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CCR 1:24 6:22 change 17:15 25:25 162:6,7,19 195:25 149:16 199:5,6,6

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coefficient 78:25 64:12 99:3 100:8 201:4 115:4,11 122:20 135:5 137:2
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80:22 158:18,24 209:9 20:3 106:24 107:22,23 constrictions 156:4
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colleague 16:12 192:5 24:15 27:4,6 189:12 91:16,23 92:16
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combined 14:21 34:19 43:16 52:5 computes 66:17,20 confluence 80:13 71:20 137:16
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committee 169:3 29:19,21,22,24 conceptually 196:4 143:4 contribution 26:21
communicated 84:8,15 86:15,20 concerned 202:7 considerations 45:12
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WESTERINK (VOL I), JOANNES

IN RE: KATRINA CANAL BREACHES CIVIL ACTION

Johns Pendleton Court Reporters 800 562-1285

53 (Pages 206 to 209)

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Johns Pendleton Court Reporters 800 562-1285

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Johns Pendleton Court Reporters 800 562-1285

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Johns Pendleton Court Reporters 800 562-1285

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Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

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Johns Pendleton Court Reporters 800 562-1285

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Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

simulative 201:21 100:24 101:13 southeastern 163:5 168:15 211:15

Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

surges 82:11 176:5,7 177:1,11 167:25 202:5 209:17 203:11 211:14

Johns Pendleton Court Reporters 800 562-1285

45:23 50:24 53:18 129:10 130:8 transformation 147:21 156:2 200:22

Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

120:15,20,21 105:20 106:7,23 124:7,13,14,19,20 181:8 187:14,20,21

Johns Pendleton Court Reporters 800 562-1285

103:19 115:19,22 201:10 $674,450 29:5 184:8 185:1 121:4 122:18

Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

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