KTR00156

POWELL (VOL I), NANCY
10/3/2008
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)
Rule 30(b)(6) deposition of THE UNITED
STATES OF AMERICA, BY AND THROUGH THE UNITED
STATES ARMY CORPS OF ENGINEERS' DESIGNEE NANCY
POWELL, given at the U.S. Army Corps of
Engineers New Orleans District offices, 7400
Leake Avenue, New Orleans, Louisiana
70118-3651, on October 3rd, 2008.
REPORTED BY:
JOSEPH A. FAIRBANKS, JR., CCR, RPR
CERTIFIED COURT REPORTER #75005
Johns Pendleton Court Reporters 800 562-1285

10/3/2008
Page 2 Page 4
1 REPRESENTING THE PLAINTIFFS: 1 EXAMINATION INDEX
2 BRUNO & BRUNO 2
3 (BY: JOSEPH M. BRUNO, ESQUIRE) 3 EXAMINATION BY: PAGE
4 (BY: FLORIAN BUCHLER, ESQUIRE) 4
5 855 Baronne Street 5 MR. BRUNO .................................6
6 New Orleans, Louisiana 70113 6 EXHIBIT INDEX
7 504-525-1335 7
8 - AND - 8 EXHIBIT NO. PAGE
9 THE GILBERT FIRM, LLC 9 Exhibit 25 ................................28
10 (BY: ELISA T. GILBERT, ESQUIRE) 10 Exhibit 26 ................................29
11 (BY: BRENDAN R. O'BRIEN, ESQUIRE) 11 Exhibit 27 ................................34
12 325 E. 57th Street 12 Exhibit 28 ................................42
13 New York, N.Y. 10022 13 Exhibit 29 ................................44
14 212-286-8503 14 Exhibit 30 ................................66
15 - AND - 15 Exhibit 31 ................................82
16 ELWOOD C. STEVENS, JR., APLC 16 Exhibit 32 ................................84
17 (BY: ELWOOD C. STEVENS, JR., ESQUIRE) 17 Exhibit 33 ................................85
18 1205 Victor II Boulevard 18 Exhibit 34 ................................85
19 Morgan City, Louisiana 70380 19 Exhibit 35 ................................86
20 - AND - 20 Exhibit 36 ................................86
21 MCKERNAN LAW FIRM 21
22 (BY: ASHLEY E. PHILEN, ESQUIRE) 22
23 8710 Jefferson Highway 23
24 Baton Rouge, Louisiana 70809 24
25 225-926-1234 25
Page 3 Page 5
1 REPRESENTING THE UNITED STATES OF AMERICA: 1 STIPULATION
2 UNITED STATES DEPARTMENT OF JUSTICE, 2 IT IS STIPULATED AND AGREED by and
3 TORTS BRANCH, CIVIL DIVISION 3 among counsel for the parties hereto that the
4 (BY: ROBIN SMITH, ESQUIRE) 4 deposition of the aforementioned witness may be
5 (BY: JACK WOODCOCK, ESQUIRE) 5 taken for all purposes permitted within the
6 (BY: MICHELE GREIF, ESQUIRE) 6 Federal Rules of Civil Procedure, in accordance
7 P.O. Box 888 7 with law, pursuant to notice;
8 Benjamin Franklin Station 8 That all formalities, save reading
9 Washington, D.C. 20044 9 and signing of the original transcript by the
10 202-616-4289 10 deponent, are hereby specifically waived;
11 11 That all objections, save those as to
12 REPRESENTING THE U.S. ARMY CORPS OF ENGINEERS. 12 the form of the question and the responsiveness
13 CORPS OF ENGINEERS, OFFICE OF COUNSEL 13 of the answer, are reserved until such time as
14 (BY: DAVID DYER, ESQUIRE) 14 this deposition, or any part thereof, is used
15 7400 Leake Avenue 15 or sought to be used in evidence.
16 New Orleans, Louisiana 70118-3651 16
17 504-862-2843 17
18 18 * * *
19 ALSO PRESENT: 19
20 NICOLE BOYER, ESQ. 20
21 CHARLES SUTTON, ESQ. 21
22 JOHN BALHOFF, ESQ. 22 JOSEPH A. FAIRBANKS, JR., CCR, RPR,
23 TIANA CHRISTOPHER, ESQ. 23 Certified Court Reporter in and for the State
24 VIA I-DEP: DEBRA CLAYMAN, ESQ. 24 of Louisiana, officiated in administering the
25 VIDEOGRAPHER: GILLEY DELORIMIER (DEPO-VUE) 25 oath to the witness.
2 (Pages 2 to 5)
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Page 6 Page 8
1 MR. BRUNO: 1 evaluations by the Corps regarding the alleged
2 This is a continuation of the 2 potential for the MRGO to serve as a conduit
3 30(b)(6) deposition. 3 and/or funnel for hurricane-generated surge.
4 Counsel, would you kindly 4 What did you review, if anything, for that?
5 introduce today's designee and the 5 A. Um -- just revisited some of the IPET
6 paragraphs for which she has been 6 work.
7 designated. 7 Q. Okay. Number 34, all scientific
8 MR. SMITH: 8 research and studies relative to the effects of
9 Our designee today is, seated 9 wetlands and/or swamp on hurricane-generated
10 beside me, Nancy Powell. And she is 10 waves. What did you do to prepare for.
11 designated for Topics 10, 8, 34, 35, 11 A. I reviewed a presentation that I made
12 40, 14, 15 and 16. 12 to Plaquemines Parish that described some
13 MR. BRUNO: 13 ongoing LACPR work, and also the interim report
14 Thank you, counsel. 14 that was put out in the I believe the 1950s or
15 NANCY JEANNE POWELL 15 60s -- I'm not sure of the date -- that talked
16 3412 Massachusetts Avenue, Kenner, Louisiana 16 about Morgan City hurricane protection.
17 70065, a witness named in the above 17 Q. This was a design memo?
18 stipulation, having been first duly sworn, was 18 A. I'm stretching as to the name of the
19 examined and testified on her oath as follows: 19 report.
20 EXAMINATION BY MR. BRUNO: 20 Q. Not the House document. Something
21 Q. Nice to see you again, Ms. Powell. 21 else?
22 We've met, of course, previously. But this is 22 A. No, not the House document. It's
23 a little bit different. You are now designated 23 something else.
24 by the Corps to respond to certain questions on 24 Q. All right. When was the presentation
25 behalf of the Corps, which allows you to go 25 made to the I guess the Plaquemines Parish
Page 7 Page 9
1 beyond your personal knowledge. You understand 1 council?
2 that? 2 A. It was the President, Plaquemines
3 A. Yes. 3 Parish, some of his councilmen, some of their
4 Q. Okay. All right. And Robin has just 4 consultants. It was done early this year.
5 gone through the paragraphs, and if you don't 5 2007.
6 my I'd like to just run through them again very 6 Q. Okay. '07. All right.
7 quickly and see what you did to prepare. 7 Do you mind if we have a copy? Do you
8 Number 10 is the evaluations by the 8 have a copy of the slide presentation?
9 Corps regarding storm surges within the MRGO, 9 A. Yeah. I can get to that for you.
10 Lake Borgne, Lake Pontchartrain, the IHNC, the 10 Q. I would appreciate that. Number 35 is
11 GIWW and their relationship to the design, 11 all scientific research and studies relative to
12 construction, operation and maintenance of part 12 the effects of hurricane generated surge,
13 or parts of the MRGO individually or 13 current or waves on earthen levees. What if
14 collectively. Okay? What if anything did you 14 anything did you do to prepare to speak to that
15 do in order to prepare yourself to speak on 15 issue?
16 behalf of the Corps on those subjects? 16 A. Nothing specific, per se, but the
17 A. I reviewed the what I call the NESCO 17 ongoing work that my office is doing that I'm
18 report, which is Bretschneider 's report on the 18 responsible for in reviewing deals with those
19 MRGO surge study. 19 types of issues.
20 Q. Okay. Anything else? 20 Q. Okay. Number 40 are measures,
21 A. For that question, no. 21 actions, analyses, studies and/or reports
22 Q. Okay. Did you speak to anybody, 22 commenced and/or undertaken by the Army Corps
23 interview anybody? 23 concerning a change in hydrology associated
24 A. No. 24 with and/or caused by the digging or dredging
25 Q. Okay. All right. The next one is 25 of the MRGO. Any documents specific to that
3 (Pages 6 to 9)
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Page 10 Page 12
1 topic? 1 you also relying on the conclusions in the IPET
2 A. Okay. There was a document that was 2 report to support your testimony today?
3 put together -- and here again, I'm sorry, the 3 A. The data that's contained in the
4 name escapes me. It was a document that was 4 report.
5 looking at the effects of the construction of 5 Q. All right. Do you have any opinion
6 MRGO as well as the barrier plan, the original 6 about the conclusions in the IPET report on any
7 barrier plan that was part of Lake 7 subject?
8 Pontchartrain and vicinity project, looking at 8 MR. SMITH:
9 how those two features would alter salinity in 9 Joe, she's not here to testify
10 Lake Pontchartrain. 10 about her opinions about that.
11 Q. Okay. Could you just show it to us? 11 MR. BRUNO:
12 I'm sure we have it, I just don't know how to 12 Well, she's relying on them.
13 reference it. If you don't know its title. 13 MR. SMITH:
14 A. We'd have to stop. I can go get it. 14 Just ask her the questions in the
15 Q. No, no. We'll do it at a break. 15 designated topic areas, and I'll
16 A. Okay. Good. 16 object if they're outside. She's not
17 Q. But I mean, I won't be able to ask you 17 going to answer that question.
18 about it if I don't have a better description 18 EXAMINATION BY MR. BRUNO:
19 of it and I don't expect you to have memorized 19 Q. All right. So I gather from your
20 the title. So if you could get that for me. 20 response that none of the conclusions in this
21 It's in your office? 21 IPET report form the basis of any of your
22 A. Yes. 22 testimony today. Right?
23 Q. Number 15 are the facts, data or other 23 A. I guess you would have to define
24 information when combined with the design 24 conclusions. I've confined my review for this
25 criteria utilized that resulted in the design 25 deposition to the review of the chapters that
Page 11 Page 13
1 for the MRGO Reach 2 GIWW/MRGO Reach 1 and IHNC 1 talked about the design assumptions and
2 federal flood control structures. What if 2 analysis that was performed to design the
3 anything did you do to prepare for that? 3 levees. I did not review any of the
4 A. Again, the -- most of that information 4 conclusions section of that report.
5 is contained in the IPET report, the section 5 Q. Okay. Well, that's a very good point.
6 that I helped prepare. 6 And perhaps we should explore that a tad
7 Q. Finally, the information and knowledge 7 because I need understand what the government
8 regarding any changes in the factual 8 perceives to be conclusion versus what are some
9 assumptions utilized to develop the standard 9 of the factual recitations. There are a number
10 project hurricane and/or the probable maximum 10 of factual recitations regarding what occurred
11 hurricane that may have occurred over time as a 11 in the past in this IPET report, aren't there?
12 result of the construction of the MRGO or the 12 A. I have not read the whole report.
13 loss and/or destruction of the marsh, swamp, 13 Q. All right. Well, let's talk about as
14 trees and brush in the vicinity of the MRGO. 14 it relates specifically to the design of the
15 A. Can I see that one? 15 levees. There are paragraphs in here which
16 Q. Yeah. Why don't you read it. 16 describe what occurred; isn't that true?
17 A. It's a little bit long. I didn't 17 A. I have not read the whole report.
18 necessarily review any information for this 18 There are paragraphs that I have reviewed for
19 topic, per se, I'm just aware of the 19 this deposition, and I can show you
20 assumptions that went into the standard project 20 specifically what I reviewed.
21 hurricane. 21 Q. Why don't you do that, then.
22 Q. Okay. All right. Now to the extent 22 A. It's going to not be in that volume.
23 that you relied on or consulted with the IPET 23 Q. This is the executive summary. I
24 report, I need to understand, are you relying 24 brought this. Maybe you can give me --
25 on the data contained in the IPET report or are 25 A. It's going to be the other volume.
4 (Pages 10 to 13)
10/3/2008
Page 14 Page 16
1 Q. Well, doesn't the executive summary at 1 description of the design and the design
2 least give you a description of all the 2 parameters.
3 volumes? It's just easier than hauling all the 3 Q. Exactly. And you took those to be
4 paper in here. 4 accurate, right?
5 A. Right. But the description of the 5 A. Yes.
6 design and assumptions that were made in the 6 Q. Okay. I mean, did you find any fault
7 design vis-a-vis the surge and the waves, most 7 with the IPET description of what occurred in
8 if not all of that information is contained in 8 connection with the design?
9 a different volume than what's in the executive 9 MR. SMITH:
10 summary. 10 Objection. This is beyond the
11 Q. I understand, but this will help me 11 topics she's designated to address.
12 get to that volume. This is just an index, 12 MR. BRUNO:
13 that's all it is. 13 No, it's not. You want to call
14 MR. SMITH: 14 the Judge?
15 Tell him what volume it is. 15 MR. SMITH:
16 That's all he needs to know. 16 Which topic --
17 MR. BRUNO: 17 MR. BRUNO:
18 We need more than that, but we'll 18 No. Let's call the Judge. I'm
19 start with the volume. 19 not doing this all day.
20 A. It's Volume 3. 20 MR. SMITH:
21 EXAMINATION BY MR. BRUNO: 21 Which topic does this relate to?
22 Q. Is there a subtitle or something? 22 MR. BRUNO:
23 THE WITNESS: 23 I'll tell you specifically which
24 You don't have Volume 3. 24 topic this relates to. It's Number
25 MR. SMITH: 25 15. Okay? There it is. Number 15.
Page 15 Page 17
1 No. This isn't a document 1 She said she used the IPET. All I
2 production deposition either. 2 want to know is whether or not the
3 A. Having not reviewed this volume, I'm 3 information contained in the IPET upon
4 not aware of where in it I need to look to find 4 which she relied she believes is
5 the same information. 5 accurate or not. This is no big
6 MR. SMITH: 6 teeth.
7 That's fine. 7 MR. SMITH:
8 A. So -- 8 I know what you're trying to do,
9 MR. SMITH: 9 Joe.
10 That's fine. You've given him 10 MR. BRUNO:
11 the answer to his question. 11 I'm not trying to do anything.
12 A. Volume 3, Page 112, it just says this 12 MR. SMITH:
13 volume provides a detailed description of the 13 It has nothing to do with this
14 hurricane protection system. The character of 14 deposition. It has to do with the one
15 the system starting with the definition of 15 you want to do next week.
16 hazard defined by SPH, translated -- 16 MR. BRUNO:
17 translation of the SPH into authorized level 17 I will do the one next week.
18 protections, the general methods and 18 Okay? This is this topic. Okay? All
19 assumptions of the design of the flood walls. 19 I want to know is -- and I'm even
20 (Indicating.) 20 asking the witness to make the
21 Q. Right. And those aren't conclusions, 21 distinction between conclusions and
22 are they? Those would be more of a factual 22 factual recitations. I'm not playing
23 recitation of what occurred. That's all I'm 23 any games. You are, though.
24 trying to get at. Right? 24 EXAMINATION BY MR. BRUNO:
25 A. The information I reviewed was a 25 Q. My goodness, he thinks I'm trying to
5 (Pages 14 to 17)
10/3/2008
Page 18 Page 20
1 get you to comment on the conclusions reached 1 defining the future hurricane hazard to New
2 about the breaching of the levees. I'm not. 2 Orleans and vicinity? Was that part of your
3 How about that, in fairness to you and to 3 contribution to Volume III?
4 Robin? I'm not going there. All I want to 4 A. My contribution to Volume III
5 know is, this thing contains a ton of 5 consisted of reviewing the existing documents
6 information about what happened in the past, 6 and preparing summaries of the work that was
7 and I'm just trying to learn, since you're here 7 performed from a hydraulic perspective
8 designated to talk about what happened in the 8 vis-a-vis the design of the system. So in
9 past, not conclusions, all right, it's to why 9 context of that and what you said, I'd have to
10 those levees failed or performed or whatever, 10 say no because I didn't look at -- you talked
11 let's leave that off the table, but I do want 11 about future?
12 to know whether or not the descriptions of what 12 Q. Right. In other words, in order to
13 occurred in the past you find to be accurate as 13 build the levee there had to be some assessment
14 they relate to topics that you've been 14 of the hurricanes to come. Isn't that the way
15 designated to the talk about. 15 it was done?
16 MR. BRUNO: 16 A. There was an assessment that was made
17 That's it, Robin. And that's not 17 as to the design storm.
18 beyond the scope of this deposition 18 Q. Right. And the design storm was what?
19 and shouldn't cause you any pain. 19 As you understand it?
20 EXAMINATION BY MR. BRUNO: 20 A. The standard project hurricane for the
21 Q. Now can I get an answer? 21 Lake Pontchartrain and vicinity system.
22 MR. SMITH: 22 Q. Right. And is that a future event or
23 What's the question? 23 a past event?
24 MR. BRUNO: 24 A. That is a synthetic event.
25 Read it back. 25 Q. Exactly. But it's a synthetic event
Page 19 Page 21
1 (Whereupon the previous question was 1 which is designed to describe what, something
2 read back.) 2 that happened in the past or something that
3 EXAMINATION BY MR. BRUNO: 3 might happen in the future?
4 Q. That's the question, Ms. Powell. 4 A. It is a synthetic event that describes
5 MR. SMITH: 5 the design hurricane.
6 Object to form. 6 Q. Okay.
7 MR. BRUNO: 7 A. It may never happen, it may be
8 You may now answer the question. 8 exceeded, it may not be exceeded. So in your
9 MR. SMITH: 9 context I can't answer your question.
10 If you understand the question. 10 Q. Well, it's certainly not designed to
11 A. Within the context of the section that 11 deal with something that happened in the past
12 I helped to prepare, then my understanding of 12 because that's already gone, right? I mean,
13 the question is yes, I believe that small 13 we're trying to deal with a future event when
14 section is factual. 14 we build any protective structure, aren't we?
15 EXAMINATION BY MR. BRUNO: 15 A. We build a structure that's
16 Q. Thank you. And that's small section 16 authorized.
17 is contained -- 17 Q. Of course.
18 A. In Volume III. 18 A. And the authorization was the standard
19 Q. -- in Volume III. I didn't have the 19 project hurricane.
20 chance to look at this. Do they have some 20 Q. But what are we protecting from,
21 subsections? Do you recall the title? 21 something that happened in the past or
22 (Off the record.) 22 something that might happen in the future? Can
23 EXAMINATION BY MR. BRUNO: 23 you answer?
24 Q. Did you participate at all in drafting 24 A. In your context, it's very difficult
25 anything that described the methodology for 25 to answer because what you can have in the
6 (Pages 18 to 21)
10/3/2008
Page 22 Page 24
1 future can exceed the design hurricane or it 1 MR. BRUNO:
2 cannot exceed the design hurricane. 2 No, I want this question
3 Q. Right. 3 answered. And if we're not going to
4 A. So you are not designing for a system 4 get an answer --
5 that will protect for any future condition. 5 MR. SMITH:
6 Q. Right. 6 She answered that question.
7 A. So in that context, it's very 7 MR. BRUNO:
8 difficult to answer your question. 8 Look, fine. Stop. Let's call
9 Q. I didn't say any. I said something. 9 Magistrate Wilkinson. I'm not going
10 You said any. 10 to do this all day. This is not going
11 MR. SMITH: 11 to happen.
12 There's no question pending. 12 MR. SMITH:
13 EXAMINATION BY MR. BRUNO: 13 Do what you want to do, Joe.
14 Q. The question on the table regards 14 MR. BRUNO:
15 something in the future. I'll let you define 15 Off the record.
16 what the something is, but it's something that 16 (Whereupon Magistrate Wilkinson was
17 hasn't yet occurred. Isn't that true? 17 consulted via telephone.)
18 MR. SMITH: 18 THE COURT:
19 Don't argue with witness, Joe. 19 Read the last question.
20 MR. BRUNO: 20 (Whereupon the previous question was
21 I'm not arguing with the witness, 21 read back.)
22 Robin. 22 THE COURT:
23 MR. SMITH: 23 I'm not going to referee this
24 Ask a question then. 24 deposition question by question, so
25 MR. BRUNO: 25 I'm going to instruct you to ask
Page 23 Page 25
1 I have a question. 1 questions, and I'm going to instruct
2 MR. SMITH: 2 the witness to answer them to the best
3 That's not a question. 3 of her ability. If there's some
4 MR. BRUNO: 4 problem with, you know, an argument
5 That is a question. 5 take some witness has been designated
6 MR. SMITH: 6 who didn't have sufficient knowledge
7 No, you're arguing with the 7 or some other argument, you can file
8 witness. 8 it by motion later on. All right?
9 MR. BRUNO: 9 But this sort of arguing I thought was
10 I'm not arguing with the witness. 10 beneath what you two guys were capable
11 MR. SMITH: 11 of. So continue with the deposition,
12 Ask a question. 12 ask questions, and get answers from
13 MR. BRUNO: 13 the witness.
14 I already have. And I'd like an 14 MR. BRUNO:
15 answer. 15 Okay, Judge. Thank you very
16 MR. SMITH: 16 much.
17 Asked and answered. 17 THE COURT:
18 MR. BRUNO: 18 Good-bye.
19 No, it wasn't answered. The 19 MR. BRUNO:
20 witness changed the use of the words. 20 Back on. Let's see if we can get
21 I didn't say any, I said some. She 21 an answer. I would like the name of
22 changed my question to something else. 22 the document that she reviewed so we
23 And that's inappropriate. 23 can go get it. Do you mind if she
24 MR. SMITH: 24 goes and gets the document so that she
25 If you have another question -- 25 can give me the name right now, or
7 (Pages 22 to 25)
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Page 26 Page 28
1 would you like me to file a motion? 1 eras. Is that okay with you?
2 (Brief recess.) 2 A. Okay.
3 EXAMINATION BY MR. BRUNO: 3 Q. So let's start by identifying a bunch
4 Q. All right. You were kind enough to go 4 of documents. The first thing I'd like to talk
5 get those documents for me. I just want to 5 about is the design of the hurricane protection
6 hook them up with the right paragraph. 6 system, so you'll know where we are. Okay?
7 All right. You identified in 7 A. (Nods affirmatively.)
8 connection with Paragraph 34, that was the 8 Q. All right. These are voluminous
9 effects of the wetlands and swamps, the 9 documents, we can attach or not attach, I'll
10 presentation as well as an interim report in 10 leave it up to counsel to decide what he wants
11 either the fifties or the sixties. 11 to do.
12 A. Uh-huh. 12 First is -- the first document which
13 Q. Which one is that? 13 I'm going to mark as Exhibit Number 25 is
14 A. This is the interim survey report for 14 entitled The National Hurricane Research
15 Morgan City. 15 Project. Okay? (Tendering.)
16 Q. All right. So it's the interim survey 16 Are you familiar with that document?
17 report, Morgan City, Louisiana, and vicinity. 17 (Exhibit 25 was marked for
18 Okay. That's great. That's one of them. 18 identification and is attached hereto.)
19 All right. Then in connection with 19 A. Report Number 33, yes.
20 Paragraph 35, this is the one relative to the 20 EXAMINATION BY MR. BRUNO:
21 effects of hurricane generated surge? No, you 21 Q. Yes, ma'am. Okay. Good. Very good.
22 said ongoing work on that one. I'm sorry. 22 MR. SMITH:
23 Then for 40, you said measures, 23 Joe, do you have a copy for us?
24 actions, analyses, studies and/or reports 24 MR. BRUNO:
25 commenced or undertaken concerning a change in 25 No. They're so voluminous. You
Page 27 Page 29
1 hydrology. And then you called it the -- 1 can look at my copy if you want.
2 that's this one, the effects on Lake 2 EXAMINATION BY MR. BRUNO:
3 Pontchartrain, Louisiana of hurricane surge 3 Q. All right. The next document is
4 control structures on the Mississippi River 4 entitled The Interim Survey Report, Lake
5 Gulf Outlet channel, and that was November of 5 Pontchartrain Louisiana and Vicinity, 21
6 1963. 6 November 1962. (Tendering.) Are you familiar
7 A. That's correct. 7 with that document?
8 Q. Okay. And this one, this is just a 8 (Exhibit 26 was marked for
9 Design Memo Number 2. 9 identification and is attached hereto.)
10 A. Yeah. I also consulted that. 10 A. I don't recall reading this document.
11 Q. And supplemented. Great. Okay. I 11 I couldn't tell you either way if I've looked
12 think we've got all the stuff. 12 at it before or not. I certainly have not
13 All right. Now, where we were was in 13 looked at it recently.
14 IPET, and the reason I was asking you this, I 14 EXAMINATION BY MR. BRUNO:
15 was just trying to see if we could avoid going 15 Q. Okay. Do you know at least what it
16 through a recitation of a bunch of facts about 16 is?
17 what occurred in connection with the subjects 17 A. It's a document that was put together
18 that you've been designated for. That was the 18 pre authorization of the project.
19 real purpose. No nefarious purpose whatsoever. 19 Q. What project?
20 So we'll just cover that another way. 20 A. The Lake Pontchartrain and Vicinity
21 What I'd like to do, to make it easier 21 Project.
22 on you, is to do this chronologically in the 22 Q. All right. And is that something
23 context of those subjects. So we start with 23 that's done as a matter of course when the
24 1955 and move forward. I'm going to try, you 24 Corps embarks on the process of survey to
25 know, to get the documents that relate to those 25 authorization?
8 (Pages 26 to 29)
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Page 30 Page 32
1 MR. SMITH: 1 it.
2 Objection. Vague. 2 MR. BRUNO:
3 EXAMINATION BY MR. BRUNO: 3 Robin, she testified it was an
4 Q. Fine. No, don't answer the question. 4 interim report. She knows what that
5 Let's go through the whole process. All right. 5 means. I don't know when why you
6 What is your understanding of the process by 6 insist --
7 which a project that the Corps is interested in 7 MR. SMITH:
8 doing goes from the germ of an idea to an 8 Why don't you ask her if she
9 authorization by Congress. Let's walk through 9 knows what an interim report is rather
10 each step and then we'll eliminate the 10 than ask her if she knows everything
11 vagueness. 11 about the process from beginning to
12 MR. SMITH: 12 end about authorizing a project.
13 No, Joe, that's not her topic. 13 MR. BRUNO:
14 She's not designated to address all 14 And of course then you're going
15 the steps the Corps goes through to 15 to say I'm getting outside of the
16 get a project authorized. That's not 16 scope again. But that's okay.
17 her topic. She's not here to address 17 EXAMINATION BY MR. BRUNO:
18 that today. 18 Q. I'm trying to get through this the
19 MR. BRUNO: 19 best way I can, Ms. Powell. Do you know what
20 Are you instructing the witness 20 an interim report is in the context of the
21 not to answer? You said vagueness, 21 business of getting a project authorized?
22 not me. 22 A. Interim survey reports are no longer
23 MR. SMITH: 23 used to get projects authorized.
24 I am going to instruct the 24 Q. Fair enough. Back then.
25 witness not to answer. I am. Because 25 A. As I did answer, with the date of this
Page 31 Page 33
1 we're going to wind up in front of the 1 project report being 1962.
2 Magistrate if you're going to continue 2 Q. Sure.
3 to just go willy-nilly asking any 3 A. This is a pre-authorization document.
4 question you feel like. 4 This is a document that comes before
5 MR. BRUNO: 5 authorization.
6 I didn't ask any question I felt 6 Q. What is it used for?
7 lie. I was trying to ask a question 7 A. I don't know. Like I said, the
8 about a specific document. You 8 process has changed. I would have to assume
9 insisted that it was vague. So I was 9 that this was a report that was similar to what
10 trying to eliminate the vagueness from 10 we would call a reconnaissance report or a
11 the question. The only way I can 11 feasibility study in today's process.
12 eliminate the vagueness from the 12 Q. Okay. All right.
13 question is to have the record reflect 13 A. The process has changed.
14 where in the process this document 14 Q. Now, in the context of -- let me ask
15 might fit. Now, you know, who is 15 you this so we can just get centered here:
16 playing games here, you or me? 16 What is the Lake Pontchartrain and Vicinity
17 MR. SMITH: 17 Hurricane Protection Project?
18 She's never seen this document 18 A. As I understand the authorization,
19 before. How would she know where in 19 it's a hurricane protection project.
20 the process this documents fits? 20 Q. All right. And the authorization
21 MR. BRUNO: 21 occurred in 1965, is that accurate? I can show
22 I won't know until she tells me. 22 you -- do you know that it was authorized in
23 MR. SMITH: 23 1965?
24 She told you she had never seen 24 MR. SMITH:
25 it before, or she didn't recall seeing 25 We'll stipulate that it was
9 (Pages 30 to 33)
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Page 34 Page 36
1 authorized in 1965. 1 Congress tells us what to build.
2 A. I don't know if it was re authorized 2 Q. Right. And then Congress refers back
3 or anything else, but I know that it was 3 to that letter, so Congress then is using that
4 authorized. 4 as a description of what you're going to build,
5 EXAMINATION BY MR. BRUNO: 5 right?
6 Q. I didn't ask you about 6 A. That's how authorization does work.
7 re-authorization. Let's not do that. My 7 Q. Okay. So does that or does that not
8 questions are really simple. When I ask about 8 describe what you're authorized to build?
9 authorization that's I want to know about. If 9 A. The reason why I'm struggling with
10 I want to ask about re authorization I'll ask 10 this is because it does predate Hurricane
11 you about re authorization. I don't want to 11 Betsy, and there were some changes made in the
12 get caught up in some gamesmanship with words. 12 hydraulics as a result of Hurricane Betsy that
13 All right? I'm trying to be fair about this. 13 would not be contained in this report. So this
14 Now, we have agreed that -- let's mark 14 report doesn't completely describe the
15 this as Exhibit 27. Let me show you this 15 hydraulic aspects.
16 document. Have you seen that before? 16 Q. Okay. So your testimony is that there
17 (Exhibit 27 was marked for 17 were some changes made to that authorized
18 identification and is attached hereto.) 18 project, correct?
19 A. Yes. I believe I've seen this 19 A. There were some changes made to the
20 document. 20 hydraulics that's contained within this
21 EXAMINATION BY MR. BRUNO: 21 document.
22 Q. Okay. All right. Can you share for 22 Q. I said some changes. You can tell me
23 us on the record what it is? 23 what they are, but the answer to the question
24 A. This is a letter from the Secretary of 24 would be either there were some changes or
25 the Army transmitting a letter from the Chief 25 there weren't some changes. Were there some
Page 35 Page 37
1 of Engineers, Department of the Army, dated 1 changes made?
2 March 4th, 1964 submitting a report together 2 A. Can I get him -- you asked for changes
3 with accompanying papers and illustrations on 3 to the authorization.
4 the review of the reports on an interim 4 Q. All I said was, were there changes
5 hurricane survey of Lake Pontchartrain and 5 made to the -- stop.
6 vicinity, Louisiana. 6 MR. BRUNO:
7 Continue? 7 Read it again.
8 Q. No. What is its significance, if any, 8 (Whereupon the previous question was
9 to building levees? 9 read back.)
10 A. Part of the authorization process, as 10 MR. SMITH:
11 I understand it. But I'm not an expert on the 11 Asked and answered.
12 authorization process. 12 EXAMINATION BY MR. BRUNO:
13 Q. All right. Okay. Does it generally 13 Q. Your answer?
14 describe what it is that is entailed by the 14 A. Yes, there were changes made to the
15 project? 15 hydraulics after this.
16 A. Does the report describe -- 16 Q. And the changes that were made -- and
17 Q. The project? 17 this is why I'm breaking it up, because now I
18 A. The project. Okay. Yes. 18 want to know if they were changes made more
19 Q. Which would be what's entailed by the 19 than just to hydraulics. You've identified
20 project, as well. 20 hydraulics, which is fine. Any other changes
21 A. Yes. 21 made?
22 Q. It tells the Congress what you're 22 A. That's beyond my area of expertise.
23 going to do; right? 23 Q. All right. So you know only that some
24 A. Um -- it tells the Congress that these 24 changes were made and the changes that you're
25 are the Chief of Engineers' recommendations. 25 aware of were to hydraulics.
10 (Pages 34 to 37)
10/3/2008
Page 38 Page 40
1 A. That is correct. 1 what this report has in it and what is in the
2 Q. Okay. Now what do you mean by 2 DMs to see what -- if there was a change in
3 hydraulics? 3 height, change in wave --
4 A. I'm referring to the hydraulics 4 Q. Fair.
5 section that's in this report that refers back 5 A. -- change in whatever.
6 to the standard project hurricane, the 6 Q. I'd like you to do that -- not now.
7 hydraulic design that sets the height and the 7 You can give me a written answer at some
8 minimum cross-section of the levee. 8 feature point, but I'd like to have that
9 Q. All right. Can I take your answer to 9 question answered.
10 mean that change to hydraulics means that the 10 A. Okay.
11 still water height was changed to a higher 11 Q. Now, do you know what information, all
12 number? 12 right, is the new information that was added to
13 A. I don't know if it was changed to a 13 this analysis that's ended up being Exhibit
14 higher number. I do know that the storm 14 Number 27? Did that information take the form
15 characteristics of Betsy were included in the 15 of a report or some analysis or, frankly, just
16 analysis. 16 some description of what this new information
17 Q. Okay. 17 was?
18 A. I don't know if that resulted in a 18 A. As I recall from the DMs, there's a
19 higher number or not. 19 description of Hurricane Betsy, there's a
20 Q. Okay. The number may have been lower. 20 description of its hurricane parameters.
21 A. I don't know. 21 Q. Okay.
22 Q. Okay. Well, it either had to be 22 A. So there was an analysis that was
23 higher or lower or stay the same. 23 performed that incorporated the high water
24 A. Uh-huh. 24 marks and stage data from Betsy into how you do
25 Q. It didn't stay the same. Right? 25 the design of the system.
Page 39 Page 41
1 A. I don't know. 1 Q. Okay. All right. Good.
2 Q. Well, I thought you said there were 2 Do you know whether or not the
3 changes made. 3 Bretschneider and Collins report was or was not
4 A. Yeah. They incorporated Hurricane 4 part of that body of information that was added
5 Betsy into the design. 5 to the analysis that resulted in Exhibit Number
6 Q. Okay. Well, did that effectuate any 6 27?
7 changes in the design? 7 A. Okay, I'm sorry. I'm confused.
8 A. I have to go back to my answer. I 8 MR. BRUNO:
9 don't know. 9 Read it again.
10 Q. You don't know. If you don't know, 10 (Whereupon the previous question was
11 that's fine. Okay. All right. All we know 11 read back.)
12 is -- so you when you talking about changes, 12 A. I take the last part of that sentence
13 you're saying, well, the change wasn't really a 13 out because this predates Bretschneider.
14 change in the result, the change that you're 14 Q. I know. But --
15 aware of is that a new piece of information was 15 A. But yes, the Bretschneider information
16 added to the mixture of information which ended 16 was incorporated into the hydraulic decide.
17 up in some kind of a result. Is that a fair 17 Q. So-called changes that we've been
18 characterization of what you're telling me? 18 talking about.
19 A. That would be a fair characterization. 19 A. Yes.
20 Q. Okay. Now who would I ask in order to 20 Q. Okay. All right.
21 find out whether or not this added information 21 Now, let me show you the next
22 changed the design? 22 document. My understanding is that the
23 A. I don't know who personally worked on 23 document that you reviewed, which was the
24 the project back then. We would have to go 24 interim survey report, which has remarkably the
25 through the available documents and compare 25 same title as the other document which we've
11 (Pages 38 to 41)
10/3/2008
Page 42 Page 44
1 shown you -- yeah, Interim Survey Report for 1 title is -- oh, Flood Control Act of 1965 I
2 Lake Pontchartrain. You in fact reviewed the 2 think is the title. Right there. Okay?
3 interim survey report for Morgan City. 3 (Exhibit 29 was marked for
4 (Exhibit 28 was marked for 4 identification and is attached hereto.)
5 identification and is attached hereto.) 5 A. Okay.
6 A. Correct. 6 EXAMINATION BY MR. BRUNO:
7 EXAMINATION BY MR. BRUNO: 7 Q. So let's just put that -- and the
8 Q. Okay. So you know what that is. 8 reason I'm asking this question is because we
9 A. That report, yes. 9 talked a little bit about an interim report.
10 Q. All right. And what is its purpose? 10 An interim report I think you've already
11 A. I assume the purpose of that report 11 testified is a precursor to the actual
12 was the same purpose as this report, was a 12 authorization. This I'm going to mark as
13 pre-authorization documentation to look at the, 13 Number 30 is the authorization -- I'm sorry. I
14 um -- potential of having a hurricane 14 made a mistake. I already marked it as 28.
15 protection project in Morgan City. 15 This is the Morgan City project. Take a look
16 Q. Okay. Now, in fact, the Bill -- and 16 at it see if I'm accurate in that assessment.
17 maybe we can stipulate to this, but the 17 (Tendering.)
18 Congressional authorization which authorized 18 A. I would say yes based on the title and
19 the Lake Pontchartrain and Vicinity Hurricane 19 what's contained in the document.
20 Protection Project was the same authorization 20 Q. All right. And that letter would
21 that authorized the Morgan City, Louisiana and 21 incorporate those components of this interim
22 Vicinity Hurricane Protection Project. Do you 22 survey report that the Corps decided to present
23 know that to be true? 23 to Congress in that letter, isn't that true?
24 A. I'm not aware of that, no. 24 A. I would assume so.
25 MR. BRUNO: 25 Q. Sure. And listen, the only reason I'm
Page 43 Page 45
1 Can we stipulate to that, Robin? 1 asking the question, Ms. Powell, is I don't
2 MR. SMITH: 2 have the interim report but I do have the final
3 I don't know that to be true. 3 and I'm wondering if we could use the final as
4 MR. BRUNO: 4 the basis for factual information that you may
5 How about we read it? We can 5 have gleaned from the interim.
6 make that an attachment, Robin, if 6 Do you understand my question?
7 you'd like. 7 A. Yeah.
8 MR. SMITH: 8 Q. And is that a fair thing for us to do?
9 Why don't you just reference it. 9 A. Um -- I think it's fair.
10 It's a public law. 10 Q. Okay.
11 MR. BRUNO: 11 A. It's -- a lot of what was in that
12 That's fine. I was just hoping 12 report is contained in this document.
13 we could stipulate. 13 Q. Okay.
14 MR. SMITH: 14 A. Of course, maybe not word for would
15 We can stipulate -- 15 word but it's in here.
16 MR. BRUNO: 16 Q. I know. I know. But may we know or
17 That this is a public law. 17 learn now what you gleaned from the interim
18 MR. SMITH: 18 report about Morgan City that would be germane
19 -- that it's a public law. 19 to the topics that you've been designated for.
20 MR. BRUNO: 20 A. The reason why I reviewed this
21 And that it says what it says. 21 document was to refresh my memory on how the
22 No problem. Okay. 22 plate A4 was developed --
23 EXAMINATION BY MR. BRUNO: 23 Q. Right.
24 Q. Now, I'm going mark as Exhibit 29 24 A. -- and applied to hurricane protection
25 Public Law 89-298, October 27, 1965, and the 25 studies.
12 (Pages 42 to 45)
10/3/2008
Page 46 Page 48
1 Q. Why don't we go through that briefly 1 inland.
2 for the moment. What -- would you share with 2 Q. All right.
3 us what Plate A -- did I get it right, A4? 3 A. And that relates back to the storm --
4 A. Plate A4. Page 71. 4 like I said, the storm track, the speed of the
5 Q. Page 71. Tell us what significance 5 storm -- you know, Gustav was such that we had
6 the plate has for you. 6 peak surges back in the Lafitte area the night
7 A. Okay. This plate was used as part of 7 of the 2nd of September, whereas, you know, the
8 the analysis in looking at surge propagation 8 storm hit the morning of the 1st.
9 from what is known as the surge reference line, 9 Q. Right. The Monday.
10 which is, as this document defines that, an 10 A. The Monday. So how do you describe
11 artificial coastline. 11 that physics? Back in the 60s they did that
12 Q. All right. You'll have to please help 12 with a simplified analysis of how to compare
13 me. Okay? Would you define surge propagation. 13 water levels that are inland versus water
14 A. Um -- I can define it by giving you an 14 levels that are along the coast and came up
15 example. 15 with what was termed a simplified approach.
16 Q. That's fair. However you want to do 16 Because it's apparent -- here again Gustav had
17 it is fine with me. 17 surges much higher along the coast. Backside
18 A. Okay. Hurricane Gustav. Hurricane 18 of Grand Isle was over six feet. The surge
19 Gustav occurred -- 19 from the backside of the storm that went inland
20 Q. A couple of -- 20 was less than three feet.
21 A. -- a couple of weeks ago. 21 So how do you describe that physics?
22 Q. Couple of weeks ago. 22 That's what this plate was attempting to do so
23 A. Okay. Given the track of hurricane 23 that for that critical storm track they could
24 Gustav, the surge that affected the area on the 24 be able to figure out what -- what surge
25 west bank and vicinity project has to move from 25 elevation do you use for your design?
Page 47 Page 49
1 the Gulf of Mexico inland. That surge 1 Q. Okay. Now, when we use the word
2 propagation occurs many hours if not a day or 2 surge, is there -- is surge characterized by a
3 two after the passage of the hurricane, because 3 number? In other words, do we say ten feet of
4 of the location of the hurricane, it's track, 4 surge, or is -- is that accurate? In other
5 how surge gets into that area. 5 words, what -- is there a numeric way to
6 Q. Okay. 6 describe surge? I guess that's the best way to
7 A. The physics of that is very hard to 7 ask the question.
8 model, and when you back into the 1960s they 8 A. Yeah. I mean, you characterize it.
9 didn't have a model that could accurately 9 It's -- surge is depth of water that is
10 represent that physics of the surge moving into 10 normally added to your tide or any other
11 that area. Like I said, it comes from the 11 hydraulic water level.
12 backside of the storm. So. Yes. 12 Q. Okay.
13 Counterclockwise. 13 A. That gives you what your design water
14 Q. Yeah. It's counterclockwise. I got 14 level or your --
15 you. 15 Q. I understand.
16 A. Most research that was done talked 16 A. -- your -- for Gustav, what the peak
17 about the -- you know, the surge that the storm 17 water level was.
18 pushes ahead of it. 18 Q. Right. Well, what's always confused
19 Q. In the front end. 19 me is whether or not surge also takes into
20 A. The front end. But in this particular 20 consideration volume of water. Because
21 case with Gustav, as an example, that surge is 21 obviously you have a certain height of water,
22 actually from the back end. And so it's 22 but then the question is for how long will it
23 affected by the storm track, the magnitude of 23 be at that height? So my question to you is,
24 the surge along the coast, and the duration 24 and maybe there's another description for that,
25 that that surge has the opportunity to move 25 does surge -- when we talking about surge --
13 (Pages 46 to 49)
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Page 50 Page 52
1 when you talk about surge in your day-to-day 1 curve --
2 activities here -- 2 Q. Right.
3 A. Uh-huh. 3 A. -- the stage hydrograph curve. So
4 Q. -- are you talking only about the 4 that shape of that curve -- those curves can
5 depth of the water added to the tied or are you 5 both be totally different and give you the same
6 also talking about volume? 6 volume.
7 A. I use the term surge to talk about the 7 Q. Of course. And duration is time.
8 depth of water added to tide. I don't use it 8 A. Duration is time.
9 in context with the duration. 9 Q. So the record is clear, duration is
10 Q. All right. Which would be the volume. 10 time. So an hour.
11 A. Which the volume plays a role in that 11 A. Uh-huh.
12 duration, yes. 12 Q. So within an hour, given a certain
13 Q. I'm trying to think of what the Dutch 13 height, you got this curve, you can calculate
14 call this thing but it escapes me. But is 14 the volume.
15 there a word that describes the amount of 15 A. Uh-huh.
16 volume or flow of water that accompanies this 16 Q. And if you have more hours then
17 water that comes in from the hurricane? 17 obviously if you have a higher surge in a short
18 A. I don't know that there's a specific 18 duration you get the same volume as a lower
19 term, um -- per se. You know, we look at the 19 surge and of a long duration.
20 water -- the hydrograph, which is the water 20 A. Correct.
21 level and its duration over time. 21 Q. Right? Same volume.
22 Q. Well, the reason I'm asking the 22 A. You can have the same volume.
23 question, because it's one thing, is it not, 23 Q. You can have the same volume.
24 for -- let's say you have a still water height 24 Obviously different surges, though.
25 of 10 -- 25 A. Yeah.
Page 51 Page 53
1 A. Uh-huh. 1 Q. Okay. I got you. All right. So
2 Q. -- and then you have a surge of 11. 2 we're still on that chart. And so -- going --
3 Doesn't the duration of time that the water is 3 you said this was I believe a simplified
4 at 11 have some effect on your design for a 4 approach of trying to explain the business of
5 levee? In other words, if it's going to be at 5 why you have a much higher surge at the coast
6 11 feet for 15 minutes, that's one thing, if 6 but a lower surge further inland.
7 it's going to be at 11 feet for four hours that 7 Did I say that right?
8 may be something else again, I don't know. So 8 A. Yes.
9 that's why I'm asking the question. 9 Q. Okay. So what is the -- what is the
10 Am I making any sense? 10 explanation, mechanically, if there is one, as
11 A. Yeah. You're making good sense. 11 to why it is that the surge height at the shore
12 Q. All right. 12 is higher than the surge height inland?
13 A. When you start looking at the erosive 13 A. Okay. Again, go back, depends on the
14 potential that can occur on a levee as a result 14 storm. That why I'm trying to use Gustav as an
15 of a storm, you have to factor in the duration 15 example.
16 as well as the height. 16 Q. Sure.
17 Q. Okay. Now, so does volume relate -- 17 A. The surge that you saw on the coast
18 the volume of water, does that relate in any 18 occurs as the storm is moving in.
19 way to the duration? 19 Q. Okay.
20 A. Volume is volume. 20 A. The surge, at least for Gustav 's
21 Q. Right. 21 track, that you see inland at Lafitte is a
22 A. You can have a duration storm -- a 22 result of the storm already moving west of the
23 very short duration storm that has the same 23 Lafitte area, and the counterclockwise movement
24 volume of water as a very long duration storm. 24 of the wind is bringing that -- is bringing
25 The volume is actually the area under the 25 water from the Gulf of Mexico into that area.
14 (Pages 50 to 53)
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Page 54 Page 56
1 Q. Okay. So we have wind, and 1 cause the water level to go down, if anything?
2 pressure -- I know pressure has something to do 2 I don't know if it does anything at all.
3 with -- 3 A. Well, the fact that you're on the back
4 A. And you have forward speed because 4 side of the storm now because the storm did
5 there's a duration involved. 5 move inland, that's -- it's the -- the wind is
6 Q. Okay. So what we end up with is, for 6 moving the water into the overland area.
7 lack of a better description, a pile of water 7 Q. All right. So it is now on land.
8 at the coast. Right? 8 A. The storm is on land.
9 A. Uh-huh. 9 Q. And the water is on land.
10 Q. Okay. But the question is, do we 10 A. The --
11 understand mechanically why the surge level at 11 Q. I mean I think. Did the wind push the
12 the coast is higher than the surge level 12 water on land?
13 inland? What's going on there to cause that 13 A. The wind, to some -- well, go back to
14 surge level to decrease? 14 the Gustav example.
15 A. In the context that I'm talking about 15 Q. That's where we are.
16 with Gustav, yes, we understand the mechanics 16 A. The area that I'm referring to
17 of why the water level inland is lower than the 17 actually gets a drawdown as the storm is moving
18 water level at the coast. 18 in.
19 Q. All right. What is the -- 19 Q. Right. But it's still more --
20 A. But each storm is different. 20 A. So there's less water at the time of
21 Q. I understand. But what is the 21 the peak at the coastline.
22 explanation in the context of Gustav? 22 Q. Right.
23 A. Okay. The initial thing is you look 23 A. The water level actually, inland, has
24 at the -- how high did the Gulf of Mexico get? 24 gone down because of how the winds -- the wind
25 The storm is pushing water to the coast. Then 25 are actually blowing the water out.
Page 55 Page 57
1 the storm is moving away inland. So that rate 1 Q. Right.
2 of speed that it's moving inland, you know, 2 A. And then the surge is coming up at the
3 while the gulf is still somewhat elevated, the 3 coastline, then the storm is moving westward.
4 gulf is actually coming down at the same time 4 Q. Right.
5 the storm is moving, so it's kind of like I've 5 A. And the backside of the storm is
6 hit my peak at the coastline -- 6 bringing the water inland.
7 Q. All right. 7 Q. Okay. So --
8 A. -- I've come down because the storm 8 A. So it's a slightly different physics.
9 has already passed, but now because of the wind 9 That's why --
10 coming from a different direction the wind is 10 Q. Did I miss it? Is it lower off the
11 taking that water that's falling in the gulf of 11 coast or higher on the coast? I thought you
12 Mexico and continuing to push it into -- 12 told me that the surge level was higher at the
13 inland. 13 coast, but it's lower inland, and that this
14 Q. Okay. Fair enough. 14 simplified approach would explain why it's
15 A. So this plot here is describing the 15 lower.
16 water surface profile -- 16 A. Uh-huh.
17 Q. All right. 17 Q. So why is it lower?
18 A. -- that you could expect -- 18 A. The surge reference line coastline.
19 Q. Inland. 19 Q. Right. So you've got --
20 A. -- inland. 20 A. Because that may not necessarily be
21 Q. All right. So why does the water go 21 your actual coast because the line would --
22 down -- I mean, however high the water is is X 22 kind of moves around a little bit.
23 height. 23 Q. Well, sure. But I mean it's X height.
24 A. Uh-huh. 24 Pick a number; 10. I don't know what it was.
25 Q. So what does the inland movement do to 25 10.
15 (Pages 54 to 57)
10/3/2008
Page 58 Page 60
1 A. Yeah. 1 A. Uh-huh.
2 Q. And when it got in land it was lower. 2 Q. So what does Subparagraph 5 mean to
3 A. Right. 3 the layman?
4 Q. Right? Did I get that right? 4 A. It's just talking about the limit of
5 A. Yeah. 5 over land surge penetrations depending upon
6 Q. Okay. So what made it go lower? 6 height of the surge, which is, you know, what
7 A. But it's not -- what makes it go lower 7 the Gulf of Mexico is doing, and the duration
8 is the source of water and the energy that's 8 of high stages at the coast, which is depending
9 moving that water -- you have the source of 9 on the storm track and the storm moving inland.
10 water, but the energy that's moving that water 10 Q. Right. And then it says, the data
11 inland is going away. 11 indicate that the weighted mean decrease in
12 Q. Right. 12 surge heights inland is at the rate of 1 foot
13 A. The hurricane has already gone past. 13 per 2.75 miles. What does that mean?
14 So -- 14 A. That is the slope of the line that --
15 Q. So it moves in that direction. 15 (Indicating) -- was, um -- developed to try to
16 A. As you get in the outer bands of the 16 describe the process --
17 hurricane, there's less energy to move that 17 Q. Okay.
18 water inland. 18 A. -- in absence of, you know, a physics
19 Q. Okay. 19 model or anything at the time that could
20 A. Therefore the water level is lower. 20 accurately reflect the whole complicated system
21 Q. All right. Does the topography, the 21 and how it would work.
22 fact that it is over land have anything to do 22 Q. So am I interpreting it correctly that
23 with reduction in the surge? 23 it means that if you have 10 feet of surge,
24 A. The topography of the land affects the 24 when that surge goes inland 2.75 miles that
25 hurricane itself and can also affect the 25 surge will now be nine feet? According to this
Page 59 Page 61
1 movement of the water. 1 chart.
2 Q. Okay. But does it affect surge? Just 2 A. In the context of you have the
3 taking that little piece of the puzzle. 3 location of the surge reference line, and --
4 A. Yeah. 4 which is -- and then at that surge reference
5 Q. All right. And that chart talks a 5 line you have a 10-foot surge.
6 little bit about that, right? 6 Q. Okay.
7 A. No. 7 A. Then if you move 2.75 miles inland,
8 Q. It doesn't? 8 then that surge height would be reduced by a
9 A. The chart relates to a water surface 9 foot, yes.
10 profile, a slope of the water surface -- 10 Q. Okay. Does that happen in open water,
11 Q. Okay. 11 as well?
12 A. -- that can be applied. This is 12 A. It would not happen in the Gulf of
13 actually a water surface slope. (Indicating.) 13 Mexico. It could happen in open waters such as
14 Q. Okay. Let me just get with you. And 14 bays that this relationship would still apply.
15 you're on Page -- Okay. It's Page 71? 15 Q. All right. Now, does that happen
16 A. 71, but I'm also referring back to 16 because in order for water to move over land it
17 Page 54, which is the text. 17 needs more energy to push through the trees and
18 Q. Okay. And the text that you're 18 the grass and the land and all that business
19 looking at is Subparagraph 5? 19 that it may encounter?
20 A. Paragraph 5 and Subparagraph 6. 20 A. That's a part of this, but this was
21 Q. Okay. All right. So Paragraph 5 21 also an attempt to describe the fact that the
22 talks about the marshlands that fringe the 22 storm is losing energy, the storm is moving
23 coastline in certain locations are inundated 23 away, so there's no -- there's no push to bring
24 for considerable distances inland by hurricane 24 water inland on the backside of the storm. So
25 surges that approach the shore. Right? 25 you've lost that aspect also of the ability for
16 (Pages 58 to 61)
10/3/2008
Page 62 Page 64
1 surge to move inland. 1 of Lake Palourde and it would be only the
2 Q. All right. I'm confused just a tad, 2 passage of the hurricane to the west that would
3 because your example referred to Gustav, which 3 bring the water back around into the lake.
4 was the scenario where we're looking at the 4 Q. On the back side again.
5 backside. 5 A. On the backside again.
6 A. Right. 6 Q. Okay.
7 Q. I thought you told me, Ms. Powell, 7 A. So those are -- it looks like for
8 that this chart only considered the front side 8 these -- at least these two examples, these
9 of the storm. Did I get that wrong? 9 would be the storms where you were having more
10 A. No. We didn't talk about that at all. 10 influence from that back side. Similar to what
11 Q. Okay. I thought we did. So this 11 Gustav did.
12 chart talks about the front side of the storm 12 Q. So then do we then conclude that this
13 and the backside of the storm? 13 chart teaches us about what happens to surge as
14 A. Because of its simplicity, it 14 the hurricane is moving -- is past us?
15 doesn't -- 15 A. I think it does part of that, but
16 Q. Distinguish. 16 you'd have to look at each one of the storms
17 A. -- it doesn't distinguish, so it was 17 that they use from the data, the 1957 storm,
18 applied to -- 18 the 1947 storm, all these high water marks, to
19 Q. Right. 19 see if in fact were these -- you know, what was
20 A. -- the critical track that was used 20 the impetus that created that high water mark?
21 for this design. 21 Was it -- in the case that you're looking at,
22 Q. All right. 22 is the storm itself pushing the water inland --
23 A. And let's see the plate that's in here 23 Q. Right.
24 that tells you what that is. 24 A. -- ahead of the storm --
25 Okay. Here's -- these are the storm 25 Q. Right.
Page 63 Page 65
1 tracks that were used for design. 1 A. -- or the back side of the storm
2 MR. SMITH: 2 pushing the water inland.
3 If you could just mention what 3 Q. Okay.
4 page that is. 4 A. So we'd have to actually look at every
5 A. Yeah. On Page 77 and 78. 5 one of these in a separate context.
6 EXAMINATION BY MR. BRUNO: 6 Q. Sure. Well, that would describe the
7 Q. So what does that tell us about 7 bases upon which the chart was created. May I
8 whether this chart is used for storms as they 8 ask, though, then, about what or how this chart
9 approach as opposed to -- 9 was used once it was made by the Corps? In
10 A. Um -- Page 77, the -- my 10 other words, did the Corps only use this chart
11 interpretation of this figure would be that the 11 to describe what was expected to happen with
12 storm has already passed, it's moved inland and 12 surge after the hurricane passed or did this --
13 the water is coming -- because the winds are 13 was this chart used perhaps for some purposes
14 now from the southwest, counterclockwise, it's 14 regarding the approach of a storm? I don't
15 pushing the water in. So that would be a case 15 know, that's what I want the find out.
16 where, you know, the inland penetration is 16 A. I would say that each case would be
17 dependent on this track and what's happening on 17 different, because this chart was not used in
18 the back side of the storm. 18 every design application, because there was a
19 Q. All right. 19 critical storm and a critical track identified.
20 A. On 78, they don't show a surge 20 So depending on that truck and storm, and
21 reference line. So I'm not sure what this one 21 depending on where you are putting the levee,
22 shows. Um -- this one says critical to Lake 22 you may have this type of an effect or you may
23 Palourde, so you're bringing in -- again, as 23 not have this type of an effect.
24 the storm moves along the track the winds are 24 Q. Okay. I'm looking at -- forgive me
25 coming out of the north, it's pulling water out 25 for going out of turn just a little bit. I'm
17 (Pages 62 to 65)
10/3/2008
Page 66 Page 68
1 going to mark this document. Let me give it a 1 Q. Okay. Okay. Now, and then you looked
2 title. Let's just put a number on it now. 2 at that -- please help me remember -- for what
3 We'll figure it out later. 3 reason? You were trying to do something, I
4 This is the Lake Pontchartrain 4 don't recall what it was.
5 Louisiana and Vicinity Design Memorandum 5 MR. SMITH:
6 Number 1, Hydrology and Hydraulic Analysis, 6 Objection. Asked and answered.
7 Part 4, Chalmette Extension, October, 1967. 7 EXAMINATION BY MR. BRUNO:
8 And if we can, it looks to me, I may be wrong, 8 Q. It was asked and answered, and I
9 but we've got one of these little charts back 9 forgot and I'd like the courtesy of you helping
10 there. 10 me remember what you said.
11 A. Uh-huh. 11 A. I don't know, Number 35, Number 34,
12 Q. We're we go. (Indicating.) Yeah. 12 whatever it was, the effect of wetlands on --
13 MR. SMITH: 13 Q. Yeah. Here it is. Yeah. Let me help
14 Exhibit 30? 14 you. In fairness to you, it was --
15 MR. BRUNO: 15 A. I revisited this in context with
16 This is Exhibit 30. 16 reviewing work that --
17 (Exhibit 30 was marked for 17 MR. SMITH:
18 identification and is attached hereto.) 18 (Tendering.)
19 EXAMINATION BY MR. BRUNO: 19 MR. BRUNO:
20 Q. Now, by happenstance my fingers opened 20 That was 34. Yeah. That's
21 to that page. I don't know if that's the right 21 right.
22 page or not. But do we have there another one 22 EXAMINATION BY MR. BRUNO:
23 of these charts? 23 Q. You told me that in the context of 34,
24 A. Um -- this is for the Chalmette 24 all scientific research and studies relative to
25 extension, the area that goes from Bayou Dupre 25 the effects of wetlands and/or swamps on
Page 67 Page 69
1 all the way around to Caernarvon. And yes, 1 hurricane-generated waves, right?
2 there's a -- there should be a chart in here. 2 A. Uh-huh.
3 Q. I think I have it as Plate 6. 3 Q. Okay. All right. So --
4 A. Uh-huh. 4 MR. SMITH:
5 Q. Okay. Now, do I gather from the 5 Just say yes or no, if you can,
6 simple fact that we have a chart for the Morgan 6 for the court reporter.
7 City area and we have a chart for Chalmette 7 EXAMINATION BY MR. BRUNO:
8 that you make a new chart for each project? 8 Q. So just so we can move past that, the
9 A. It appears what they did is they took 9 answer is yes?
10 the plate out of the Morgan City analysis, 10 A. Yes.
11 changed the title and put it in this report, 11 Q. So what if anything did this chart
12 yeah. 12 tell you about the effect of wetland and/or
13 Q. Okay. So it's not a new chart, it's 13 swamp on hurricane-generated waves?
14 the same old chart. 14 MR. SMITH:
15 A. It's the same chart. 15 Objection. Vague.
16 Q. They're just using it for some purpose 16 A. The chart actually tells me how in the
17 which we'll get into in a moment. 17 design process the physics of the storm moving
18 A. Uh-huh. 18 away from the area of interest and the surge
19 Q. Okay. So I just wanted to establish 19 propagating inland, you know, how that physics
20 if it was the same chart. 20 was described to be used in this design
21 A. It appears to be the same chart, yeah. 21 instance.
22 Q. And it makes the same conclusion, 22 EXAMINATION BY MR. BRUNO:
23 average surge decrease 1 foot per 2.75 miles, 23 Q. Okay.
24 right? 24 A. So --
25 A. Yeah. 25 Q. So did the Corps assume a surge height
18 (Pages 66 to 69)
10/3/2008
Page 70 Page 72
1 reduction for each 2.75 miles of -- before I 1 Q. Okay. I think I'm with you. Is this
2 ask that question, let me see if I can learn 2 the right page?
3 what the 2.75 miles refers to. It's of what, 3 A. Yeah.
4 exactly? 4 Q. Yeah. Okay, good.
5 A. Of whatever is between the surge 5 A. On Table 2, you'll see the Corps --
6 reference line and the levee location. That 6 the MRGO levee reach, the maximum surge height
7 could be open water, that could be -- 7 at the surge reference line is 12 and a half,
8 Q. Swamp? 8 but at the levee location it's also 12 and a
9 A. -- swamp, that could be -- 9 half. The designers believed that the surge
10 Q. Trees? 10 reduction was not applicable for that reach of
11 A. -- whatever -- 11 the levee, that it would be applicable for the
12 Q. Okay. All right. 12 Verret and Toca reaches on the tracks of the
13 A. -- that's in between the surge 13 storms, Track Cs. The surge reference line
14 reference Lynn and the levee. 14 maximum surge right was 15, but at the levee
15 Q. Okay. And does the Corps assume that 15 location it was 12.2. The actual reduction was
16 it's going to be one foot no matter what is in 16 applied in that case.
17 between? 17 Q. Okay. Can you help me figure out
18 MR. SMITH: 18 where each of these references are, the F, the
19 Objection to the form of the 19 C and the C?
20 question. "Assume." 20 A. Okay. The F is --
21 EXAMINATION BY MR. BRUNO: 21 Q. Is there a map in there somewhere?
22 Q. Well no, let me withdraw the question. 22 A. Yeah. Okay. On Plate 3 of this
23 Does the 1 foot reduction apply 23 Exhibit 30 --
24 regardless of what is in fact between the 24 Q. Okay.
25 reference line and the point at which -- and 25 A. -- you'll see -- and it's a little
Page 71 Page 73
1 that 2.75 miles? 1 bit better on Plates 4 and 5 that you can see
2 A. Only if it was applicable. It was not 2 it, but at least on Plate 3 you'll see Track F
3 used in every design instance. 3 which starts -- you see the word Flossy?
4 Q. Okay. 4 Q. Yes, I sure do.
5 A. It was only used in design instances 5 A. If you come straight down you'll see a
6 where it was apparent that the surge at the 6 dashed line.
7 coastline was not accurately -- did not 7 Q. Yes.
8 accurately represent the surge inland that 8 A. And you follow that dashed line you'll
9 would be created by the storm design storm on 9 see Track F and you just keep -- that's Track
10 the critical track. 10 F. That was the design track used for the MRGO
11 Q. Right. Okay. I got you. So that 11 reach.
12 would obviously depend upon the track. 12 Q. Okay.
13 A. Uh-huh. 13 A. Track C you have to start where the
14 Q. Because you then have to establish 14 scale of miles is down at the bottom.
15 what you call it, your line? Forgive me. 15 Q. See that. Sure?
16 A. The surge reference line. 16 A. You'll see another dashed line and
17 Q. The surge reference line and the place 17 you'll see Track C moves -- is a different
18 where you've building whatever you're building. 18 design storm track.
19 A. Uh-huh. 19 Q. Uh-huh.
20 Q. I got you. And if you ascertained 20 A. So those are the two. For the MRGO
21 that there was land of 2.75 miles in between 21 Track F was used, for Verret and Toca, Track C
22 those two points, well then, yeah, you could 22 was used for the design.
23 safely calculate a 1 foot reduction, right? 23 Q. Okay.
24 A. Yeah. Here's a good example of what I 24 A. And if you go to Plate 4, Plate 4 here
25 mean. Go to Page 6 of Exhibit 30. 25 again is for Track C, which is Verret and Toca.
19 (Pages 70 to 73)
10/3/2008
Page 74 Page 76
1 They show the wind fields. 1 Q. Okay. Ms. Powell, we've got this nice
2 Q. Right. 2 big map up here. I don't know how we're going
3 A. What they call isovels, the velocity 3 to do that, but let me --
4 patterns. 4 All right. Okay. I'm moving my pen
5 Q. All right. Was a levee contemplated 5 along where the MRGO reach of the levee is.
6 to be built there? 6 Okay? Is that accurate? And then it makes
7 MR. SMITH: 7 this sharp right-hand turn and makes a little
8 Objection. Vague. 8 bit more of a turn, and it follows down and
9 EXAMINATION BY MR. BRUNO: 9 connects back here. So this extension is this
10 Q. Oh, that's where the Chalmette 10 part of the levee and some part of this, we
11 extension was going to go? 11 don't know how much. Some amount of that.
12 A. Yeah. Verret and Toca is part of the 12 Right?
13 Chalmette extension. 13 A. Correct.
14 Q. Was that ever built? 14 Q. Okay. So what I'm curious about is,
15 A. That's -- let me get the description 15 those little towns whose names I've already
16 of the Verret and Toca reach. Based on my 16 forgotten, Toca and Verret, that's down in
17 understanding of the original -- the first 17 here.
18 plate that's in this whole document which shows 18 What is your sense of the direction of
19 authorized plan of protection, the Verret to 19 the wind given the track that you referred to
20 Toca reach is going to be the lower part of the 20 as it relates to this area here, these two
21 levee reach down here. I just need to find 21 little towns?
22 where it start and where it ends. See down 22 A. Okay. I referred to Track C.
23 here. (Indicating.) 23 Q. Right.
24 Okay. There's a description of -- I 24 A. I'm trying to get to Plate 4 of
25 have to find it. It's in here somewhere. 25 Exhibit 30, which shows what Track C is. The
Page 75 Page 77
1 There's a description of what the MRGO reach 1 track generally goes just to the west of Grand
2 is, there's a description of the Toca area and 2 Isle, which is off this map, and goes west of
3 the Verret area. Okay. Page 3 is the -- you 3 Lake Salvador, so it's way over --
4 can glean from what they have at the bottom of 4 Q. Okay.
5 Page 3, Track C and F are used for the 5 A. So as that storm moves, the winds are
6 Chalmette extension, Track C being critical to 6 coming out of the north. If the storm is
7 the levees south of Highway 46, and Track F 7 eastward of the area in question, the Verret
8 being critical to the levee along the MRGO. 8 and Toca area, the winds would be out of the
9 Q. Okay. So whatever the extension is 9 north. So any water along the reach of levee
10 along the MRGO, that's Track F? 10 from --
11 A. That's Track F. And the surge 11 Q. That line that referred to, the
12 reduction factor was not applied. 12 storm --
13 Q. Is nil -- not applied. And then when 13 A. But I'm looking at Track C which is
14 it makes that sharp right-hand turn, we call 14 only critical to the reach of levee that starts
15 that the connecting levee -- 15 at Highway 46 and goes this way.
16 A. Okay. 16 Q. Okay. So what is the direction of the
17 Q. -- between the MRGO and the river. 17 attack, if you will, for this levee?
18 A. Uh-huh. 18 A. For this levee reach here that both of
19 Q. That's where that surge reduction 19 us pointed to, when the storm is still to the
20 formula was used. 20 east of here the winds are out of the north,
21 A. Correct. 21 the water is actually decreasing. The wind is
22 Q. Okay. Great. Good. Thank you very 22 pushing water away from that levee.
23 much. 23 Q. Okay.
24 (Brief recess.) 24 A. As the storm moves further west, the
25 EXAMINATION BY MR. BRUNO: 25 back side winds, the winds are now shifting to
20 (Pages 74 to 77)
10/3/2008
Page 78 Page 80
1 come out of the south. The storm has moved to 1 storm is to the east, the winds are out of the
2 where it's westward of this reach, the water is 2 north, and that would brings this water --
3 now coming -- 3 Q. All right. So once again, we have a
4 Q. From the south. 4 frontal attack if you will, I guess if we're
5 A. -- from the south. 5 using military parlance. It's a direct attack
6 Q. So it's a direct attack, if you will. 6 on -- well, actually, it's here on that section
7 A. And the water is now propagating from 7 of levee. Right?
8 the Gulf of Mexico over the wetlands south of 8 A. Correct.
9 this levee into here. 9 Q. Okay.
10 Q. All right. So that that distance that 10 A. So that's exact -- I would say it's
11 we talked about would be some point -- a point 11 exact opposite of --
12 on this southernmost part of a levee down -- 12 Q. Sure.
13 A. To wherever the surge reference line 13 A. -- of this levee reach, whereas the
14 is. 14 water came in -- you know, from the south, the
15 Q. Okay. All right. And since we're 15 water here's is coming in from the north while
16 dropping two feet we can assume it's about five 16 the storm is still over east of the area,
17 miles? 17 whereas here the storm is west of the area and
18 A. Um -- if the math is correct. I would 18 the wind is bringing it back around from the
19 assume they would have that in here. 19 south.
20 Q. Not the map, but what I was doing is 20 Q. Got you. Okay. So using the same
21 deducing in reverse the chart that you 21 track, if we use this alignment, there may or
22 originally showed us. 22 may not be some changes in the calculation of
23 A. Uh-huh. 23 the degree to which the surge would be reduced
24 Q. There it is. 24 if you add -- consider all this land in here,
25 A. On Page 6, Table 2 shows just under 25 this central wetlands unit. Is that correct --
Page 79 Page 81
1 3 feet. So it would be probably -- 1 A. I don't know that any calculations
2 Q. 3 times 2.75. About eight miles? 2 were ever made on this levee.
3 A. If that math is correct, yeah. 3 Q. No, I'm not saying that --
4 Q. And believe me, I'm not saying that it 4 A. I would have to determine where I
5 is. 5 believed the surge reference line would be --
6 A. Yeah. 6 Q. Right.
7 Q. All right. Now, just one more 7 A. -- before I could say -- you know, if
8 question or series of questions before we leave 8 the surge reference line was at this location,
9 this. We've had some testimony that one of the 9 then the wetlands would have no --
10 original alignments of the levee considered was 10 Q. Exactly.
11 at the 40 Arpent. Okay? Before we go there, 11 A. -- you know, there would be no
12 the F track that was used for this Chalmette 12 reduction because there's not enough distance.
13 extension, can we look at and determine the 13 Q. Okay.
14 direction of attack that was contemplated by 14 A. So the line of maximum surge has yet
15 the Corps on the F track? 15 to be determined for this, the 40 Arpent levee
16 A. Okay, based on Figure -- Plate -- 16 alignment.
17 well, Plate 5 in Exhibit 30, Track F is -- it's 17 Q. Right.
18 going to be somewhere between the Mississippi 18 A. So --
19 River and the MRGO. 19 Q. Well, we do know --
20 Q. Okay. 20 A. -- it would be speculative as to if
21 A. I'm well further east of this map. 21 there would be a reduction that would be
22 And then it's going to move to where it crosses 22 applied from your 1960s technology. You know,
23 the river below this levee reach. 23 we enjoy, today, something -- you know, the
24 Q. Okay. All right. So we have that -- 24 ability to model the physics, so we would not
25 A. So we have that track. So as the 25 even use this methodology.
21 (Pages 78 to 81)
10/3/2008
Page 82 Page 84
1 Q. All right. In fairness to you, we did 1 Center. So, yeah. I would assume this is an
2 take the deposition of a Corps employee who 2 older version of the third edition, 1966.
3 said he did do still water calculations for 3 Q. Okay. We, by the way, cannot find a
4 this 40 Arpent levee, and that gentleman 's 4 copy of the '54. It is not in the production.
5 name was -- I'm really testing myself now. 5 We have looked. So if you have a copy of it,
6 Jerry Colletti? No, Soileau. 6 we would be in your debt. Do you know if you
7 A. Cecil Soileau. 7 have a copy of the '54?
8 Q. Cecil Soileau. He the one that told 8 A. I don't know. Everything that we
9 us that they changed because this was the 9 could find in our office we provided to DOJ.
10 consideration, somebody said change it and they 10 So if it's --
11 did. So that's fine. 11 Q. If it exists, Robin has it.
12 A. Okay. 12 A. Robin has it. It may not.
13 Q. All right. Of course, you haven't 13 Q. Fine. The next document is Exhibit
14 talked to Cecil about those -- obviously, what 14 Number 32 which -- have you seen this?
15 he may or may not have done about calculating 15 (Exhibit 32 was marked for
16 still water heights along the 40 Arpent Canal. 16 identification and is attached hereto.)
17 A. No. 17 A. Yes.
18 Q. Okay. Good. All right. I'm marking 18 EXAMINATION BY MR. BRUNO:
19 this document Exhibit Number 31. Let me show 19 Q. What is that?
20 it to you and see if you've ever seen this 20 A. That is Lake Pontchartrain, Louisiana
21 thing. 21 Vicinity Design Memorandum Number 1, Hydrology
22 (Exhibit 31 was marked for 22 and Hydraulic Analysis for Part 1, which is
23 identification and is attached hereto.) 23 Chalmette, dated August, 1966.
24 A. Yes. 24 Q. What is that, what is its significance
25 EXAMINATION BY MR. BRUNO: 25 if any to the --
Page 83 Page 85
1 Q. What is it? 1 A. This would be the design memorandum
2 A. It's the U.S. Army Coastal Engineering 2 that provides the hydrology and hydraulic
3 Research Center Shore Protection, Planning and 3 analysis for the Chalmette reach of the levee
4 Design Technical Report Number 4, Third 4 system. Although it will describe the
5 Edition, 1966. 5 hydrology of the entire project area and the
6 Q. All right. Now, the Lake 6 development of design elevation for Chalmette
7 Pontchartrain Louisiana and Vicinity Design 7 Inner Harbor Navigation Canal, Citrus back
8 Memo Number 1, which we haven't yet marked yet, 8 levee and New Orleans back levees, as noted on
9 but just to give you some reference -- 9 Page 1.
10 A. Uh-huh. 10 Q. Okay. Let me show you the next
11 Q. -- in the bibliography section refers 11 document I've marked as Exhibit 33. This is
12 to the shore protection, planning and design 12 the Bretschneider and Collins report.
13 technical report Number 4 dated June, 1954. 13 (Exhibit 33 was marked for
14 Is that a predecessor to that 14 identification and is attached hereto.)
15 document? Maybe I'll just show you the page. 15 A. This is the National Engineering
16 A. I would assume it is. 16 Science Company Storm Surge Effects of the
17 Q. Let me show you before you answer. 17 Mississippi River Gulf Outlet, Study A, that
18 A. Okay. 18 was prepared by Bretschneider and Collins.
19 Q. It's Number 11. Tendering.) 19 EXAMINATION BY MR. BRUNO:
20 A. Beach Erosion Board Shore Protection 20 Q. And then finally -- well, this is the
21 Planning and Design, Technical Report Number 4, 21 Design Memo Number 3. I've marked it as 34.
22 June, 1954. This is technical report Number 4. 22 Are you familiar with that?
23 The Beach Erosion Board became, you know, 23 (Exhibit 34 was marked for
24 the -- part of the Beach Erosion Board became 24 identification and is attached hereto.)
25 the part of the Coastal Engineering Research 25 A. Yes. This is Lake Pontchartrain
22 (Pages 82 to 85)
10/3/2008
Page 86 Page 88
1 Louisiana and Vicinity Chalmette Area Plan 1 just call it that, the overland surge elevation
2 Design Memorandum Number 3 dated November, 2 chart?
3 1966. 3 A. Okay.
4 EXAMINATION BY MR. BRUNO: 4 Q. All right. Now, that chart was
5 Q. Now, I've piled all those documents in 5 created utilizing high water marks that were
6 front of you because really I want to make 6 taken from visual observation at certain points
7 certain that I had as much of the reference 7 on the map, at certain times, resulting from
8 material that you may need to answer some of 8 certain storm events. Isn't that true?
9 these questions. You may or may not. Okay? 9 A. It was taken from high water marks. I
10 And let's just for completeness sake mark 10 assume they surveyed them in -- not just
11 Design Memo Number 3, Supplement 1, which 11 visually observed them, but actually came up
12 includes the Chalmette extension. And I'm 12 with an elevation.
13 going mark this as 35. This regards that last 13 Q. Well, that's what actually I meant by
14 piece of levee that you and I have just been 14 visual. I mean, someone actually looked at it,
15 talking about. 15 measured it, recorded the information. Right?
16 (Exhibit 35 was marked for 16 A. Correct.
17 identification and is attached hereto.) 17 Q. So it's from the actual storm event.
18 Q. All right. Let me show you this 18 A. It was from several storm events, yes.
19 document which is entitled Review of Report 19 Q. Okay. Now, explain to me the
20 St. Bernard Parish, Louisiana, marked as 20 difference, if there is any, between the
21 Exhibit Number 36. Have you ever seen this 21 standard project hurricane and the design
22 thing before? 22 hurricane.
23 (Exhibit 36 was marked for 23 A. For the Lake Pontchartrain and
24 identification and is attached hereto.) 24 Vicinity Project, the design hurricane is the
25 A. No, I don't recall ever seeing this. 25 standard project hurricane.
Page 87 Page 89
1 EXAMINATION BY MR. BRUNO: 1 Q. Are there instances when the design
2 Q. If you look at the second page, it 2 hurricane might not be the standard project
3 just seems to be review of a bunch of different 3 hurricane?
4 reports after Betsy. That was -- maybe Betsy 4 A. Yes. The New Orleans to Venice
5 was the catalyst for. 5 Hurricane Protection Project, the design
6 A. No, I've never seen this. 6 hurricane is something different.
7 Q. Okay. 7 Q. What accounts for the difference? I
8 A. Can we keep a copy? 8 mean, is it just matter of choice, or is that a
9 Q. Sure. In fact, I've attached it, so 9 judgment call? Or --
10 it will be a part of the deposition. All 10 A. Um -- it's more than just a judgment
11 right. Now, with all of that, let's see if we 11 call, it's a whole detailed analysis that's
12 can kind of get centered here. 12 performed to see what in fact can be justified
13 First, the chart that you and I have 13 economically or from the criteria, that was
14 looked at for some while that talks about the 14 used to say, you know, we can justify a project
15 surge reduction over a certain distance, give 15 with this design hurricane.
16 me a good descriptor of that so I will know how 16 Q. Okay. Let me see if I've got it.
17 to describe it. Is it -- you've called it a 17 First, you calculate the standard project
18 simplified approach to an assessment of surge 18 hurricane. That's a matter of utilizing
19 reduction between the surge reference line and 19 certain required information. Right? Defined
20 the point at which you are measuring, but is 20 by the Corps' own practices and procedures.
21 there maybe a little shorthand version I could 21 A. Um -- we no longer use standard
22 use? 22 project hurricane in our design procedure.
23 A. Just the name that's on the chart, 23 Q. Back then. But back then. Let me
24 overland surge elevations coastal Louisiana. 24 share with you, all of my questions -- remember
25 Q. Overland surge elevations -- can I 25 we were talking chronologically? This whole
23 (Pages 86 to 89)
10/3/2008
Page 90 Page 92
1 business is '55 to '65, okay? That's where I 1 the Chalmette, um -- I'm sorry. Let me say it
2 am. 2 correctly. The Chalmette -- what is it called?
3 A. Uh-huh. 3 The Chalmette --
4 Q. And when I leave there I'll tell you. 4 A. The Chalmette Loop.
5 So we're talking about first the 5 Q. The Chalmette Loop. Yeah. As
6 design of those levees, and we're talking 6 distinguished from Lake Pontchartrain levees,
7 about, obviously then, when they were designed, 7 et cetera. It's the Chalmette -- is it loop?
8 which is from '55 to '65. But you start with, 8 Chalmette area, I think.
9 or you did -- back in that era, the standard 9 A. Chalmette.
10 project hurricane was determined first, I'm 10 Q. It's Chalmette something. But that
11 gathering from your testimony. Is that 11 generally refers to the hurricane protection
12 correct? 12 designs along the MRGO reach, correct?
13 A. Based on what I've read in the 13 A. Correct.
14 documents, I would conclude that the process 14 Q. Does it also include the hurricane
15 started with the standard project hurricane. 15 protection designs for the southern border of
16 Q. Okay. And then there's some process 16 New Orleans East?
17 by which the Corps determines whether or not it 17 A. Let me make sure -- I'm going to
18 can build to protect from that standard project 18 clarify. I apologize for this.
19 hurricane or not. And if it can, then it 19 Q. I'll show you the map.
20 becomes the design hurricane. If it can't, for 20 A. The standard project hurricane is the
21 whatever reasons, economic or otherwise, then 21 design hurricane for the entire Lake
22 they create a design hurricane. Did I say that 22 Pontchartrain and Vicinity Hurricane Protection
23 correctly? 23 Project. So the actual storm itself, not the
24 A. Not quite. 24 track. Tracks are different.
25 Q. Okay. 25 Q. Okay.
Page 91 Page 93
1 A. There's always a -- in this era there 1 A. But the standard project hurricane
2 was always a design hurricane. The Corps 2 storm parameters --
3 selected and recommended the standard project 3 Q. Well, that's where I got myself
4 hurricane for Lake Pontchartrain and Vicinity 4 confused.
5 as that design hurricane. Because New Orleans 5 A. Yeah. It's two parts.
6 to Venice lacked maybe an economic 6 Q. In other depositions, okay, I thought
7 benefit-to-cost ratio or whatever criteria was 7 that I understood the testimony to be that
8 used, there was no -- there was no 8 there was a different track chosen for the
9 justification for that -- for using that as the 9 lakefront area, if you will --
10 design hurricane; therefore, something 10 A. Correct.
11 different was used which was actually a 11 Q. -- than there was for the Chalmette
12 smaller -- what I would call a smaller type 12 area --
13 storm. 13 A. Correct.
14 Q. That's fair. I'm just trying to 14 Q. -- which would necessitate a different
15 figure out what comes first. Which of the two 15 calculation of the standard project hurricane.
16 is born first, the design hurricane or the 16 A. That's a good way to put it. But the
17 standard project hurricane? 17 standard project hurricane --
18 A. In our analysis -- 18 Q. It's the same --
19 Q. Back then. Okay? 19 A. It's --
20 A. In the analysis, the standard project 20 Q. -- wind speed, it's the same
21 hurricane was looked at. It became, in the 21 pressure --
22 case of Lake Pontchartrain and Vicinity the 22 A. It's in all likelihood the same wind
23 design hurricane because they could justify it. 23 speed and same pressure, but it may be a
24 Q. Okay. Well, at least as regards the 24 different forward speed.
25 Lake Pontchartrain -- and let's be specific to 25 Q. Okay.
24 (Pages 90 to 93)
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Page 94 Page 96
1 A. I'd have to go back through each 1 A. Correct.
2 individual document, but that's all summarized 2 Q. And the still water height for the
3 in the IPET. 3 Citrus back levee is a different number.
4 Q. Well, you got me a little confused 4 A. (Nods affirmatively.)
5 because I thought it was established in other 5 Q. True?
6 depositions that at the end of the day when you 6 A. True.
7 made your determination of the standard project 7 Q. Okay. Although, and you may correct
8 hurricane, in this case the design hurricane, 8 me if I'm wrong, the storm track used for the
9 you ended up with a still water height. 9 MRGO/Chalmette area is the same storm track
10 A. Correct. 10 used for the southern border of New Orleans
11 Q. But that still water height is not the 11 East.
12 same for all locations in the system. 12 A. Okay. New Orleans -- I'm looking at
13 A. Correct. 13 Page 28 of Exhibit 32 --
14 Q. Therefore, one would logically 14 Q. That's why I piled up all those
15 conclude, I think, that you were having 15 documents in front of you.
16 different standard project hurricanes depending 16 A. -- and Page 6 of Exhibit 30 --
17 upon where you were in the system. So, in 17 Exhibit 32 on Page 28, the design hurricane
18 fact, it's got to be a different standard 18 characteristics, um --
19 project hurricane based upon geography, does it 19 Q. Let me just catch up to you. Page 32?
20 not? 20 Oh, Page 6 you said?
21 A. I think it goes back to how I define 21 A. I'm sorry. Exhibit 32, it's going to
22 standard project hurricane and how you're 22 be Page 28. That is the Lake Pontchartrain
23 defining standard project hurricane. We're 23 Louisiana Vicinity, the DM Number 1, Chalmette.
24 doing it a little bit different. I think we're 24 That's where the New Orleans East back levee
25 reaching the same point, but I'm using a little 25 is.
Page 95 Page 97
1 bit different semantics. You know, I use the 1 Q. All right. Well, in any case, you've
2 definition of standard project hurricane that's 2 got it. Just tell me what the answer is.
3 in these documents -- 3 A. Okay. And I apologize, I'm really
4 Q. Right. 4 actually looking at Page 4 of Exhibit 30 and
5 A. -- which is just simply a hurricane 5 comparing that to Page 28 of Exhibit 32.
6 that may be expected from the most severe 6 Q. Okay. I'm with you. I see Page 28,
7 combination of meteorological conditions that 7 design hurricane characteristics, Lake Borgne
8 are considered characteristics of the region 8 area of New Orleans East, Citrus and
9 involved. So that's -- 9 Chalmette --
10 Q. But it's the region involved -- 10 A. Uh-huh.
11 A. I have that plus the track that's 11 Q. -- and, um -- looks to me like they're
12 critical to my region gives me -- and the tidal 12 all the same.
13 characteristics of that area -- 13 A. Right. So from that I would conclude
14 Q. Okay. 14 that the design hurricane for the MRGO reach
15 A. -- ultimately give me the still water 15 and for the New Orleans back levee reach are
16 level that I'm going to use for design. So I'm 16 the same. They're the same CPI, same maximum
17 agreeing with you only because we're just 17 winds, same radius of maximum winds, same
18 dealing with semantics right now. 18 forward speed, direction of approach and track.
19 Q. Okay. Well, in point of fact, though, 19 Q. Okay. All right.
20 the still water height for the MRGO reach was 20 (Lunch break.)
21 X, the still water height for the lakefront was 21 EXAMINATION BY MR. BRUNO:
22 a different number. 22 Q. Okay. Ms. Powell, we were chatting
23 A. Correct. 23 about design hurricane and standard project
24 Q. The still water height for the back 24 hurricane. If you look at the interim report
25 levee is a different number. Right? 25 for the Lake Pontchartrain, Louisiana and
25 (Pages 94 to 97)
10/3/2008
Page 98 Page 100
1 Vicinity project, at Page IX, you'll see 1 elevation that's due to the presence of waves.
2 there's a glossary and I forgot the exhibit 2 It's not the wave height but it's a piece of
3 number. Why don't you help me there. What did 3 the surge elevation that occurs because there
4 we put on there, 26? 4 are waves there.
5 A. 26. 5 Q. Okay. So what is buildup, then, if
6 Q. Let me mark mine so that we will know. 6 you know?
7 All right. We have a definition of 7 A. As the glossary says, it would be
8 both the design hurricane and standard project 8 something that would build up, um -- if there
9 hurricane. You see that? 9 was in fact a barrier or a change in width or
10 A. Yes. 10 depth. That would be the incremental increase
11 Q. Okay. And the design hurricane, is 11 in water level due to those factors.
12 that hurricane selected by the reporting office 12 Q. Would you consider that the water that
13 as the basis for the design of the proposed 13 would be pushed into what many regard or call
14 plan of improvements, whereas the standard 14 the funnel to be build up?
15 project hurricane is a hurricane that may be 15 MR. SMITH:
16 expected from the most severe combination of 16 Objection. Vague.
17 meteorological conditions that are considered 17 EXAMINATION BY MR. BRUNO:
18 characteristic of the region involved. Right? 18 Q. Is that the kind of thing that's
19 A. That's correct. 19 described?
20 Q. All right. Can I gather from that 20 A. Well, again, the buildup is just
21 that the process then -- obviously, since one 21 incremental increase.
22 is selected, that the process requires that the 22 Q. Right.
23 standard project hurricane be developed first? 23 A. So due to the presence of the
24 A. Based on what I've read of the 24 levees --
25 documents, that would be a true statement. 25 Q. Right. That's what I'm saying, the
Page 99 Page 101
1 That was done first. 1 funnel. Let me be specific about the funnel
2 Q. Okay. All right. Now, what is a 2 for the record.
3 probable maximum hurricane? 3 A. Yeah.
4 A. According to the definition, that's a 4 Q. I'm taking about what the pundits and
5 hurricane that may be expected from the most 5 many others have described, in fact, the Corps
6 severe combination of meteorological conditions 6 documents themselves talk about this funnel, to
7 that are reasonably possible in the region. 7 be the place where the Intracoastal Waterway
8 Q. So the distinction is possible versus 8 northern levees converge with what we call
9 characteristic? 9 Reach 1 of the MRGO channel, and then on the
10 A. Correct. 10 south the MRGO levee along Reach 2, where those
11 Q. And just while we're here, buildup 11 two things converge. So you have two
12 refers to increase in the water surface 12 structures there, you have a levee on the
13 elevation, and I think that may also be 13 Intracoastal Waterway and you have a levee on
14 referred to as wave buildup? Is that right? 14 the MRGO. So if there was an increase in water
15 Or wave propagation. 15 that resulted from the movement of water into
16 A. There are separate wave definitions in 16 that throat, if you will, would that be called
17 the glossary, so I'm going to conclude that 17 buildup?
18 buildup does not apply to waves. There's a 18 A. I would define the buildup as that
19 definition called wave set-up. 19 incremental increase in water level due to the
20 Q. Right. Uh-huh. 20 presence of those levees forming that
21 A. Which is, um -- a little bit further 21 constriction, yeah.
22 in the glossary that talks about the elevation 22 Q. Okay. So that the water comes in at a
23 of the water surface above the hurricane tide 23 certain height and the extent to which there is
24 height due to the wave action alone. It's a 24 any difference in height as it moves through,
25 component of what I would call the surge 25 that's the buildup; it's the difference between
26 (Pages 98 to 101)
10/3/2008
Page 102 Page 104
1 the two. 1 mandate, and then the report is a result of
2 A. In this case, with the presence of the 2 that mandate.
3 levees, the buildup would be the difference 3 Q. Okay. I want to limit our discussion
4 between the two water levels. 4 to the Chalmette area, first of all, so we
5 Q. Okay. I got you. All right. Now, 5 don't have to cover so much ground. But what
6 the Congress of the United States authorized 6 is it, if you know, is the first step in the
7 the Corps to begin a study or to do a survey 7 process toward responding to this mandate of
8 for hurricane protection in the Lake 8 Congress as it relates to the Chalmette area?
9 Pontchartrain and Vicinity area in -- let's see 9 A. I can only talk about what I would do
10 what the date of this is, June of 1955. 10 as a hydraulic engineer in response to this
11 That sound right? I'm looking at 11 directive.
12 Page 1 of the report. 12 Q. Okay.
13 A. In Section 1A -- 13 A. Which would be to look at the factors
14 Q. Authority. 14 you talked about, look at, you know, acquiring
15 A. -- it says, approved 15 July 19 -- 15 15 data on the behavior and frequency of
16 June, excuse me, 1955, yeah. 16 hurricanes, um -- the determination of methods
17 Q. All right. And essentially, this gave 17 of forecasting the paths, improving warning
18 the Corps permission to begin the I guess what 18 systems of looking at different -- I'm sorry --
19 today you would call a reconnaisance report. 19 of looking at the standard project hurricane,
20 Is that right? I may have that wrong. 20 which was the --
21 A. No, I would interpret this sentence as 21 Q. Right. Yeah.
22 saying to start a reconnaisance study. 22 A. -- the means that we would be
23 Q. Okay. And obviously, based upon our 23 evaluating this.
24 review of the document itself, back then they 24 Q. All right. I'm just trying to figure
25 called this a survey, it looks like. If you 25 out how to connect the dot between this mandate
Page 103 Page 105
1 look at Page 2 at the top, such survey to be 1 and the standard project hurricane. The
2 made, et cetera, et cetera. 2 mandate seems to say go out and, you know,
3 A. Uh-huh. 3 evaluate hurricane protection.
4 Q. Is that a fair conclusion? 4 A. Uh-huh.
5 A. Yeah. Because this is an interim 5 Q. And then we see at Page 24 that --
6 survey report, yes, that they are directing the 6 this thing called a standard project hurricane.
7 Corps to do. 7 A. Uh-huh.
8 Q. Okay. Now -- 8 Q. Can you explain for us how you get
9 A. A survey. 9 from the mandate to standard project hurricane?
10 Q. -- let's see what they were authorized 10 Is that something in the Corps' procedures and
11 to do. So they're to include the securing of 11 practices or --
12 data on the behavior and frequency of 12 A. Um -- I believe that at the time this
13 hurricanes and the determination of methods of 13 would have been a standard practice of the
14 forecasting their paths and improving warning 14 Corps of Engineers as defined in its
15 services and, if possible, means of preventing 15 engineering regulations and manuals --
16 loss of human lives and damages to property 16 Q. Okay.
17 with due consideration of the economics of 17 A. -- that the Corps would look at a
18 proposed breakwaters, seawalls, dikes, dams and 18 standard project hurricane and possibly the
19 other structures, warning services or other 19 probable maximum hurricane as possible design
20 measures which may be required. 20 hurricanes and base their hydraulics and
21 Is this interim report the survey 21 analysis on those hurricanes.
22 report that we're reading from that responds to 22 Q. Okay.
23 this mandate? 23 A. That would not be in this document, it
24 A. That's normally how these documents 24 would be another document that would -- in
25 are put together. It will describe the 25 either a manual or a regulation that said, when
27 (Pages 102 to 105)
10/3/2008
Page 106 Page 108
1 you do this type of study look at the standard 1 in some areas if it's a slow moving forward
2 project hurricane. 2 speed that might create a higher surge than a
3 Q. That's fine. I just want us to 3 faster storm.
4 conclude with an understanding that the mandate 4 Q. Uh-huh.
5 of Congress is what gave the Corps the 5 A. So you're going to look at those types
6 authority to start the process. 6 of combinations. And that's why you end up
7 A. Uh-huh. Yes. 7 with some of those areas having different
8 Q. And one of the first things that the 8 critical tracks, some of them having different
9 Corps did was to evaluate the standard project 9 forward speeds.
10 hurricane for the Chalmette area. I mean, 10 Q. Okay. So what comes first, the
11 again, I only say that because I'm eliminating 11 reasonably characteristic or the severity?
12 the other areas from our discussions right now. 12 A. Based on the process, to me it appears
13 Okay? Is that fair? 13 that the reasonably characteristic comes first.
14 A. That's fair. They looked at all the 14 Q. Okay.
15 storms, the historical storms in context also. 15 A. And then you look at how to combine
16 But the design and analysis -- preliminary 16 them.
17 design and analysis of which the economic 17 Q. Sure. All right.
18 analysis is based was done on the standard 18 A. And that's because the central
19 project hurricane. 19 pressure and the wind velocity and the 30
20 Q. All right. Now, it says here at 20 nautical miles are set, and then you look at
21 Page 24 that the standard project hurricane is 21 the critical track, then you look at the
22 one that may be expected from the most severe 22 forward speeds.
23 combination of meteorological conditions that 23 Q. All right. To better enable us to
24 are considered reasonably characteristic of the 24 understand what it is that we're reaching for,
25 region. Can you help me understand first of 25 at the end of the day when we have computed
Page 107 Page 109
1 all what the reference to most severe 1 whatever it is that the standard project
2 combination is? 2 hurricane is, how is it described?
3 A. I might be able to give you a little 3 First of all, are there numbers used?
4 bit of an example. Um -- when we looked at the 4 And if so, what measures are utilized to
5 standard project hurricane there were different 5 describe the standard project hurricane?
6 what they call translation speeds and different 6 A. Okay, as I understand the question,
7 rates of hurricane forward movement that were 7 and you can let me know if I've understood this
8 studied, forward speed. 8 correctly, the standard project hurricane is
9 Q. Uh-huh. 9 described as a central pressure index, and in
10 A. So the combination that would give you 10 this case it's 27.6 inches, a maximum wind
11 what they call the most severe combination, 11 velocity of 100 miles per hour at a radius of
12 that's reasonably characteristic. 12 30 nautical miles.
13 Q. Right. 13 Q. Okay. So it sounds like two
14 A. In a lot of cases the slower forward 14 parameters that they've chosen to use to
15 speed was selected because it gave you, um -- 15 describe at least this hurricane, the central
16 the condition that was reasonably 16 pressure and wind velocity at a certain
17 characteristic. And that was the more severe 17 distance from the eye.
18 condition. 18 A. Correct.
19 Q. Okay. 19 Q. Okay. Does that sound right? Does
20 A. In some cases on hurricanes, depending 20 that look like the two descriptors?
21 here again on track, because also the most 21 A. Right. And then you combine that with
22 severe combination is what is the critical 22 the forward sped and the track.
23 track? That's another way of defining that 23 Q. Okay.
24 term. But it's that combination of those 24 A. And the angle, because you ultimately
25 things. And what I was trying to say was that 25 have to calculate the water level.
28 (Pages 106 to 109)
10/3/2008
Page 110 Page 112
1 Q. Okay. So the standard project 1 than that time frame. Right?
2 hurricane has 1, a central pressure; 2, a 2 A. Yes, certainly there were more
3 maximum mall wind velocity at a radius of 30 3 tropical storms and hurricanes --
4 miles? 4 Q. Sure.
5 A. 30 nautical miles. 5 A. -- that occurred during that time
6 Q. 30 nautical miles; it has a track, a 6 frame.
7 certain -- 7 Q. Right. And all this leading up to
8 A. A critical track to the area of 8 this question: Well, first of all, am I right,
9 interest, yes. 9 did the analysis for the standard project
10 Q. A critical track, okay. That's 10 hurricane for the Lake Pontchartrain and
11 important to make the distinction. A critical 11 Vicinity area, was it in fact limited
12 track to the area of interest; and finally it 12 temporally in any way?
13 has -- what's the last thing? 13 A. My answer to your question, as I
14 A. The forward speed. 14 understand it, is yes, because the weather
15 Q. Forward speed, okay. 15 service looked at the Gulf Coast and divided it
16 A. And the track really defines your 16 into three zones, and our zone happens to be
17 direction of approach. 17 Zone B. So it's only the storms that were
18 Q. All right. So we look at past 18 within Zone B that were considered in the
19 hurricanes in order to make an assessment of 19 development of the standard project hurricane
20 what numbers, frankly, should be put into each 20 that was ultimately used for the Lake
21 of those four categories. Is that accurate? 21 Pontchartrain and Vicinity project.
22 Except for the track, which is a line. 22 Q. Okay. And do you know how that --
23 A. That was done. 23 let's establish first whether I'm right about
24 Q. That's the way they did it. And they 24 the 1901 to 1957 --
25 relied on the weather service data as to these 25 A. The Exhibit 25, Page 3, talks about a
Page 111 Page 113
1 previous hurricanes, and I think I've marked 1 record was made of all tropical storms 1900 to
2 that already for you somewhere. 2 1956 that passed through each zone and had at
3 A. If you'd go back -- 3 any time been of hurricane intensity.
4 Q. Somewhere in that big stack. 4 Q. I'm sorry. Where are you reading
5 A. -- to Exhibit 25, Report Number 33 5 from?
6 that the weather service put out, that's how 6 A. This is on Page 3.
7 the standard project hurricane indices are 7 Q. Of the same document?
8 defined. 8 A. Of Exhibit 25, the same document.
9 Q. And that is the National Hurricane 9 Q. Okay.
10 Research Project. 10 A. The -- it's the beginning of the
11 A. Correct. 11 discussion on --
12 Q. Okay. 12 Q. Got you.
13 A. Exhibit 25. 13 A. -- the central pressure index.
14 Q. And that is simply a description of 14 Q. Okay.
15 all the hurricanes that occurred for which they 15 A. And there's -- the first full sentence
16 have data, right? 16 on Page 3 indicates a record was made of all
17 A. It's a description of the hurricanes 17 tropical storms from 1900 to 1956 that passed
18 that were considered in development of the 18 through each zone and had at any time been of
19 standard project hurricane. And. 19 hurricane intensity.
20 Q. Well, they didn't consider them all, 20 Q. All right. So that the limitation
21 right? They limited themselves from 1901 to 19 21 discussed in some of the other -- the IPET
22 I think it's '56 or '57, I don't remember 22 documents, among others, was not a limitation
23 which, but it's in this document. And that's 23 that the Corps established, that was a
24 why I asked you to look at this document, 24 limitation that occurred as a result of the
25 because this document has more hurricanes in it 25 National Hurricane Research Project. Isn't
29 (Pages 110 to 113)
10/3/2008
Page 114 Page 116
1 that true? 1 Q. Oh, it doesn't start there?
2 A. The hurricane research project, the 2 A. Um -- the actual description of the
3 weather bureau, which is now the National 3 process starts on Page 3. The table of
4 Weather Service, is the ones that performed the 4 hurricanes that are listed is in Table A of the
5 study and selected the storms. 5 appendix, which is Page 73.
6 Q. Okay. All right. So then, the next 6 Q. Okay. So it says, um -- a record was
7 process was to select those storms that had 7 made of all the tropical storms from 1900 to
8 relevance to the Chalmette area, correct? Or 8 1956 that passed through each zone and had at
9 am I getting ahead of myself? Did they first 9 any time been at hurricane intensity, and it
10 establish the central pressure and the wind 10 says a notation was made for the period from
11 speed -- 11 1900 to 1956 of the CPI whenever it was
12 A. No, the storms were of relevance to 12 estimated to be less than 29 inches in any of
13 Zone B which Chalmette is contained within, but 13 the zones listed in Table A of the appendix.
14 it was the whole entire Zone B. 14 All right. So that takes us to this chart at
15 Q. Okay. So it's not -- the track was 15 Page 73. All right. And this is list of all
16 not one of the first things, in the order of 16 the hurricanes. Let's see. Is it broken down
17 importance that was more toward the end. First 17 by three zones? I see zone and then a blank.
18 thing was to kind of get a sense of what the 18 I see Zone B and a Zone C.
19 central pressure was, wind speeds and forward 19 A. Yeah. The zone blank is Zone A. And
20 track. 20 Zone B, Zone C. I think it is. Let me see.
21 A. Radius to maximal winds. It would 21 Yeah. It looks like it's.
22 have been the three parameters we previously 22 Q. Yeah. Zone B is what's shown on that
23 discussed; the central pressure index, the 23 little diagram we just looked at.
24 maximum winds, and the radius of maximum wind. 24 A. Yeah. I'm not quite sure what zone it
25 Those would be the first three parameters that 25 is, but the pertinent section is the one that
Page 115 Page 117
1 were looked at. 1 says Zone B.
2 Q. All right. And from that evaluation 2 Q. All right. So how do we go about the
3 came the selection of the standard project 3 process of figuring this out? Do we simply
4 hurricane pressure, forward track and wind 4 average the central pressure index, or --
5 speed at 30 nautical miles that you referenced 5 A. No, that's why I go back to Page 3.
6 just a few moments ago. Those numbers. 6 Page 3 describes the process that was done and
7 A. Again, the three parameters, the 7 notes how that central pressure was determined.
8 central pressure index, the maximum wind and 8 And then there was a -- there was analysis done
9 the radius to maximum winds. 9 that is described as occurrences per hundred
10 Q. Okay. All right. And do you know how 10 years, profiles of variations of average
11 they came to those numbers? 11 frequency of CPI occurrences on a 100-year
12 A. Only through what's documented in your 12 basis, and they were calculated and they're
13 Exhibit 25. 13 shown on Figure 15.
14 Q. Okay. We have a section that will 14 Q. It says that the plot was made of
15 indicate for us all the hurricanes and all the 15 storms in which the particular CPI was equal to
16 numbers? That's east coast. It's break broken 16 or less than the other CPI values. Do you know
17 down by sections, as you pointed out. 17 what that means? This is still at Page 3,
18 All right. Page 31, does that look 18 second -- first full paragraph entitled
19 like where it begins, Gulf Coast zones? 19 cumulative percent of occurrences.
20 A. Um -- it's in several places through 20 A. Okay. Back to Figure 12. Okay. They
21 here. Let me go to Page 31. 21 did a cumulative number of occurrences, so
22 Q. The first part seems to be the east 22 you're accumulating -- you essentially ranked
23 coast. 23 all the central pressure indexes from low to
24 A. You're just referring to Figure 11 is 24 high or high to low, it doesn't quite --
25 on Page 31. 25 Q. It's at Page 32, right?
30 (Pages 114 to 117)
10/3/2008
Page 118 Page 120
1 A. That's the resultant of what was done. 1 number of the event, the rank, Y is the number
2 First off they ranked the zones, and then they 2 of years of record, which is 57, which is from
3 did a, um -- they wanted to show that, you 3 1900 to 1956. That's 57 years.
4 know, in the particular example that they talk 4 Q. Oh, I see. And then once you get the
5 about, in Zone 1 there was one hurricane with a 5 P, then what do you do?
6 CPI of 26.35, and then there were seven 6 A. The P is the percent chance of
7 hurricanes with 28 inches or lower. So they're 7 occurrence per year, and you're are looking at
8 accumulating how many of these hurricanes have 8 the -- let's see. I'm looking to confirm my
9 a central pressure less than 26, how many have 9 understanding of this. We actually end up with
10 a central pressure less than 28, how many have 10 27.6? We end up with the central pressure that
11 a central pressure less than 29 inches. 11 has one occurrence per 100 years in the New
12 Q. All right. 12 Orleans area within Zone B.
13 A. And that's basically what that curve 13 Q. Okay. And that's how we got to 27.6.
14 on Figure 12 represents for the gulf area. 14 A. That's how you get to 27.6.
15 Q. Does the central pressure relate to 15 Q. All right. And then the next thing we
16 the severity of a hurricane? 16 do is we determine the wind speed?
17 A. Um -- we'd have to define severity. 17 A. Actually, they did the radius to
18 But the central pressure is a parameter that's 18 maximum winds second.
19 used to describe hurricanes. 19 Q. Okay. And how did they do that?
20 Q. Right. Well, I'm using severe in the 20 A. Again, they looked at the historical
21 same context that the standard project 21 sizes of hurricanes, you know, measured what's
22 hurricane is used. Okay? 22 called the R max in nautical miles, plotted
23 A. Yeah. 23 those, and you can see on Page 17 they plotted
24 Q. It does say most severe, so whatever 24 it against the central pressure index --
25 that word means in that context. 25 Q. Okay.
Page 119 Page 121
1 A. Yeah. It's one of the parameters 1 A. -- identifying, you know, here again
2 that's used to help define the standard project 2 from the historical storms, what storms were in
3 hurricane, so. 3 Zone A, what storms I were in Zone B and what
4 Q. All right. So is the lower the number 4 storms were in Zone C. So we're looking for,
5 more severe or the higher the number more 5 on Page 37, figure 17, the little triangles are
6 severe? 6 the storms that are in Zone B. And there was
7 A. The lower, in this case. 7 some determination of what they called small
8 Q. The lower. Okay. So we have a range 8 radius storms, mean radius storms, large radius
9 here it looks like from about 29 to about, say, 9 storms. They did envelopes that kind of
10 27 and, I don't know, roughly three quarters or 10 bracket the data that's available, and from
11 something. So once we've got this nice chart, 11 this --
12 how do we select our central pressure index? 12 Q. So, let's see. Zone B is little
13 A. To get to the central pressure index 13 triangles.
14 that is selected for the SPH, you look at the 14 A. Uh-huh.
15 occurrences per 100 years. And that's going -- 15 Q. And, um -- if we go to what, 26 to 27?
16 and you start with your cumulative number of 16 A. 27.6.
17 occurrences. 17 Q. So we find that on the chart, roughly,
18 Q. Right. 18 and then we move to the right until we
19 A. But you end up -- there is an equation 19 intersect with a triangle?
20 here that they show on Page 3. 20 A. Well, I think they believed that it
21 Q. Okay. P is for percent chance of 21 was somewhere in that envelope and they went
22 occurrence per year. 22 ahead, to be conservative, and to use the most
23 A. Correct. 23 severe combination, used the upper envelope of
24 Q. Do you know how that is calculated? 24 the large radius storms. Because you go in
25 A. Just by that equation. M is the 25 this figure, about 27.6 central pressure, the
31 (Pages 118 to 121)
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Page 122 Page 124
1 30 nautical mile radius to maximum winds is on 1 Q. Okay. So what we have, the percentage
2 the large radius envelope on the most severe 2 distribution of rate of hurricane center
3 side of that envelope. 3 translation for the Gulf Coast. So it looks
4 Q. Right. 4 like we have a range, and the ranges are
5 A. And that 30 nautical miles radius to 5 plotted based upon the cumulative percentage of
6 maximum winds was the selected design 6 occurrences as compared to the forward speed.
7 parameter. 7 Does that make sense?
8 Q. Okay. And that gets you to the 90 8 A. Yeah.
9 miles per hour? I'm sorry. No, that's just 9 Q. Okay. So which one do they pick?
10 radius. 10 A. Um -- for the Chalmette area, the
11 A. That's your radius to maximum winds. 11 forward speed of 11 knots was selected.
12 Q. All right. So we have a large radius 12 Q. And that appears to be simply because
13 storm, so we have to go from there to some kind 13 the largest cumulative percentage of
14 of a wind sped at 30 miles -- 30 nautical 14 occurrences falls about right there, at 11. Is
15 miles. How do we do that? 15 that right?
16 A. Okay, that's going to be on Page 7, 16 A. I would say about 50 percent of the
17 the winds. That's going to be associated with 17 occurrence falls about 11.
18 the central pressure and the radius to maximum 18 Q. Right.
19 winds. There's some equations in there that 19 A. So again, it was selected -- the
20 are used to calculate the maximum gradient 20 forward speed was selected as what would be
21 wind, and then from that calculate the what's 21 most critical to the Chalmette area. And they
22 called the maximum 30 foot over water wind 22 selected the 11 knots forward speed, whereas
23 speed. 23 for example the north shore of Lake
24 Q. Okay. It's a calculated number. 24 Pontchartrain, a translation speed of 5 knots
25 A. It's a calculated number. 25 was selected. So here again, although this
Page 123 Page 125
1 Q. All right. And we got to -- what 1 information was available there was a
2 number did we end up with? 2 determination of what would be more critical to
3 A. 100 miles per hour. 3 the particular area.
4 Q. 100 miles per hour. Okay. So then 4 Q. Right.
5 the next thing we have to do is develop a 5 A. And therefore, you end up with
6 determination of its forward speed. And how do 6 different pieces of the Lake Pontchartrain and
7 we do that? 7 Vicinity project having different forward
8 A. Okay. That was done in a manner that 8 speeds. Looking at what's most critical to the
9 I would say is similar to what they did with 9 Chalmette area.
10 the radius to maximum winds, um -- looking at 10 Q. And this is Gulf Coast. This is the
11 the forward speeds of the historical storms -- 11 entire gulf coast. This is all three zones.
12 Q. Okay. 12 A. Yeah.
13 A. -- on Page 29. 13 Q. Okay. All right. I'm just trying to
14 Q. Yes. 14 understand these little dots. There's the one
15 A. Again, you're look at some of the 15 dot obviously is not 100 percent of all
16 historical information, geographically, on the 16 occurrences. Do you know what the little dots
17 X axis and forward speed on the Y axis, and you 17 mean in that crosshatch?
18 had different envelopes of speed. 18 A. You got me. I'm not quite sure what
19 Q. Now, this is referring the Zone 1, 2, 19 the dots mean. Because I'm rereading Page 5.
20 3 and 4, which is the east coast. 20 Q. All right. That's fine. Bottom line
21 A. Right. There should be a similar -- 21 is, we agree that 11 knots is a moderately fast
22 Q. Is Chart 1 for the -- 22 hurricane. I shouldn't even say moderately
23 A. I would hope there's a similar one in 23 fast. It's a moderate speed. It's not fast
24 here for -- Figure 20. They did it a little 24 and it's not slow. It's in the middle.
25 bit differently for the Gulf Coast. 25 A. There were three categories defined by
32 (Pages 122 to 125)
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Page 126 Page 128
1 the weather service, a representative low 1 2:00 o'clock in the afternoon.
2 speed, a representative moderate speed and 2 Q. Oh. I'm sorry. You're right. 28
3 representative high speed, and the 11 knots was 3 September to October 1, 1915, all within 1915.
4 the representative moderate speed and that was 4 Okay.
5 selected as one of the parameters critical to 5 A. This is one hurricane.
6 the Chalmette area at that speed. 6 Q. I got you. And then A4 is another
7 Q. Okay. All right. So all we have left 7 one?
8 now is the track. Right? 8 A. Plate A4 is the 1947 hurricane. And
9 A. Correct. 9 it's snapshots of the wind velocity over time.
10 Q. Okay. So how do we do that? I'm 10 Q. Right. And then A5 is the standard
11 thinking that's the place to go. I'm just 11 project hurricane.
12 guessing. I don't know as much as you. 12 A. Correct.
13 A. No, that's a good place to go back to, 13 Q. So if you look at -- looks to me like
14 which is the plate -- 14 they looked at -- if you look at Plate A7, they
15 Q. Which Plate A7 which describes the 15 looked at 1909, 1915, 1901, 1947, 1893 and
16 Track A, the Track C, and -- and the Track F. 16 1956. Okay. So, how do they pick the track
17 A. Correct. 17 for Chalmette?
18 Q. And we know Track F is what they 18 A. They would have looked at the wind
19 ultimately selected, I think. 19 patterns that would be associated with the
20 A. Yes. Track F was the selected track. 20 historical tracks or a modification of those
21 Q. And so we have this map at Page -- 21 historical tracks, and using knowledge of
22 well, I don't see a page number, but it's just 22 hurricanes at that time looking at, okay, if I
23 simply -- if we start at -- looks like Plate A3 23 have my hurricane on Track C, for example, is
24 is where they start the little drawings of the 24 that going to give me the critical parameters,
25 maps. I'm going back to the interim report, 25 you know, at my area of interest? And maybe
Page 127 Page 129
1 Exhibit 26. 1 the answer is no. Let me go look at a Track C
2 A. Okay. 2 that might be shifted over or look at the 1947
3 Q. All right? 3 hurricane or go look at the 1893 hurricane.
4 A. That's just one of the historical 4 But it's the knowledge of how the surge -- the
5 hurricanes, it's not the standard project 5 hurricane winds, with the counterclockwise
6 hurricane. 6 movement, how the surge would occur, you know,
7 Q. I realize that. But what is an 7 either on the front side of the storm or the
8 isovel, if I'm saying that right, pattern? 8 backside of the storm, understanding those
9 A. Isovel? 9 processes and the general physics of the storm
10 Q. Isovel. 10 they would go look and say, okay, this storm
11 A. That's a line of equal velocity. 11 track is more critical to my area of interest
12 Q. And the velocity refers to the forward 12 than another track.
13 movement of the storm? 13 Q. Okay. So does that mean I'm looking
14 A. In this particular case, it refers to 14 at history to figure out which storm put the
15 the average wind velocity. 15 highest amount of surge in Chalmette, or at
16 Q. As it moves along a path? 16 least the Chalmette area?
17 A. Yeah. Because you get snapshots as it 17 A. I'm considering history, but I may
18 moves along the path. These are time snapshots 18 find in my analysis that a track that's
19 of the velocities as the hurricane moves 19 slightly different would give me a different
20 through that path, yes. 20 result. In this particular case, for
21 Q. Okay. It says, hurricane of 28 21 Chalmette, Track F was selected, which mimicked
22 September to 1 October 1915. So this is just a 22 the 1947 hurricane. But in another case, for
23 bunch of different hurricanes. 23 example, Track C that you can see on plate A7
24 A. This is one hurricane in time. This 24 is similar to 1909 but maybe not exactly like
25 is a sequence. The first plot up here is at 25 the 1909 hurricane.
33 (Pages 126 to 129)
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1 Q. Right. 1 equation that was used to represent -- the
2 A. Here again, using the knowledge of, 2 calculate surge.
3 you know, how the winds in a hurricane work and 3 Q. All right. Well, it says that in
4 how surge propagates on the front side and back 4 order to reach agreement between computed
5 side of storms, the decisions in some cases 5 maximum surge height and observed water marks.
6 mimicked a historical hurricane and in other 6 So clearly they were trying to determine
7 cases were similar but somewhat different. 7 whether they could replicate what was observed.
8 Q. Okay. Well, but I'm just trying to 8 A. They used historical storms to help
9 figure out, what is the parameter that we 9 calibrate this equation.
10 looked at to determine what it is that we're 10 Q. Right. And all -- that's what I
11 picking? Is it -- 11 want -- there was a need, obviously, to make
12 A. They may have actually made some 12 this equation fit within the real world, and so
13 calculation along the historical tracks to see 13 there was a need to calibrate, right?
14 what was the resultant surge in that area and 14 A. Right. As with any kind of model, you
15 may have looked at -- 15 calibrate.
16 Q. Let's do it this way: Can we agree 16 Q. Well, sure. And so what I'm trying to
17 that it was the surge characteristic that was 17 reach out to first, before we get to the
18 at least one of the important factors that went 18 equation, is these observed high water marks.
19 into the selection of a particular track? 19 These observed high water marks come from a
20 A. The surge meaning the resultant of the 20 particular hurricane, I would imagine.
21 characteristics that they were picking, yes, 21 A. Yes.
22 because they wanted to see what track would 22 Q. All right. And I would -- and am I
23 give me the most critical parameters reasonably 23 correct in assuming it would be the highest
24 characteristic of my area. 24 surge experienced in a particular area, in this
25 Q. I guess what I'm trying to figure out 25 case Chalmette, from those historical storms?
Page 131 Page 133
1 is how do you go about the business of 1 A. I don't know that it was the highest
2 determining how much surge a particular 2 for those storms. I can check real quick.
3 hurricane will create and, to be specific, to 3 But, you know, you calibrate to known data.
4 the Chalmette area? Is that based upon history 4 Q. Right. If you look at is it A11,
5 or is that based upon some scientific 5 hurricane surge heights, observed, computed,
6 calculations? 6 there is an observed number and a computed
7 A. There was a scientific calculation 7 number? Does that help us? You see A17?
8 made. 8 A. Oh, table?
9 Q. All right. How do you do that? 9 Q. You see that?
10 A. Let me get you there so you can follow 10 A. Yeah.
11 along. Okay. If you want to start on Page A16 11 Q. There is an observation?
12 of the Exhibit 26 -- 12 A. Uh-huh.
13 Q. Is that the interim? 13 Q. In 1915 and 1947.
14 A. Yes. 14 A. Right.
15 Q. Okay. A16. I'm with you. 15 (Off the record.)
16 A. Are you on Page A -- Page A16, not 16 EXAMINATION BY MR. BRUNO:
17 Plate. 17 Q. All right. If we look at Page A17 and
18 Q. Oh. Page A16. 18 A18, it seems like we got these verification of
19 A. It's going to look like this. 19 surge heights. And by now, based upon our
20 (Indicating.) 20 other charts we know we're looking only at the
21 Q. Got it. 21 1915, the 1947 and the 1956 storms, because
22 A. Okay. Down toward the bottom of the 22 those are the ones that most closely mimic our
23 page you'll see there there is an equation. 23 tracks, right?
24 Q. Okay. 24 A. Yeah. A better table would be the
25 A. And this is the general storm tide 25 actual -- for the Chalmette area is in
34 (Pages 130 to 133)
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Page 134 Page 136
1 Exhibit 32. But that's what I was looking, to 1 pressure index and the maximum wind at the
2 make sure I had that one, too. But the method 2 radius, they were close, but it looks like
3 was the same. 3 Betsy was a little faster storm.
4 Q. What page are you on? 4 A. Correct.
5 A. I'm starting on Page 20 and 21. 5 Q. And we still have a moderately -- I
6 Q. Okay. 6 hate to use the word moderately fast. Moderate
7 A. It follows in the same format as where 7 speed, how about that, storm. Right?
8 you were on the original, but this really is 8 A. The forward speed, yeah.
9 specific to the Chalmette area. 9 Q. Okay. All right. And the observed
10 Q. Okay. And they look at all three 10 surge levels at Shell Beach are indicated, for
11 storms, the 1915, the '47 and the '56. Do we 11 the September 1915 storm, 8.3 feet; '47,
12 know why they chose those three storms for this 12 11.2 feet; 10.9 feet, September '56. We know
13 evaluation? It doesn't seem like this was the 13 where Shell Beach is. Violet is interior,
14 result of a track analysis, this was more the 14 isn't it? Is that -- closer to the river,
15 result of something else. 15 midway between -- maybe not midway, but it's
16 A. I don't believe they indicate why they 16 closer to the river. Do they mean --
17 only chose those three. They did continue the 17 A. They mean the community of Violet,
18 analysis to look at how the equations worked 18 yeah.
19 with Hurricane Betsy. No, they don't mention 19 Q. The community of Violet. So at that
20 why they only use two observed -- it says two 20 time there were no levees, so they observed
21 observed storms -- I'm reading Page 17 -- two 21 7 feet in '47 and six feet in '56.
22 observed storms with known parameters and 22 Michoud -- that's where the Michoud
23 effects were used to establish and verify 23 facility is in New Orleans East?
24 procedures and relationship for determining 24 A. I'm assuming so, yes.
25 surge height, wind, tide level and overtopping 25 Q. Long Point I haven't heard of. Do you
Page 135 Page 137
1 flows. 1 have any idea where that is? That's a new one
2 It may be they didn't have enough 2 on me.
3 information on some of the other storms or they 3 A. I think there's a map in here that
4 were not as critical to the area. 4 shows -- I don't know where that is.
5 Q. All right. Well, the '47 hurricane 5 Q. There's a Plate 3 which seems to be
6 had a little higher central pressure index than 6 the map.
7 our standard project hurricane by about a 7 A. Yeah. I just can't read what's on it.
8 point, huh? 8 Q. Let me see if we can find Rigolets.
9 A. Uh-huh. A little larger storm with a 9 I'm looking at Table 6 where they have
10 radius max winds of 33. 10 hydrologic stations. Let me see if I can back
11 Q. Okay. And our 1915 hurricane had 11 into this. What did we call it, Long Point?
12 probably closer to the central pressure index 12 A. Long Point. I think I know where it
13 and, frankly, closer to the -- 13 is. If we had the original we might be able to
14 A. Uh-huh. 14 see that, but I'm thinking if you look on plate
15 Q. -- wind speed at 30 nautical miles, 15 7 there's some words.
16 right? 16 Q. Got you.
17 A. Right. When you look at Table 10 on 17 A. You see where the words Lake Borgne
18 Page 18, the 1915, the 1947, the '56 and 18 are, that are written sideways?
19 Hurricane Betsy, you know, had central 19 Q. Yes.
20 pressures, radius to maximum wind, forward 20 A. If you --
21 speeds, and VX is velocity, the wind speed, you 21 Q. I see Long Point. I sure do.
22 know, we were right around the same 22 A. I think that's Long Point up there.
23 characteristics of a standard project 23 Q. Okay. All right. Good. Thank you
24 hurricane. 24 very much.
25 Q. All right. In terms of central 25 All right. Now, these were then
35 (Pages 134 to 137)
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1 compared to that formula, and the formula is 1 A. Which page?
2 described on Page 19. Right? 2 Q. 4. See where it says -- it's
3 A. Are we in the same document? 3 highlighted for you.
4 Q. I think so. 4 A. Okay. I found the section.
5 A. I'm still in the -- 5 Q. All right. You've seen it now. Can
6 Q. Number 32? 6 you tell me what a slow rising storm surge --
7 A. 32. Yeah. It starts on Page 19 -- 7 is that the speed with which setup occurs?
8 Q. Yeah. Surges? 8 A. In this particular case, I think
9 A. -- and continues on Page 20, yes. 9 they're defining slow rising storm surge as the
10 Q. Okay. All right. So, surge -- well, 10 rate of rise of the water level.
11 actually S is wind setup in feet. Is that 11 Q. Right. Okay. So --
12 surge? S, at Page 20 is defined to be wind 12 A. And the water level in our case, going
13 setup in feet. Before we get any further 13 back to Exhibit 32, is --
14 along, I want to make sure we understand our 14 Q. The still water height.
15 terms. That I understand the terms. 15 A. -- the still water height.
16 A. Yeah, that's how I define surge. 16 Q. I just want to see, is there any
17 Q. Wind setup. 17 connection between the rate at which setup
18 A. When you look in the glossary under 18 occurs or surge increases and the forward speed
19 wind setup, they say it's the superelevation of 19 of the hurricane?
20 the water 's surface above the hurricane tide 20 A. It's all related, yes.
21 height due to -- I'm sorry, I'm reading the 21 Q. Is there some mathematical
22 wrong one. 22 relationship or -- in other words, how do we
23 Q. You're reading from which document, 23 determine the connection?
24 for the record? The same? 24 A. Okay. We're going back to our circa
25 A. Wind setup in feet -- 25 1960s, right?
Page 139 Page 141
1 Q. Same as setup it says. 1 Q. Oh, yeah.
2 A. Uh-huh. 2 A. Because it's a different today.
3 Q. Vertical rise in the still water level 3 Q. No, no, no. Even Bretschneider is
4 above that which would occur without wind 4 what, 1960 some odd. '66. So we're not
5 action caused by wind stresses on the surface 5 modern, whatever that word means.
6 of the water. 6 A. Okay.
7 A. Correct. 7 Q. Yet.
8 Q. Okay. That seems like it's only 8 A. If you go back to -- and I'm going
9 caused by wind, and not by, um -- I guess 9 back to Exhibit 32 --
10 they're including here the fact that the 10 Q. What's 32?
11 hurricane will push water in from the gulf. 11 A. -- which is Part 1 Chalmette, the DM
12 That's a wind action. 12 Number 1.
13 A. Right. Yeah. 13 Q. Which is it again? I'm having a hard
14 Q. Okay. Now, I just want to make sure 14 time.
15 I'm not getting myself confused, because we 15 A. Exhibit 32, DM Number 1, Part 1,
16 also have -- we have forward speed of the 16 Chalmette.
17 hurricane, and then we have something called a 17 Q. Got it. Okay.
18 slow rising storm surge. That has nothing to 18 A. If you go to Page 18 and 19 and 20 --
19 do with the forward speed of the storm, does 19 Q. Okay. There we go.
20 it? Or does it? I don't know. 20 A. And I'm going to start with -- there
21 A. I'd have to see what context that term 21 is an equation on Page 18 --
22 was used in. 22 Q. Uh-huh.
23 Q. It's Bretschneider, Page 4. Slow -- 23 A. -- that talks about maximum gradient
24 let me let you catch up to us. There's a lot 24 wind speed, central pressure, et cetera, et
25 of different words and phrases. 25 cetera. It's down toward the bottom of the
36 (Pages 138 to 141)
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Page 142 Page 144
1 page. If you go to the next page, there is an 1 and the forward speed of the hurricane?
2 estimated wind speed in the region of the 2 A. Well, that's what I'm trying to
3 highest speeds obtained, and they're using the 3 explain.
4 output from the equation on Page 18 along with 4 Q. Okay. I'm sorry.
5 the forward speeds to calculate the estimated 5 A. You know, because -- and I'm trying to
6 wind speed. 6 do it in context of --
7 Q. At 30 nautical miles? 7 Q. Yes.
8 A. At the design parameters. 8 A. -- of the 1960s. These equations,
9 Q. Which is 30 nautical miles. 9 that's where your forward speed comes in. And
10 A. Right. Well, I got V sub X is equal 10 then you use that estimated wind speed in the
11 to, and then I have a coefficient .885 times V 11 equation that calculates surge. And you can do
12 sub GX. That parameter is calculated using the 12 that for every increment of time throughout the
13 equation on Page 18 at the bottom of the page. 13 storm and then look at the shape of your
14 Q. All right. This gave us the wind 14 hydrograph that you calculated and then see,
15 speed calculation. 15 does it rise quickly or does it rise slowly?
16 A. Right. 16 So it is interrelated. If I use these
17 Q. So we didn't pick one, by the way, we 17 equations that are on these pages here I can
18 calculated the wind speed to be 100 for our 18 create myself a surge hydrograph. And I look
19 standard project hurricane. 19 at that shape and I say, okay, this is a slow
20 A. The standard project hurricane we 20 rising surge hydrograph, this is a faster
21 selected 100. 21 rising surge hydrograph. So that's how it's
22 Q. But apparently we calculated it. It 22 linked.
23 looks like it, anyway. We calculated it based 23 Q. All right.
24 upon forward speed and the pressure -- 24 A. And Bretschneider stated, in their
25 A. Yeah. 25 document, and if you continue reading that
Page 143 Page 145
1 Q. Okay. So any way, now, bottom line: 1 paragraph, you know, they talk about the
2 We got our 100 miles an hour at 30 nautical 2 synthetic hurricanes. So it's all linked in
3 miles. 3 there.
4 A. Right. But as part of that equation 4 Q. Okay. Now, I get a little confused
5 there's a parameter in there where you use the 5 because Betsy was a fast moving hurricane --
6 forward speed. 6 right?
7 Q. Yeah. But we were talking about the 7 A. Correct.
8 rate at which the surge -- let me say it more 8 Q. And it produced high surge --
9 properly. The rate at which setup occurs is 9 A. Correct.
10 probably the best way. 10 Q. -- right?
11 A. Uh-huh. 11 And these guys are saying that a more
12 Q. In other words, the speed with which 12 rapidly rising surge, such as -- they seem to
13 we go from still water height to the setup 13 be talking -- it says, however such a storm
14 height seems to be what's being referred to by 14 will not produce tides which are as high as
15 Bretschneider and Collins. They say slow 15 more critical hurricane tracks such as Betsy or
16 rising storm surge, more rapidly rising -- so 16 the synthetic hurricane.
17 they're talking about I guess. 17 What are they saying there?
18 A. Yeah. 18 A. Okay. They were attempting to explain
19 Q. When I see slow and rapid, I'm 19 that there are certain type of storms that will
20 thinking speed. 20 give you -- that the gulf outlet channel has an
21 A. Right. 21 effect on the surge.
22 Q. And then we're talking about a surge, 22 Q. Let's leave that part out.
23 so we got to talk about how quickly it goes 23 A. When you go back to your highlighted
24 from Point A to Point B. And so the question 24 sentence.
25 is, is there a relationship between that speed 25 Q. Forgive me. Let's leave out the
37 (Pages 142 to 145)
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Page 146 Page 148
1 channel. I just want to see what they're 1 A. There are a bunch of hydrographs in
2 talking about in the context of slow rising 2 here.
3 storm surge and more rapidly rising storm 3 Q. Okay.
4 surge. Because it seems to be inconsistent. 4 A. Um --
5 It says -- first of all, they acknowledge that 5 Q. I see at 58 something called storm
6 Betsy is a fast moving storm. 6 surge computations.
7 A. Right. 7 A. Page 58?
8 Q. In fact, it's way at the top of the 8 Q. 58.
9 chart on our little graph that we looked at 9 A. Yeah. These are the -- looks like the
10 some time ago. And we also know that Betsy 10 computations that came out of Bretschneider 's
11 produced a really high surge. Then they're 11 model using Hurricane Betsy as a --
12 saying here, though, that such a storm, which 12 Q. All right. So we have here a chart
13 would be Betsy, will not produce tides which 13 which has surge height compared to time?
14 were as high as the more critical hurricane 14 A. Uh-huh.
15 tracks such as Betsy. So I'm very confused. 15 Q. But I don't see where the speed of
16 A. No, because they're referring back to 16 the -- the forward speed of the hurricane is
17 a storm that will give you a more rapidly 17 shown.
18 rising surge which the gulf channel has an 18 A. No. But they're using Hurricane
19 effect on. 19 Betsy, so they're using the forward speed that
20 Q. I'm with you. But -- 20 was --
21 A. That's not necessarily Betsy. They 21 Q. Oh. It's forward speed.
22 actually ran Betsy in this analysis. 22 A. It's forward speed.
23 Q. Well, isn't Betsy a fast moving storm? 23 Q. All right. So the only way we can
24 A. Betsy is a fast moving storm, but does 24 understand whether or not -- I guess how does
25 that completely 100 percent translate into a 25 one measure the speed of the increase in surge?
Page 147 Page 149
1 fast rising surge? 1 We just -- or is there a way to do it by
2 Q. Well, that's why I asked you if there 2 looking at this chart?
3 was a relationship. 3 A. Not on that chart. I guess for that
4 A. Yeah. There is relationship, but you 4 chart, for that particular instant, you'd look
5 got to go through the whole calculation. 5 at -- let's go back to it. If you're talking
6 Q. It's not 1 to 1. 6 about the rate of rise --
7 A. It's not 1 to 1. There's all these 7 Q. Yes.
8 other parts of the equation. So you may end 8 A. -- you could go, for example, at noon
9 up, even though you have a fast moving storm 9 on September 9th and 6:00 p.m. on September
10 like Betsy, the size of Betsy and all the other 10 9th, and look at the storm surge height for
11 parameters that go into this equation, result 11 each of those two values and compute the slope
12 in a more ra -- would not result in the rapidly 12 of the line, and that could give you the rate
13 rising surge that Bretschneider is referring to 13 of rise.
14 here. 14 Q. Well, the problem is it goes up and
15 Q. And the only way I can truly 15 down.
16 understand, at least to test that, is to have a 16 A. Well, but I was looking at just that
17 hydrographs of Betsy, a hydrograph of the 17 particular time period. Yes, it's going to
18 synthetic hurricane, and I can see what the 18 vary through the whole --
19 relationship is in those two instances between 19 Q. Whoa. My point is, the only way you
20 the forward movement and the speed with which 20 can determine the speed with which it rises,
21 the surge rises, right? 21 you have to pick some point along its upward
22 A. Right. 22 rise and then some point below its upward rise
23 Q. Do you know if Mr. Bretschneider or 23 and calculate how long it took to get from
24 Mr. Collins did those hydrographs? Are they in 24 Point A to Point B. Wouldn't that make sense?
25 this document? 25 So for example, if you look at noon, and there
38 (Pages 146 to 149)
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Page 150 Page 152
1 are three different lines here so one of them 1 what's fast, medium or slow. Right? Which is
2 is computed, the other one is smooth -- 2 exactly what we did, frankly, with regard to
3 A. Do the CLL0 line. 3 forward movement.
4 Q. Okay. Fair enough. And so that looks 4 A. Yeah.
5 to me like -- 5 Q. We looked in the real world, and then
6 A. It's somewhere near 2. And then at 6 we compared all of the storms, and the guys
7 6:00 p.m. or 1800 it's at 6:00. So in six 7 that went really fast we called them fast, the
8 hours it went up four feet. 8 guys that went -- the guys that finished first
9 Q. Okay. 9 were fast, the guys that were at the tail end
10 A. So that's -- four feet divided by six 10 were slow and the guys in the middle we called
11 hours would be the rate of rise, as a rate. 11 it moderate. Right?
12 Q. All right. 12 A. Right.
13 A. A speed. 13 Q. Okay. Same thing.
14 Q. And so how do we determine whether 14 A. Yeah. The exact limits will not --
15 that's fast, slow, moderate, medium, whatever? 15 Q. You'll never know, but it's limits
16 A. We'd have to see if we're on the same 16 based upon real world experience, you're right.
17 page as Bretschneider, what he considered fast, 17 It can only be based upon what we've
18 medium, slow. And that I don't know. 18 experienced already because we don't know what
19 Q. All right. Well, really, the only 19 the future will give us. Fair enough?
20 true way to do it would be to compare other 20 A. Fair enough. Because, you know, he's
21 storms, because the whole logic is based on 21 defined it so he had to do it based on his life
22 past storms -- 22 experiences. So.
23 A. Right. 23 Q. Right. But he didn't give us any
24 Q. -- synthetic storms, in other words, 24 other storms to compare it to. Other than his
25 real world experiences. Right? 25 own life experience.
Page 151 Page 153
1 A. Yeah. I mean, he's developed a 1 A. Um -- my understanding, he did run
2 yardstick that he uses that says this is fast, 2 some different tracks and different storms. He
3 this is medium, this is slow. 3 ran Betsy, certainly.
4 Q. Right. 4 Q. Well, if you look at Page -- forgive
5 A. Um -- it's his determination of what 5 me, this is a very lousy copy -- Page 9, it
6 that is, and I don't think it's -- I have not 6 says a significant improvement on this method
7 found anything in his report that tells me what 7 was originally proposed -- and I guess he's
8 he thinks is fast, medium or slow. 8 talking about --
9 Q. Right. 9 A. Yes. He made up synthetic storms.
10 A. I can only go by that he thought what 10 Q. It's a theory for storm tide.
11 you have here, you know, what actual scenarios 11 A. Page 9, okay.
12 he ran, and see which ones of those scenarios 12 Q. And he says a significant improvement
13 where he said there's a negligible effect, then 13 on this method was originally proposed by
14 I go look and see, okay, what was my rate of 14 Freeman and Jung and called The Bathystrophic
15 rise? 15 Storm Tide. The assumption of a slow moving
16 Q. Right. Exactly. 16 storm is required, and the theory is a -- this
17 A. And I would say then based on that 17 is where my copy fails me --
18 that would be his definition of slow. 18 A. Quasi static.
19 Q. Sure. 19 Q. -- the effects of longshore currents
20 A. I just don't know. 20 are considered and these produced corrections
21 Q. Of course. 21 to the more simple storm tide computation of --
22 A. It's not in here. 22 A. Equation 5.
23 Q. So we agree that you'd have to just 23 Q. -- because of the --
24 compare hydrographs from actual real world 24 A. Coriolis effect.
25 storms in order to have some understanding of 25 Q. All right. Can you make some sense
39 (Pages 150 to 153)
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Page 154 Page 156
1 out of that for me? 1 Q. Okay.
2 A. No. 2 A. So. Yeah. I mean, to make it simple,
3 Q. You know, you spoil me -- 3 you know, it's -- it is the wind speed at the
4 A. I'm sorry. 4 radius to maximum winds of 30 nautical miles.
5 Q. Okay? You read it well. But you have 5 Q. All right. Now, the fetch length in
6 truly spoiled me. You were going to give it to 6 statute miles. Is that a fixed number with
7 me. 7 regard to the MRGO alignment of the levee?
8 A. I'm sorry. 8 A. It is and it's not, because the fetch
9 Q. All right. But it sure looks like -- 9 length is going to be the distance that's
10 MR. SMITH: 10 related to where the track is.
11 It's impressive sounding, that's 11 Q. Right.
12 for sure. 12 A. You can have a different fetch
13 MR. BRUNO: 13 depending on where your storm is along that
14 Which is a lesson to be learned. 14 track. But yes, you're relating it back to
15 EXAMINATION BY MR. BRUNO: 15 where you're trying to calculate the surge,
16 Q. It certainly appears here that the 16 which in your case is the levee along the MRGO.
17 whole business of the slow moving storm is an 17 Q. Right. But of course for our purposes
18 assumption. 18 I think we established that the track that was
19 A. But it almost sounds that the 19 selected for our synthetic storm posited a
20 assumption of the slow moving storm is required 20 direct hit on the levee, so at least for the
21 for the method proposed by Freeman. The 21 purposes of this formula it is a fixed number.
22 question becomes is that really what was used? 22 Because we did choose a track for our standard
23 And now I'm -- 23 project hurricane. I'm sorry. Our design
24 Q. What is that word? 24 hurricane.
25 A. Quasi-static. It's not quite static. 25 A. Well, when you run through the
Page 155 Page 157
1 But you're getting well beyond my area of 1 calculations they generally used one fetch
2 expertise on storm tide theory. That's why I'm 2 length.
3 not sure what's going in here. 3 Q. Well, I know they have to use one --
4 Q. Fair enough. So let's leave it alone. 4 if they use more than one, you'd have multiple
5 Where we were was in the calculation 5 calculations, but I'm trying to see if we can
6 of surge height. And we have our formula, and 6 agree that the one they had to choose was the
7 so our formula, it turns, requires some 7 one that had some relationship to the track
8 information. It requires that we establish the 8 ultimately selected for the design hurricane.
9 wind speed and statute miles per hour, which in 9 A. I guess where I'm confusing you is
10 our case, would that be the wind speed at 30 10 that you do make multiple calculations to make
11 nautical miles? 11 sure you've got the right -- the most critical,
12 A. It's derived from that. Here again, 12 um -- calculation. So you might -- you know,
13 you've got to go back through the calculation 13 because you have the MRGO levee going, you
14 for the maximum theoretical gradient wind. But 14 know, that distance, you might actually make
15 you ultimately get a wind speed. 15 four or five different calculations using --
16 Q. Well, okay. We were talking -- it 16 Q. But at different location?
17 just says wind speed in statute miles per hour, 17 A. At different locations.
18 but you're telling me that refers to -- why 18 Q. Yeah. We are talking across each
19 don't you just tell my what you think it refers 19 other because I'm assuming -- well, just pick a
20 to. Let's do it that way. 20 point. You may make a thousand different
21 A. Because you're calculating the 21 calculations along the entire length of the
22 estimated wind speed in the region of the 22 MRGO, but for that one point, since you've
23 highest speeds, and we're making the assumption 23 chosen a track, it's going to be the same
24 that that's where your R max, your radius to 24 fetch. Is that right?
25 maximum winds, is 30 nautical miles. 25 A. For the same --
40 (Pages 154 to 157)
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Page 158 Page 160
1 Q. Location. 1 A. Yes.
2 A. -- location of the storm and the same 2 Q. So that doesn't help you, because if
3 location of the levee, yes. 3 you look at Page 24, they have average depths,
4 Q. Precisely. Now, fetch -- I'm sorry. 4 but I don't see 12.98. I see two different
5 The depth of the fetch, whatever that length 5 numbers.
6 is, you take the average depth of what's under 6 A. Right. But the example that is shown
7 the water. Now, is this the fetch pre surge or 7 on Page 22 --
8 is this the fetch at a certain given -- I guess 8 Q. Okay.
9 it doesn't make any sense. If you were 9 A. See, that's the thing, there's many,
10 calculating surge, obviously this has to be 10 many calculations that are made over and over
11 based upon the normal tides. Isn't that true? 11 again with this equation. They only show one
12 A. We ultimately end up adding that surge 12 example on Page 22.
13 depth to the tide to get your surge elevation, 13 Q. Well, but we would expect that,
14 but you're going to look at the depth. 14 because this is for not only Chalmette, right,
15 Q. Forgive me. I didn't mean to -- I 15 this is for -- goodness, this is all over the
16 stuck the word tide in there because water 16 place.
17 depth will change on the tides. You have to 17 A. Right.
18 pick a time of day to get a water depth. And 18 Q. But if we do go to Page -- if we look
19 it's got to be the same time every day in order 19 at Page 24, we do have some average depth --
20 for you to get the right depth. 20 A. Correct.
21 A. Uh-huh. 21 Q. -- information.
22 Q. If I'm making any sense. I guess at 22 A. But I can't guarantee that that is the
23 some point in the day, maybe you use low tide? 23 actual depth that went into the equation that
24 Is that it? Low tide water depth? 24 calculated -- because this is actually wave
25 A. Well, if you're calibrating your 25 run-up depths and not the surge calculations.
Page 159 Page 161
1 equation you're going to use what actually 1 Q. Right.
2 occurred. 2 A. That's --
3 Q. Oh, yeah. No question. No question. 3 Q. Okay. Just to help me here, where did
4 But I mean if you're doing your -- once you've 4 you see the fetch depth on Page 22?
5 calibrated it, then you're going to start using 5 A. It's going to be the -- the value
6 this equation. 6 that's used in the equation is going to be the
7 A. Correct. 7 column that says D equals the sum of S plus the
8 Q. Because the calibration doesn't work 8 average D plus 2.84 plus Delta S over 2. It's
9 for every point on the MRGO alignment because 9 the third one from the right.
10 you don't have the real world data. 10 Q. Oh, I see.
11 A. Right. 11 A. That's the actual depth that's used in
12 Q. So yeah -- 12 the calculation that's shown here as an
13 A. They end up using the normal predicted 13 example.
14 tide as the -- 14 Q. Oh, I see. Well, then, we need to
15 Q. There we go. It's the normal 15 understand what on earth the D equals all that
16 predicted tide. Point is, though, that that is 16 other stuff means.
17 the average depth of the water along the length 17 A. That's what I was going back and
18 of the fetch. 18 trying to do. And maybe we need a break so I
19 A. It appears from the equation that they 19 can figure it out.
20 are using an average of the depth between two 20 Q. All right. Well, let's take a little
21 different stations. And I'm trying to go back 21 break because you have been going for almost
22 through the equation to figure out how they 22 two hours now.
23 got, on Page 22, 12.98, because that is the 23 (Brief recess.)
24 depth they're using, and it's -- 24 EXAMINATION BY MR. BRUNO:
25 Q. They're using 12.98? 25 Q. All right. So where were we? We were
41 (Pages 158 to 161)
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Page 162 Page 164
1 trying to determine whether or not you could 1 calculation.
2 figure out the formula utilized by the Corps to 2 Q. Well, I thought we were using this
3 determine the fetch depth which was a number 3 formula to calculate the surge? That's where I
4 that gets plugged into the calculation of 4 got confused. You've got a formula that says
5 surge. Right? 5 you need to do this to get S, and now we're
6 A. Correct. 6 saying we've got an S and we're -- it seems a
7 Q. And you've told me you've tried but 7 little circular to me.
8 you -- you can't do it. 8 A. Yeah. It does seem very circular.
9 A. Well, some of it looks like it 9 But it's -- you're using the surge at one
10 involves some of the initial elevation 10 location to calculate at the next location
11 calculations, the average depth for the 11 along the -- along what they call the adjacent
12 particular fetch that you're looking for, 12 stations on the range. So that's why it's a
13 between Station 1, for example, or Station 2, 13 little confusing.
14 you know, there's two different examples, I'm 14 Q. I also note that it shows for example
15 looking at the two different exhibits and 15 one hour before landfall. I mean, you could
16 seeing how they've used these numbers. 16 calculate -- you could do this any number of
17 Q. Okay. 17 times. I mean, you can do it a million times
18 A. I think what was getting me was I did 18 if you wanted to.
19 not know, it least in this equation, where the 19 A. Right. But that's what they actually
20 2.84 came from. 20 did. They did this several -- you know, lots
21 Q. Right. Because they're adding -- it 21 of times. I don't want to tell you it's
22 says average depth. 22 thousands of times, but lots of times, and you
23 A. Yeah. Whereas -- 23 ultimately end up with different surge levels,
24 Q. Well, S -- S can't have two meanings, 24 and you look to see along your reach -- you're
25 huh? S can't possibly mean surge, huh? 25 going to pick probably, for that given reach,
Page 163 Page 165
1 They're using S twice. 1 what you believe is the highest surge elevation
2 A. Okay, based on what I believe the 2 along that reach.
3 formula is showing I can tell you how you get 3 Q. Okay.
4 to 12.98, if that helps. 4 A. But you've got to start with, as the
5 Q. Yes, ma'am, it does. 5 storm moves through each increment of time, you
6 A. Because this is an incremental setup 6 know, it gets translated along each increment
7 that they're talking about to get the next 7 of levee reach.
8 setup for elevation that they have here. But 8 Q. Okay.
9 they initially start at Station Mile 4 that has 9 A. And you ultimately -- like I said, you
10 a depth of mean low water -- a depth of 0 feet 10 may get a thousand different numbers, and you
11 mean low water, and it has a sum of S of 11 look and say, okay, this is the highest surge
12 9.86 feet. They take that 9.86 feet, add 0 to 12 elevation I got from my representative reach,
13 it, add 2.84 to it. 2.84 appears to be the 13 I'm going to use that for my designer
14 initial elevation of the water. Then they add 14 parameter. But you got to actually go through
15 a difference in the setups, divided by 2, which 15 this incremental analysis. Now --
16 happens to be .55, divided by 2, which is .26. 16 Q. This will also give you, by the way,
17 If you take that 9.86 plus the 0 plus the 17 the speed with which the surge will go up.
18 2-point 84, plus the .26, you'll come up with 18 A. If, you know --
19 just about 12.98. 19 Q. Over time.
20 Q. All right. What I don't understand is 20 A. This example doesn't, but if you made
21 why would you -- if the depth is 0, why do you 21 those calculations, yes, you would.
22 add to that depth? 22 Q. You need a whole bunch of them.
23 A. Well, that depth there is the depth 23 A. Yes.
24 before the water comes in. So you have to 24 Q. All right. Now, do you know if the
25 start with the surge, which is the 9.86 in this 25 Corps used the MRGO channel in connection with
42 (Pages 162 to 165)
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Page 166 Page 168
1 its calculation of the fetch depth? 1 We're both good.
2 Remembering that our standard project hurricane 2 Q. Well, how about that?
3 is on a direct attack so that clearly the fetch 3 A. Aren't we good.
4 would include the channel. Right? 4 Q. All right. I don't know how he's
5 A. Yeah. 5 numbering these photographs. Maybe Page 17?
6 Q. So anything here that indicates that 6 What do you think? You said 5 was an example.
7 the Corps used the channel at all? 7 That just refers us right back to where we
8 A. As I read the comment that's on Page 3 8 were. Okay. Yeah. Page 23?
9 of Exhibit 32, if you go to Page 3 -- 9 A. 7.
10 Q. Page 3, okay. Wait, I'm sorry. Is 10 Q. Yeah. It says a study is presently
11 this the -- are we looking at the letter from 11 being made. It says the procedures presented
12 the -- from Chief Davis or no? 12 in this report were based upon the assumption
13 A. Um -- I'll show you exactly what I'm 13 that the gulf outlet had no effect on the
14 looking at. (Indicating.) This is what I'm 14 hurricane surge elevation. So it's pretty
15 calling Page 3. 15 clear, is it not, that they did not put into
16 Q. Wendel Johnson. 16 the formula the extent to which the channel may
17 A. It's Wendel Johnson. 17 have altered the fetch depth calculation,
18 Q. Okay. I'm with you. 18 right?
19 A. As I read that sentence it says the 19 A. You could conclude that. But again,
20 standard project hurricane surge elevation 20 they talk about that it's -- everything is
21 appears reasonable and is approved subject to 21 approved pending the completion of the analysis
22 the future studies of the effects of the 22 of the effects of the MRGO on surge. So it was
23 Mississippi River Gulf Outlet on surge 23 addressed.
24 elevations presently under investigation. So I 24 Q. All right. Well, now, let's be fair
25 read that as this particular document and these 25 with each other. I didn't ask if it was
Page 167 Page 169
1 particular calculations did not consider the 1 addressed.
2 effects of the MRGO, it's only after the 2 A. Okay.
3 Bretschneider work was finished that it was 3 Q. I was asking you about the formula as
4 clear that the effects had been considered 4 indicated -- as described in the document that
5 properly. 5 uses a number for fetch depth. And the
6 Q. But for the formula to work and 6 comments by the colonel or the general, whoever
7 realistically, you do have to -- if you know 7 it was, refers us to the calculations section.
8 that you've got a channel there on your fetch 8 And it further refers us to the section here
9 line, you should include that in your average 9 which says we're doing an evaluation somewhere
10 depth calculations, shouldn't you? If you were 10 else.
11 going to do it by the book. 11 So we can conclude, can we not, that
12 A. Yeah. 12 those calculations do not include the MRGO
13 Q. All right. And -- okay. And then of 13 channel as a component part of the fetch depth
14 course if you did that you'd also have to know 14 as described by the formula used to calculate
15 the actual depth of the channel. Right? At 15 surge, isn't that true?
16 each of these locations where you were doing 16 A. I have to somewhat disagree because it
17 these numbers. 17 does say that it was based on the assumption it
18 A. Correct. 18 has no effect, but it doesn't clearly say we
19 Q. Okay. I just want to find 8D7 so I 19 did not consider the depth of the MRGO in the
20 can see what he's talking about there. 20 calculation of the average depth across the
21 (Brief interruption.) 21 entire fetch. If the entire fetch was eight
22 A. 8D5. 22 miles, you would average the depth over that
23 EXAMINATION BY MR. BRUNO: 23 eight mile fetch.
24 Q. You see 7, I see 5. 24 Q. Sure.
25 A. Beginning and the end. AD5, AD7. 25 A. So --
43 (Pages 166 to 169)
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1 Q. But -- 1 with resultant adverse effect on fishery
2 A. -- you know -- 2 resources in the area. The gulf outlet channel
3 Q. -- the fault in that logic, I would 3 will also produce high velocity currents in the
4 suggest to you, is that what would be the need 4 Inner Harbor Navigation Canal creating a hazard
5 of a separate evaluation if you included the 5 to navigation and causing serious scour and
6 MRGO in all of your calculations here? The 6 damage, particularly in constricted areas at
7 formula is reliable, isn't it? 7 bridge crossings. These adverse effects can be
8 A. I mean, I can only go by what I'm 8 greatly alleviated by construction of a lock
9 reading. I just don't know, you know, if it 9 for navigation and salinity control at the lake
10 was included or not. 10 end of the Inner Harbor Navigation Canal at
11 Q. Okay. 11 Seabrook. This lock is properly chargeable as
12 A. It just says that the procedures were 12 a feature of the gulf outlet project.
13 based on the assumption that it had no effect. 13 So it acknowledges that it's out
14 Q. All right. 14 there --
15 A. Not that they actually put the depth 15 A. Right.
16 in the calculation. 16 Q. -- but there's no indication in those
17 Q. Do you know how the water depth was 17 documents that the actual physical
18 determined? 18 characteristics of the channel itself were
19 A. It's an average over the entire -- the 19 included in any of the calculations utilized by
20 entire fetch. 20 the Corps to come up with a standard project
21 Q. Right. But somebody had to go out 21 hurricane or a design hurricane or a still
22 there and drop the plumb bob in the water to do 22 water height. Isn't that true?
23 that, right? 23 A. In those documents.
24 A. In all likelihood they used maps and 24 Q. Right. Okay. And in this 1962
25 known surveys. 25 document, we have a description, frankly, of
Page 171 Page 173
1 Q. Right. 1 the same verification of surge height that we
2 A. If the channel did not exist -- 2 see in 1966. I'm in particular referring to
3 Q. Exactly. 3 A18.
4 A. -- it may not have been used. 4 A. Yeah. It's --
5 Q. That's what I was sort of alluding to. 5 Q. So it's basically the same data
6 A. Yeah. But -- you know, without 6 re produced in 1966.
7 looking at the calculations you can't conclude 7 A. Well, the same methodology. This was
8 that definitively or not. 8 a different location so the numbers are
9 Q. Well, except that the, when we look at 9 different, but it's the same equation and the
10 the original interim report, doesn't it use the 10 same process.
11 same analyses and discussions? If you go back 11 Q. Right. Even though the exemplar
12 to -- 12 doesn't use the same location, there are in
13 A. But it uses a different location. So 13 fact tables and graphs which give the proposed
14 you can't -- like I said, the calculations that 14 still water height, don't they?
15 were actually used are missing. 15 A. Yeah.
16 Q. In 1962 -- 16 Q. Sure. And the still water height in
17 A. But that interim study does mention 17 this document is the same still water height in
18 the MRGO. 18 the '66 document for the Chalmette area.
19 Q. Without question. It talks about, 19 A. No, it's not.
20 let's see. At Page 1 -- I'm sorry, little i, 20 Q. Oh. The difference for Betsy is
21 it says, another and related problem exists in 21 accounted for.
22 the area. The Mississippi River Gulf Outlet 22 A. (Nods affirmatively.)
23 provides a deep, direct route for the inflow of 23 MR. SMITH:
24 saline currents from the Gulf of Mexico to the 24 You have to answer audibly.
25 area along its channel into Lake Pontchartrain 25 A. Yes. The later document considers
44 (Pages 170 to 173)
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Page 174 Page 176
1 Hurricane Betsy in the calculations. 1 6?
2 EXAMINATION BY MR. BRUNO: 2 A. Yeah. That's what I'm referring back
3 Q. Right. Which we have already 3 to.
4 established was at least in part the result of 4 Q. Okay. And so your thinking is that
5 the work of Bretschneider and Collins. Right? 5 that must be the Betsy stuff?
6 The hydraulic studies that they did after 6 A. And the fact that they included Betsy
7 Betsy. 7 as one of the -- on Page 21 they refer to Betsy
8 Didn't you tell me that -- remember 8 in their verification of hurricane surge
9 they -- 9 heights.
10 A. Now you got me confused. 10 Q. Right. Okay.
11 Q. Okay. Then withdraw. I don't want to 11 A. That they did make the calculations
12 confuse you. I withdraw the question. 12 using Betsy.
13 I thought you told me that the interim 13 Q. Okay. But again, none of this would
14 document was pretty much the same as the final 14 suggest that the MRGO channel was in any way
15 document except that after Betsy they went back 15 considered in the formulas that we have already
16 and looked at the effect of Betsy on all their 16 talked about, isn't that true?
17 calculations and so they did something, and 17 A. Yeah. We cannot tell if it was or was
18 they changed the still water height by I think 18 not.
19 some number. I don't think you told me the 19 Q. Okay. All right. So after a number
20 number, but they made it higher. 20 of those calculations utilizing the formula,
21 A. They made it higher. 21 which includes the calculation of the average
22 Q. Okay. 22 depth of the fetch, we come up with a series of
23 A. And then the Bretschneider work was 23 numbers for surge.
24 done. 24 A. (Nod affirmatively.)
25 Q. Oh. After that. 25 Q. Based upon the standard project
Page 175 Page 177
1 A. Was finished after that. 1 hurricane which was selected to be the design
2 Q. Okay. 2 hurricane. Correct?
3 A. That's the work that's referred to in 3 A. Yes.
4 this paragraph that I was describing, the 4 Q. Okay. And the still water height that
5 subject, the future studies of the effects of 5 they decided to use, with the inclusion of the
6 the Mississippi River Gulf Outlet on surge 6 Betsy information, was what?
7 elevations. 7 A. If you go to Table 13 on Page 24 --
8 Q. Well, I see that, but does it reflect 8 Q. Okay.
9 that they had already altered the standard 9 A. -- under the column WTL --
10 project hurricane surge height as a result of 10 Q. Yes, ma'am.
11 Betsy? 11 A. -- you'll see that that still water
12 A. Yeah. 12 level varied depending on where you were.
13 Q. In this -- 13 Q. Right. But the reason for the
14 A. In DM Number 1, they talk about 14 variance you've already explained to us.
15 changing -- 15 A. Right.
16 Q. DM Number 1 is this one? Okay, yeah. 16 Q. Because you're doing a separate series
17 Where is that? It's not on Mr. Wendel 17 of calculations based upon the track of the
18 Johnson's letter. 18 storm, based upon the time as related to
19 A. You want to go to Page 18? 19 landfall as it relates to that particular area,
20 Q. Yes, ma'am. Okay. 20 right?
21 A. Let me find it. 21 A. Yes.
22 Q. You're referring to that sentence 22 Q. Okay. Now, even though we can't find
23 which says based on subsequent studies of 23 documents or some references which suggest
24 recent hurricanes, the U.S. Weather Bureau 24 whether the Corps took into consideration the
25 revised the SPH wind field patterns, 4, 5 and 25 channel as it existed in 1962, to the extent
45 (Pages 174 to 177)
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Page 178 Page 180
1 that it existed at all, we certainly agree, do 1 We don't know definitively one way or the
2 we not, that inasmuch as the levees were not 2 other, but it's a reasonable inference to draw.
3 constructed until after 1966, and that the 3 A. Just like we don't know definitively
4 canal wasn't dredged to whatever depth it was 4 if it would have made a difference because we
5 dredged to build those levees, that the fetch 5 don't have the calculations.
6 depth did not take into consideration the new 6 Q. Exactly. And the same is true for the
7 depth of the channel, that is, the MRGO 7 Citrus levee, right? Because we know we
8 channel, along the alignment of the MRGO 8 widened and we deepened Reach 1 as a component
9 because it hadn't happened yet. Isn't that 9 part of this MRGO, so we don't know if the
10 true? 10 calculation of the fetch for this area took
11 A. I think as I answered before, we 11 into consideration the new depth and/or widths
12 cannot determine with any certainty whether it 12 of the Reach 1. Right?
13 was or was not included in the fetch 13 A. I have no way of knowing from these
14 calculation. 14 documents.
15 Q. Well, I'm wondering if logic will 15 Q. All right. Thank you. That's fine.
16 allow us to draw some conclusions inasmuch as 16 Now, do you do that same calculation
17 we know as a matter of fact that the dredging 17 for the Inner Harbor Navigation Canal, that is,
18 of the MRGO to build the levees didn't occur in 18 the calculation of surge height? You know that
19 until after 1966. 19 formula that we used?
20 A. I know, but common practice today when 20 A. Uh-huh.
21 we do a study is to consider all authorized 21 Q. Do you use the same formula to
22 features in place. So if I was going to make 22 calculate the surge that would be anticipated
23 the calculation today I would have to consider 23 inside this channel?
24 the channel in place. So that's why I'm 24 A. If you were going to come up with the
25 hesitant about answering your question, 25 still water level that's shown on this table,
Page 179 Page 181
1 because -- 1 you would have to make some calculation, yes.
2 Q. Well, the channel in place, the 2 Q. Well, they did.
3 problem with that is that the channel in place 3 A. Yes.
4 had an authorized depth of a certain number, 4 Q. They come up with, at the Inner Harbor
5 and that number changed because another project 5 Navigation Canal, to the Louisville and
6 came along and made the depth deeper in order 6 Nashville Railroad bridge -- I don't know what
7 to build the levees, all of which happened much 7 it's called today but I know it's not that
8 later than those calculations would reflect. 8 anymore -- of 11.4 to 12.9 feet, and in the
9 That's what I'm saying. 9 Louisville and Nashville Railroad bridge to the
10 A. Okay. 10 river is 12.9 to 13.
11 Q. So I'm just wondering if logically -- 11 So how do you calculate the fetch in a
12 we're not talking about today now, we're not 12 channel like that? We know our wind direction
13 talking about today, we're talking about back 13 is something like this. How do you apply the
14 then -- whether or not it's fair for us to 14 formula to that channel?
15 conclude that the fetch depth calculations did 15 A. You're getting a little beyond my area
16 not take into consideration the depth of the 16 of expertise, but you would look at the
17 MRGO channel that resulted from the dredging to 17 direction of the winds --
18 actually build those levees. 18 Q. Right.
19 A. Like I said, I have no way of knowing 19 A. -- in relationship to the length of
20 whether it did or it did not -- 20 channel. If they were in alignment, that would
21 Q. All right. 21 be the fetch length.
22 A. -- without looking at the actual 22 Q. Well, to follow your thought, if the
23 calculations, but I understand what you're -- 23 fetch was along this line, which was coexistent
24 Q. Okay. All right. It's a reasonable 24 with Reach 1 -- you know what we mean by reach
25 conclusion to make, though, wouldn't you agree? 25 is, don't you?
46 (Pages 178 to 181)
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Page 182 Page 184
1 A. Yes. 1 buildup. Does the formula allow for buildup to
2 Q. Okay -- then that's easy to do. But 2 be included in the surge calculation, that is,
3 if you are, you know, away from that, if you're 3 the still water height calculation?
4 in this basin right here, is the fetch only the 4 A. As I look at the formula, I would
5 width of the Inner Harbor Navigation Canal? 5 conclude that that would be a separate
6 A. It depends on the calculation that 6 increment to be added.
7 you're making. Because here again, you're 7 Q. Okay.
8 making calculations throughout the whole path 8 A. Just like tide is added at the end.
9 of the storm in relationship to that area. 9 Q. Got you. Now, here we have sort of a
10 Q. Right. Got you. 10 unique situation in that if we're doing a surge
11 A. So you have a different wind direction 11 calculation way back here, we haven't yet built
12 at each calculation. 12 our levees here. Right? I mean, that's
13 Q. Right. Okay. 13 exactly what we're planning to do. So how do
14 A. And you look at that in relationship 14 you take into consideration the extent to which
15 to the water body you want to look at. 15 the levee here, or the levee here, that is the
16 Q. Right. 16 north and south banks of the Reach 1, may or
17 A. If you go back to your example of the 17 may not impact any of your calculations? How
18 IHNC, for example, you may have wind directly 18 do you do that?
19 out of the east for a portion of that 19 A. Well, here again, you got to go back
20 hurricane, in which case the length of fetch 20 to each increment of the storm along your track
21 would just simply be the width of IHNC. But 21 looking at what is the condition with your
22 there may be -- and without knowing, without 22 project in place, looking at what is going to
23 seeing the actual calculations, there may be an 23 be my fetch.
24 instant where the storm is -- winds are 24 Q. Okay.
25 directly out of the north, in which case the 25 A. And, you know, you have to consider --
Page 183 Page 185
1 fetch length in the IHNC is the length of IHNC. 1 you do -- you know, you're supposed to consider
2 Q. Right. 2 the project in place, which would mean those
3 A. But you have to go back to the path of 3 levees.
4 the storm that we're using as the critical 4 Q. Now, if somebody, and it could be
5 path. 5 anybody, does something to alter the variables
6 Q. Sure. 6 in your formula, if you change the -- you know,
7 A. And at each increment of calculation, 7 if somebody comes along and removes this land
8 and see where are my winds coming from -- 8 mass or removes this land mass, or, you know,
9 Q. Okay. 9 digs this out and decides to put a giant, I
10 A. -- and select my fetch based on each 10 don't know, maybe it's a sinkhole or something,
11 one of those increments. 11 I don't know, but to the extent that some other
12 Q. Right. Well, that still means you 12 person changes the variables, that might change
13 might end up with a fetch that's the width of 13 the calculations that -- I'm sorry -- that
14 the channel. Right? 14 would obviously change the assumptions that the
15 A. And that may be all you end up with. 15 Corps used to create -- I'm sorry not to create
16 Q. Sure. 16 but to come up with this still water height.
17 A. It depends on how -- here again, back 17 Right?
18 to the track, back to how the winds are 18 A. I guess that's a reasonable if
19 working. 19 statement.
20 Q. Do you know whether or not -- I think 20 Q. Right. And the way I understand the
21 we talked about the fact that you have a 21 way the Corps works is, if it's another Corps
22 natural funnel here. We know we've got at 22 project and that other Corps project causes
23 least a wind direction of something like this 23 some changes in the factual assumptions, for
24 where there is the potential to force water 24 example in hurricane protection, that other
25 into this area. And I think we called that a 25 project has to bear the cost of dealing with or
47 (Pages 182 to 185)
10/3/2008
Page 186 Page 188
1 fixing whatever those changes may cause to the 1 REPORTER'S CERTIFICATE
2 hurricane protection system. Do you understand 2 I, JOSEPH A. FAIRBANKS, JR., CCR, RPR,
3 that to be true? 3 Certified Court Reporter in and for the State
4 A. Um -- it's not hydraulics, but -- 4 of Louisiana, do hereby certify that the
5 Q. No. Okay. That's fair. 5 aforementioned witness, after having been first
6 MR. BRUNO: 6 duly sworn by me to testify to the truth, did
7 All right. Robin, this is a good 7 testify as hereinabove set forth;
8 time to break and place to break 8 That said deposition was taken by me
9 because the next subject is wave 9 in computer shorthand and thereafter
10 run-up. 10 transcribed under my supervision, and is a true
11 (Whereupon the deposition was 11 and correct transcription to the best of my
12 recessed for the day.) 12 ability and understanding.
13 13 I further certify that I am not of
14 14 counsel, nor related to counsel or the parties
15 15 hereto, and am in no way interested in the
16 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
Page 187
1 WITNESS' CERTIFICATE
2
3 I, NANCY JEANNE POWELL, do hereby
4 certify that the foregoing testimony was given
5 by me, and that the transcription of said
6 testimony, with corrections and/or changes, if
7 any, is true and correct as given by me on the
8 aforementioned date.
9
10 ______________ _________________________
11 DATE SIGNED NANCY JEANNE POWELL
12
13 _______ Signed with corrections as noted.
14
15 _______ Signed with no corrections noted.
16
17
18
19
20
21
22
23
24
25 DATE TAKEN: October 3rd, 2008
48 (Pages 186 to 188)
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A adjacent 164:11 105:21 106:16,17 75:12,13 81:22 ASHLEY 2:22

ability 25:3 61:25 administering 5:24 106:18 112:9 apply 61:14 70:23 asked 23:17 37:2
81:24 188:12 adverse 172:1,7 117:8 129:18 99:18 181:13 37:11 68:6,8
able 10:17 48:24 AD5 167:25 134:14,18 146:22 appreciate 9:10 111:24 147:2
107:3 137:13 AD7 167:25 165:15 168:21 approach 48:15 asking 17:20 27:14
absence 60:18 affect 58:25 59:2 and/or 8:3,9 9:21 53:4 57:14 59:25 31:3 44:8 45:1
accompanies 50:16 affirmatively 28:7 9:22,24 11:10,13 63:9 65:14 87:18 50:22 51:9 169:3
accompanying 96:4 173:22 26:24 68:25 69:12 97:18 110:17 aspect 61:25
35:3 176:24 180:11 187:6 approved 102:15 aspects 36:15
accounted 173:21 aforementioned angle 109:24 166:21 168:21 assessment 20:13
accounts 89:7 5:4 187:8 188:5 answer 5:13 12:17 area 37:22 46:24 20:16 44:16 87:18
accumulating afternoon 128:1 15:11 18:21 19:8 47:5,11 48:6 110:19
117:22 118:8 ago 46:21,22 115:6 21:9,23,25 22:8 51:25 53:23,25 associated 9:23
accurate 16:4 17:5 146:10 23:15 24:4 25:2 56:6,16 66:25 122:17 128:19
18:13 33:21 44:16 agree 125:21 25:21 30:4,21,25 67:7 69:18 75:2,3 assume 33:8 42:11
49:4 76:6 110:21 130:16 151:23 32:25 36:23 37:13 76:20 77:7,8 44:24 69:25 70:15
accurately 47:9 157:6 178:1 38:9 39:8 40:7 80:16,17 85:5 70:20 78:16,19
60:20 71:7,8 179:25 69:9 83:17 86:8 86:1 92:8 93:9,12 83:16 84:1 88:10
acknowledge 146:5 agreed 5:2 34:14 97:2 112:13 129:1 95:13 96:9 97:8 assuming 132:23
acknowledges agreeing 95:17 173:24 102:9 104:4,8 136:24 157:19
172:13 agreement 132:4 answered 23:17,19 106:10 110:8,12 assumption 153:15
acquiring 104:14 ahead 47:18 64:24 24:3,6 37:11 40:9 112:11 114:8 154:18,20 155:23
Act 44:1 114:9 121:22 68:6,8 178:11 118:14 120:12 168:12 169:17
action 1:4 99:24 alignment 80:21 answering 178:25 124:10,21 125:3,9 170:13
139:5,12 81:16 156:7 159:9 answers 25:12 126:6 128:25 assumptions 11:9
actions 9:21 26:24 178:8 181:20 anticipated 180:22 129:11,16 130:14 11:20 13:1 14:6
activities 50:2 alignments 79:10 anybody 7:22,23 130:24 131:4 15:19 185:14,23
actual 44:11 57:21 alleged 8:1 185:5 132:24 133:25 attach 28:9,9
72:15 88:17 92:23 alleviated 172:8 anymore 181:8 134:9 135:4 155:1 attached 28:18
116:2 133:25 allow 178:16 184:1 anyway 142:23 171:22,25 172:2 29:9 34:18 42:5
151:11,24 160:23 allows 6:25 APLC 2:16 173:18 177:19 44:4 66:18 82:23
161:11 167:15 alluding 171:5 apologize 92:18 180:10 181:15 84:16 85:14,24
172:17 179:22 alter 10:9 185:5 97:3 182:9 183:25 86:17,24 87:9
182:23 altered 168:17 apparent 48:16 areas 12:15 106:12 attachment 43:6
add 80:24 163:12 175:9 71:6 108:1,7 172:6 attack 77:17 78:6
163:13,14,22 AMERICA 1:12 apparently 142:22 argue 22:19 79:14 80:4,5
added 39:16,21 3:1 appears 67:9,21 arguing 22:21 23:7 166:3
40:12 41:4 49:10 amount 50:15 108:12 124:12 23:10 25:9 attempt 61:21
50:5,8 184:6,8 76:11 129:15 154:16 159:19 argument 25:4,7 attempting 48:22
adding 158:12 analyses 9:21 26:24 163:13 166:21 Army 1:13,14 3:12 145:18
162:21 171:11 appendix 116:5,13 9:22 34:25 35:1 audibly 173:24
address 16:11 analysis 13:2 38:16 applicable 71:2 83:2 August 84:23
30:14,17 40:13,15,22 41:5 72:10,11 Arpent 79:11 81:15 authority 102:14
addressed 168:23 46:8 48:12 66:6 application 65:18 82:4,16 106:6
169:1 67:10 84:22 85:3 applied 45:24 artificial 46:11 authorization
89:11 91:18,20 59:12 62:18 72:16 ascertained 71:20 21:18 29:18,25

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30:9 33:5,18,20 24:21 25:20 32:24 168:12 169:17 148:11,19 153:3 BRENDAN 2:11
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authorized 15:17 53:13 56:3,13 bases 65:7 177:6 141:3 143:15
21:16 30:16 32:21 59:16 63:18 64:3 basically 118:13 better 10:18 54:7 144:24 147:13,23
32:23 33:22 34:1 64:4,10 65:1 66:9 173:5 73:1 108:23 148:10 150:17
34:2,4 36:8,17 76:9 77:25 80:18 basin 182:4 133:24 167:3 174:5,23
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102:6 103:10 90:9 91:19 94:1 98:13 117:12 18:18 37:22 155:1 181:9
178:21 179:4 94:21 95:24 96:3 Bathystrophic 181:15 Brief 26:2 75:24
authorizing 32:12 96:24 97:15 153:14 bibliography 83:11 161:23 167:21
available 39:25 102:24 111:3 Baton 2:24 big 17:5 76:2 111:4 briefly 46:1
121:10 125:1 117:5,20 126:13 Bayou 66:25 Bill 42:16 bring 61:23 64:3
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6:16 137:10 140:13,24 Beach 83:20,23,24 57:22 59:6 65:25 57:6 63:23 80:18
average 67:23 141:8,9 145:23 136:10,13 73:1 76:8 94:24 brings 80:2
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axis 123:17,17 48:17,19 57:5 105:12 134:16 Borgne 7:10 97:7 19:23 22:13,20,25
A11 133:4 61:24 62:5,13 163:2 165:1 137:17 23:4,9,13,18 24:1
A16 131:11,15,16 64:5 129:8 believed 72:9 81:5 born 91:16 24:7,14 25:14,19
131:18 BALHOFF 3:22 121:20 bottom 73:14 75:4 26:3 28:20,24
A17 133:7,17 bands 58:16 believes 17:4 125:20 131:22 29:2,14 30:3,19
A18 133:18 173:3 bank 46:25 beneath 25:10 141:25 142:13 31:5,21 32:2,13
A3 126:23 banks 184:16 benefit-to-cost 91:7 143:1 32:17 34:5,21
A4 45:22 46:3,4 Baronne 2:5 Benjamin 3:8 Boulevard 2:18 37:6,12 41:8 42:7
128:6,8 barrier 10:6,7 Bernard 86:20 Box 3:7 42:25 43:4,11,16
A5 128:10 100:9 best 25:2 32:19 BOYER 3:20 43:20,23 44:6
A7 126:15 128:14 base 105:20 49:6 143:10 bracket 121:10 63:6 66:15,19
129:23 based 44:18 74:16 188:11 BRANCH 3:3 68:7,19,22 69:7
79:16 90:13 94:19 Betsy 36:11,12 BREACHES 1:4 69:22 70:21 74:9
B 98:24 102:23 38:15 39:5 40:19 breaching 18:2 75:25 82:25 84:18
B 4:6 112:17,18 106:18 108:12 40:24 87:4,4 break 10:15 97:20 85:19 86:4 87:1
114:13,14 116:18 124:5 131:4,5 134:19 135:19 115:16 161:18,21 97:21 100:17
116:20,22 117:1 133:19 142:23 136:3 145:5,15 186:8,8 133:16 154:13,15
120:12 121:3,6,12 150:21 151:17 146:6,10,13,15,21 breaking 37:17 161:24 167:23
143:24 149:24 152:16,17,21 146:22,23,24 breakwaters 174:2 186:6
back 18:25 19:2 158:11 163:2 147:10,10,17 103:18 brush 11:14

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BUCHLER 2:4 93:15 130:13 85:7 172:4,10 109:16 110:7 80:22 185:12,23
build 20:13 21:14 131:7 142:15 178:4 180:17 145:19 158:8 186:1 187:6
21:15 36:1,4,8 147:5 155:5,13 181:5 182:5 179:4 changing 175:15
90:18 100:8,14 157:12 161:12 capable 25:10 certainly 21:10 channel 27:5 101:9
178:5,18 179:7,18 162:4 164:1 166:1 case 47:21 63:15 29:12 112:2 153:3 145:20 146:1,18
building 35:9 71:18 168:17 169:20 64:21 65:16 72:16 154:16 178:1 165:25 166:4,7
71:18 170:16 176:21 91:22 94:8 97:1 certainty 178:12 167:8,15 168:16
buildup 99:11,14 178:14,23 180:10 102:2 109:10 CERTIFICATE 169:13 171:2,25
99:18 100:5,20 180:16,18 181:1 119:7 127:14 187:1 188:1 172:2,18 176:14
101:17,18,25 182:6,12 183:7 129:20,22 132:25 Certified 1:25 5:23 177:25 178:7,8,24
102:3 184:1,1 184:2,3,11 140:8,12 155:10 188:3,25 179:2,3,17 180:23
built 74:6,14 calculations 81:1 156:16 182:20,25 certify 187:4 188:4 181:12,14,20
184:11 82:3 131:6 157:1 cases 107:14,20 188:13 183:14
bunch 27:16 28:3 157:5,10,15,21 130:5,7 cetera 92:7 103:2,2 chapters 12:25
87:3 127:23 148:1 160:10,25 162:11 catalyst 87:5 141:24,25 character 15:14
165:22 165:21 167:1,10 catch 96:19 139:24 Chalmette 66:7,24 characteristic
bureau 114:3 169:7,12 170:6 categories 110:21 67:7 74:10,13 98:18 99:9 106:24
175:24 171:7,14 172:19 125:25 75:6 79:12 84:23 107:12,17 108:11
business 32:21 53:4 174:1,17 176:11 caught 34:12 85:3,6 86:1,12 108:13 130:17,24
61:18 90:1 131:1 176:20 177:17 cause 18:19 54:13 92:1,2,3,4,5,7,8,9 characteristics
154:17 179:8,15,23 180:5 56:1 186:1 188:16 92:10 93:11 96:23 38:15 95:8,13
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C 185:13 139:9 106:10 114:8,13 135:23 172:18
C 2:16,17 72:19,19 calibrate 132:9,13 causes 185:22 124:10,21 125:9 characterization
73:13,17,21,25 132:15 133:3 causing 172:5 126:6 128:17 39:18,19
75:5,6 76:22,25 calibrated 159:5 CCR 1:24 5:22 129:15,16,21 characterize 49:8
77:13 116:18,20 calibrating 158:25 188:2,24 131:4 132:25 characterized 49:2
121:4 126:16 calibration 159:8 Cecil 82:7,8,14 133:25 134:9 chargeable 172:11
128:23 129:1,23 call 7:17 16:13,18 center 83:3 84:1 141:11,16 160:14 CHARLES 3:21
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calculate 52:13 71:15 74:3 75:14 centered 33:15 chance 19:20 61:1 62:8,12 63:8
71:23 89:17 88:1 89:9,11 87:12 119:21 120:6 64:13 65:7,8,10
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181:11 92:2 99:19 101:16 118:9,10,11,15,18 changed 23:20,22 119:11 121:17
calculated 117:12 102:25 105:6 119:12,13 120:10 33:8,13 38:11,13 123:22 146:9
119:24 122:24,25 120:22 121:7 120:24 121:25 39:22 67:11 82:9 148:12 149:2,3,4
142:12,18,22,23 122:22 139:17 122:18 135:6,12 174:18 179:5 charts 66:9,23
144:14 160:24 148:5 152:7,10 135:19,25 141:24 changes 11:8 36:11 133:20
calculates 144:11 153:14 181:7 certain 6:24 49:21 36:17,19,22,24,25 chatting 97:22
calculating 82:15 183:25 52:12 59:23 86:7 37:1,2,4,14,16,18 check 133:2
155:21 158:10 calling 166:15 87:15 88:6,7,8 37:20,24,24 39:3 Chief 34:25 35:25
calculation 80:22 canal 1:4 82:16 89:19 101:23 39:7,12 41:17 166:12

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chose 134:12,17 147:24 174:5 completion 168:21 44:23 102:6 104:8 114:13
chosen 93:8 109:14 colonel 169:6 complicated 60:20 106:5 contains 18:5
157:23 column 161:7 component 99:25 Congressional contemplated 74:5
CHRISTOPHER 177:9 169:13 180:8 42:18 79:14
3:23 combination 95:7 components 44:21 connect 104:25 context 19:11 20:9
chronologically 98:16 99:6 106:23 computation connecting 75:15 21:9,24 22:7
27:22 89:25 107:2,10,11,22,24 153:21 connection 16:8 27:23 32:20 33:14
circa 140:24 121:23 computations 26:8,19 27:17 50:9 54:15,22
circular 164:7,8 combinations 148:6,10 140:17,23 165:25 61:2 65:5 68:15
Citrus 85:7 96:3 108:6 compute 149:11 connects 76:9 68:23 106:15
97:8 180:7 combine 108:15 computed 108:25 conservative 118:21,25 139:21
City 2:19 8:16 109:21 132:4 133:5,6 121:22 144:6 146:2
26:15,17 42:3,15 combined 10:24 150:2 consider 80:24 continuation 6:2
42:21 44:15 45:18 come 20:14 55:8 computer 188:9 100:12 111:20 continue 25:11
67:7,10 73:5 78:1 132:19 concerning 9:23 167:1 169:19 31:2 35:7 134:17
Civil 1:4 3:3 5:6 163:18 172:20 26:25 178:21,23 184:25 144:25
clarify 92:18 176:22 180:24 conclude 64:12 185:1 continues 138:9
CLAYMAN 3:24 181:4 185:16 90:14 94:15 97:13 considerable 59:24 continuing 55:12
clear 52:9 167:4 comes 33:4 47:11 99:17 106:4 consideration contribution 20:3,4
168:15 50:17 91:15 168:19 169:11 49:20 82:10 control 11:2 27:4
clearly 132:6 166:3 101:22 108:10,13 171:7 179:15 103:17 177:24 44:1 172:9
169:18 144:9 163:24 184:5 178:6 179:16 converge 101:8,11
CLL0 150:3 185:7 conclusion 13:8 180:11 184:14 copy 9:7,8 28:23
close 136:2 coming 55:4,10 67:22 103:4 considered 62:8 29:1 84:4,5,7 87:8
closely 133:22 57:2 63:13,25 179:25 79:10 95:8 98:17 153:5,17
closer 135:12,13 77:6 78:3 80:15 conclusions 12:1,6 106:24 111:18 Coriolis 153:24
136:14,16 183:8 12:20,24 13:4 112:18 150:17 Corps 1:13,14 3:12
coast 47:24 48:14 commenced 9:22 15:21 17:21 18:1 153:20 167:4 3:13 6:24,25 7:9
48:17 53:5,17 26:25 18:9 178:16 176:15 7:16 8:1 9:22
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57:11,11,13,21 166:8 107:16,18 184:21 considers 173:25 44:22 65:9,10
60:8 112:15 comments 169:6 conditions 95:7 consisted 20:5 69:25 70:15 72:5
115:16,19,23 common 178:20 98:17 99:6 106:23 CONSOLIDATED 79:15 82:2 89:20
123:20,25 124:3 community 136:17 conduit 8:2 1:5 90:17 91:2 101:5
125:10,11 136:19 confined 12:24 constricted 172:6 102:7,18 103:7
coastal 83:2,25 Company 85:16 confirm 120:8 constriction 101:21 105:10,14,17
87:24 compare 39:25 confuse 174:12 constructed 178:3 106:5,9 113:23
coastline 46:11 48:12 150:20 confused 41:7 construction 7:12 162:2 165:25
55:6 56:21 57:3 151:24 152:24 49:18 62:2 93:4 10:5 11:12 172:8 166:7 172:20
57:18 59:23 71:7 compared 124:6 94:4 139:15 145:4 consultants 9:4 177:24 185:15,21
coefficient 142:11 138:1 148:13 146:15 164:4 consulted 11:23 185:21,22
coexistent 181:23 152:6 174:10 24:17 27:10 correct 27:7 36:18
collectively 7:14 comparing 97:5 confusing 157:9 contained 11:5,25 38:1 42:6 52:20

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75:21 76:13 78:18 creating 172:4 187:25 degree 80:23 118:19

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94:10,13 95:23 63:22 65:19,19 Davis 166:12 Department 3:2 109:2,9 117:9
96:1,7 98:19 71:10 75:6,8 day 16:19 24:10 35:1 138:2 169:4,14
99:10 109:18 77:14 95:12 47:2 94:6 108:25 depend 71:12 describes 21:4
111:11 114:8 107:22 108:8,21 158:18,19,23 dependent 63:17 50:15 117:6
119:23 126:9,17 110:8,10,11 186:12 depending 60:5,8 126:15
128:12 132:23 124:21 125:2,8 day-to-day 50:1 65:20,21 94:16 describing 55:15
136:4 139:7 145:7 126:5 128:24 deal 21:11,13 107:20 156:13 175:4
145:9 159:7 129:11 130:23 dealing 95:18 177:12 description 10:18
160:20 162:6 135:4 145:15 185:25 depends 53:13 14:2,5 15:13 16:1
167:18 177:2 146:14 157:11 deals 9:18 182:6 183:17 16:7 36:4 40:16
187:7 188:11 183:4 DEBRA 3:24 deponent 5:10 40:19,20 49:24
corrections 153:20 crosses 79:22 debt 84:6 deposition 1:11 5:4 54:7 74:15,24
187:6,13,15 crosshatch 125:17 decide 28:10 41:16 5:14 6:3 12:25 75:1,2 111:14,17
correctly 60:22 crossings 172:7 decided 44:22 13:19 15:2 17:14 116:2 172:25
90:23 92:2 109:8 cross-section 38:8 177:5 18:18 24:24 25:11 descriptions 18:12
cost 185:25 Cs 72:13 decides 185:9 82:2 87:10 186:11 descriptor 87:16
council 9:1 cumulative 117:19 decisions 130:5 188:8 descriptors 109:20
councilmen 9:3 117:21 119:16 decrease 54:14 depositions 93:6 design 7:11 8:17
counsel 3:13 5:3 124:5,13 60:11 67:23 94:6 10:24,25 13:1,2
6:4,14 28:10 curious 76:14 decreasing 77:21 DEPO-VUE 3:25 13:14 14:6,7
188:14,14 current 9:13 deducing 78:21 depth 49:9 50:5,8 15:19 16:1,1,8
counterclockwise currents 153:19 deep 171:23 100:10 158:5,6,13 20:8,17,18 21:5
47:13,14 53:23 171:24 172:3 deepened 180:8 158:14,17,18,20 22:1,2 27:9 28:5
63:14 129:5 curve 52:1,3,4,13 deeper 179:6 158:24 159:17,20 38:7 39:5,7,22
couple 46:20,21,22 118:13 define 12:23 22:15 159:24 160:19,23 40:25 48:25 49:13
course 6:22 21:17 curves 52:4 46:13,14 94:21 161:4,11 162:3,11 51:4 62:21 63:1
29:23 32:14 45:14 101:18 118:17 162:22 163:10,10 65:18 66:5 69:17
52:7 82:13 151:21 D 119:2 138:16 163:21,22,23,23 69:20 71:3,5,9
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POWELL (VOL I), NANCY

IN RE: KATRINA CANAL BREACHES CIVIL ACTION

Johns Pendleton Court Reporters 800 562-1285

A adjacent 164:11 105:21 106:16,17 75:12,13 81:22 ASHLEY 2:22

Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

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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

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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

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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

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Johns Pendleton Court Reporters 800 562-1285

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